Last Updated: February 21, 2023
How We Collect Information
We may collect information about you by the following means:
- Directly from you, when you provide information to us or interact with us;
- Automatically from you, when you utilize or interact with our Site or Services;
- Directly from you, when you complete applications, forms or questionnaires you may complete or agreements you enter into with us, including information about your credit history or financial situation, and your transactions with us or others who provide services to us.
- From other third party sources that provide consumer data, such as information about your interests, demographic information, and marketing inferences.
If you decline to provide us with the personal information we require, then we may not be able to make investment products available to you or to provide other Services to you.
Information We Collect
In order to better provide you with our Services, we may collect the following categories of information:
- Contact information and any other information you choose to include when you communicate with us via e-mail, mail, phone or other channels;
- Financial information, such as assets, income and financial situation;
- Transactional information including payment information and payment history if you engage in transactions through the Services;
- Device information when you utilize our technology platforms, including as model, serial number, device location, usage data, and operating information;
- Survey information in response to questions we may send you, including for feedback and research purposes;
- User Content you may provide to publicly post via the Services (e.g., comments);
- Online User Activity described in the next section;
- Biographical information when you inquire about or apply for a position with us.
If you provide us with information regarding another individual, you represent that you have that person’s consent to give us his or her information and to permit us to use the information in accordance with this Policy.
Online User Activity, Cookies and Information Collected by Other Automated Means
When you interact with the Services, certain information about your use of our Services is automatically collected. This includes:
- Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
- Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number);
- Location information where you choose to provide the website with access to information about your device’s location.
Much of this information is collected through cookies, web beacons, and other tracking technologies, which may be operated by our partners who assist us in serving ads or providing other services to you. Below is a list of our partners with links to more information about their use of your data and how to exercise your options regarding tracking.
You may be able to opt out tracking by cookies or control how information collected by cookies is used via a number of means, as described below.
How We Use Personal Information
We use your Personal Information for the following reasons:
- Enhance the quality of the Services we wish to provide in connection with the Services;
- To complete investments between you and Akmazo Management;
- Respond to your requests, questions and comments and provide investor support;
- To support our legitimate interests of maintaining and improving the user experience, and the Site;
- Monitor the performance of our Site including metrics such as total number of visitors, and traffic;
- Tailor the content we display to you in our Services and communications, including advertising, and offer products and services that we believe may be of interest to you;
- Manage, operate, and improve the Services and grow our business, including understanding our customer base and the effectiveness of our marketing, events, promotional campaigns, and publications, and diagnose or fix technology problems;
- Evaluate, recruit, and hire personnel;
- Comply with legal requirements and industry standards, detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and protect the rights of Akmazo Management, you, or others.
We may use and share information in an aggregated or de-identified manner at our discretion, including for research, analysis, modeling, marketing, and improvement of our Services.
How We Share Your Information
- Service Providers. We may share your information with service providers that we believe need the information to perform a technology, business, or other professional function for us such as billing and collection, IT services, maintenance and hosting of our Services, payment processors, marketing partners, accounting, auditing, and tax services, and other professional services.
- Analytics. We partner with analytics providers, who collect information via tracking technologies on our websites to assist us with measuring visits and traffic on our websites so we can measure and improve the performance of the sites.
- Corporate Event. We reserve the right to transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
- We share information where necessary to comply with applicable law, regulations, subpoenas, or to respond to requests from law enforcement agencies or other government authorities or third-parties, as required by law and without your consent when it is necessary to protect our customers, employees, or property; detect, prevent, or otherwise address fraud, security, or technical issues; in emergency situations; or to enforce our rights under our terms of service and policies.
Please note that Akmazo Management only discloses information to our employees and third-party organizations that (1) need to know such information in order to process it on Akmazo Management’s behalf or to provide services as described above, and (2) have agreed not to disclose it to any other parties without Akmazo Management’s consent.
How We Protect and Store Your Personal Information
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may need to keep your data for longer than our specified retention periods to honor your requests, including to continue keeping you opted out of marketing emails, or to comply with legal or other obligations.
We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries.
Your Privacy Options
You may have certain choices when it comes to how we collect and use your information:
- Email Marketing. If at any time you no longer wish to receive marketing communications from us, you can click the unsubscribe link at the bottom of any email or email us at email@example.com.
- Online Activity Tracking and Interest-Based Advertising. You have several options to either prevent our collection of information regarding your online activity, or prevent third parties from using such information from being used for interest-based advertisements:
- You can opt out or set preferences regarding cookies when a device you utilize visits the Sites, by clicking here to access our cookie management tool.
- You may be able to set preferences or block tracking across the internet by a particular third party by interacting directly with the third parties who conduct tracking through our Services by following the links provided above.
- You can usually modify your browser setting to disable or reject cookies across the internet. Note that if you delete your cookies or if you set your browser to decline cookies, some features of our website or Services may not function properly or be available.
- If you are visiting the Services from a mobile device, the operating system of the device may offer you options regarding how the device collects and uses your information for interest-based advertising. Click here for more information.
- Visit http://www.networkadvertising.org or http://www.aboutads.info to learn more about your options for opting out of interest-based advertising (or if located in the EEA, UK, or Switzerland, click here). Please note this does not opt you out of being served ads.
- Disclosure to Third Parties for Marketing Purposes. You may opt-out of disclosure of your information to third parties who offer products and services you may be interested in by emailing us at firstname.lastname@example.org.
Persons Under the Age of 18
The Site is not intended for persons under 18 years of age. No one under age 18 may provide any information to or on the Site. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information on this Site or on or through any of its features. If we learn we have collected or received personal information from someone under 18 years of age without verification of parental consent, we will delete that information as soon as possible and cease the use of that information in accordance with applicable law. If you believe we might have any information from or about a person under 18 years of age, please contact us email@example.com .
Certain jurisdictions may provide additional rights to individuals with respect to the collection and use of Personal Information that we have collected. For example, you may have the right to request that we: (i) disclose to you any Personal Information that we have about you; (ii) correct or delete Personal Information that we have about you (subject to certain exceptions); or (iii) not disclose or sell your information to a third party (excluding qualified service providers). If you are a resident of any of the following jurisdictions, click on your location to learn more.
Your California Privacy Rights
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties for those third parties’ own direct marketing purposes. If you are a California resident, you may opt-out of such sharing by emailing us at firstname.lastname@example.org or mailing a written request to Address, Attn: General Counsel.
California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of information about them, as well as rights to know/access, delete, and limit sharing of Personal Information. You have the right to be free from discrimination based on your exercise of your CCPA rights.
Akmazo Management may disclose your Personal Information to commercial providers for a business purpose. When we disclose Personal Information for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not to use it for any purpose except for the purposes set forth in the contract.
Notice at Collection Regarding the Categories of Personal Information Collected
You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. The categories we use below to describe the information are those enumerated in the CCPA.
Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. Service providers are restricted from using Personal Information for any purpose that is not related to our engagement.
The following chart describes information we collect when you act as a customer or prospective customer of our products and services or visit our website. We do not sell Personal Information. We collect this Personal Information for the purposes described in the “Information We Collect” section above.
|Category||Examples||Sold To||Disclosed To|
|Personal Identifiers||first and last name, email address, and contact address, username, basic account information, unique identifiers (such as those assigned in cookies)||Not sold||Service Providers and Affiliates|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||name, address, telephone number, employment, employment history||Not sold||Service Providers and Affiliates|
|Commercial information||transaction information, billing records, payment records, order history, auditing, accounting||Not sold||Service Providers and Affiliates|
|Electronic, or similar information||customer support services||Not sold||Service Providers and Affiliates|
|Professional or employment related information||employment history||Not sold||Service Provider|
|Internet or other similar network activity||unique numerical identifier, cookie or tracking pixel information, device ID, browsing history, search history, IP address, interaction with a website, interaction with an application, or interaction with advertisement, analytics, security, data storage, email and mailing services||Not sold||Service Providers and Affiliates|
|Geolocation data||coarse information (e.g., ZIP code, IP address), device location||Not sold||Service Providers and Affiliates|
|Inferences drawn from other Personal Information||interests, preferences||Not sold||Service Providers|
first and last name, email address, and contact address, username, basic account information, unique identifiers (such as those assigned in cookies)
Service Providers and Affiliates
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
name, address, telephone number, employment, employment history
Service Providers and Affiliates
transaction information, billing records, payment records, order history, auditing, accounting
Service Providers and Affiliates
Electronic, or similar information
customer support services
Service Providers and Affiliates
Professional or employment related information
Internet or other similar network activity
unique numerical identifier, cookie or tracking pixel information, device ID, browsing history, search history, IP address, interaction with a website, interaction with an application, or interaction with advertisement, analytics, security, data storage, email and mailing services
Service Providers and Affiliates
coarse information (e.g., ZIP code, IP address), device location
Service Providers and Affiliates
Inferences drawn from other Personal Information
In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.
California Privacy Rights
- Right to Access/Right to Request. The CCPA permits you to request and obtain from us information regarding the disclosure of your personal information that has been collected in the past twelve months by the us or our subsidiaries to a third party for the third party’s direct marketing purposes.
- Right to Delete. Except as required by the Health Insurance Portability and Accountability Act of 1996 or other applicable law, you also have the right to request the deletion of your personal information that has been collected in the past twelve months.
How to Submit A Request
In order to exercise any of your rights, you can contact us at email@example.com.
Upon submission of your request, we will contact you via the email address provided in your request. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In some instances, such as a request for data deletion, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request. With all requests, we will aim to complete requests as soon as reasonably practicable and consistent with any timeframes mandated by applicable laws. If we require more time, we will inform you of the reason and extension period in writing. You may authorize another individual or a business registered with the California Secretary of State, or designate an authorized agent, to make requests on your behalf through these means.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
EEA, Switzerland and/or UK Privacy Rights
If you are located in the EEA, Switzerland, or the UK, you are entitled to certain rights, subject to applicable exceptions, under the GDPR, Swiss, and UK data protection laws. Please note that, in order to verify your identity, we may require you to provide us with information prior to accessing any records containing information about you.
We typically will process your information pursuant to the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services to you; or (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy. We also may process your information where it is necessary to comply with a legal obligation to which we are subject.
EU/UK Privacy Rights
- Right of Access: You have the right to obtain confirmation as to whether we are processing personal data about you, and if so, request a copy of the personal data. If you would like a copy of the personal data that we hold about you, please send a description of the personal data you would like a copy of and proof of your identity to our email as set forth below.
- Right to Correction: You have the right to correct any inaccuracies in the personal data that we hold about you and, where applicable, to complete any incomplete personal data that we hold.
- Right to Erasure: You have the right to request that we erase the personal data that we hold about you if one of the conditions in Article 17 of the GDPR applies. The right to erasure does not apply in certain circumstances, including where the processing is necessary for the establishment, exercise, or defense of legal claims.
- Right to Restriction of Processing: You have the right to restrict our processing of your personal data if one of the conditions in Article 18 of the GDPR applies.
- Right to Data Portability: You have the right to receive personal data concerning you in a structured, common, and machine-readable format or request transmission of the data to a third party, if the conditions in Article 20 of the GDPR are met.
- Right to Object: You have the right to object to the processing of your personal data based on our legitimate interests at any time. We will no longer process the data, unless there are compelling legitimate grounds for our processing that override the interests, rights, and freedoms of the data subject, or the processing serves the purpose of asserting, exercising, or defending legal claims. You also have the right to object at any time to the use of your data for direct marketing.
- Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.
How To Submit a Request
To submit a request to exercise your rights, please email us at firstname.lastname@example.org. We may have a reason under the law why we do not have to comply with your request, or may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Cross-border Transfer of Data
If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. By using the Services, you consent to the collection, international transfer, storage, and processing of your data.
Lodging a Complaint
Users that reside in the EEA, Switzerland, or the UK have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.
It is our policy to post any changes we make to the Policy on this page. The date the Policy was last revised is identified at the bottom of the page. You are responsible for periodically visiting the Site and the Policy to check for any changes.
How to Contact Akmazo Management
Contact email@example.com when you notice any suspicious account activity or experience any information security related events.
Ready To Learn More?
Send us a quick note about why you are requesting more information to the address below.
199 Wells Avenue, Newton, MA 02459