Privacy Policy

This Privacy Policy (“Privacy Policy”) describes how Compound Advisers, Inc., and its respective parent, agents, associates, affiliates, and subsidiary companies, divisions, or designees (“us,” “we,”, “our”, or “Compound”) may collect, use, protect, and share the personal information of our customers.  This Privacy Policy was last updated on October 26, 2020.  

This Privacy Policy explains how Compound may use your information and applies to all who access or use our website, mobile or tablet websites, services available and accessible via our websites, electronic services, social networking sites, interactive features, software, technology, tools, content, and any other materials or any other online activities or platform we own or control (collectively, the “Compound Site”), or when you contact us in any manner. 

SECTION 1.
AGREEMENT TO TERMS OF PRIVACY POLICY AND TERMS OF SERVICE
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All activities in which you may engage on the Compound Site are voluntary. You are not required to provide any personal information to us unless you choose to access features and/or the resources that may otherwise be made available to you on the Compound Site. Terms of Service If you do not agree with the terms of our Privacy Policy, please do not provide us with personal information. The Terms of Service of the Compound Site are expressly incorporated herein by reference and made a part of this Privacy Policy. By using the Compound Site, you signify that you agree to the terms of this Privacy Policy, which may be modified or amended at any time.

SECTION 2. 
EFFECTIVE DATE OF AND CHANGES TO PRIVACY POLICY
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This Privacy Policy is effective as of the date “Last Updated”, above, and will remain in effect except with respect to any of its provisions that are changed in the future, in which case the changes will become effective on the date they are posted on the Compound Site or when we otherwise notify you of the changes. We reserve the right to change this Privacy Policy at any time. Changes, modifications, additions, or deletions will be effective immediately upon their posting to the Compound Site. You should check this Privacy Policy periodically as its terms may change from time to time. Your continued use of the Compound Site after we post any such modifications will constitute your acknowledgment of the modified Privacy Policy and your agreement to abide and be bound by the modified Privacy Policy. We will also revise the “Last Updated” date found at the beginning of this Privacy Policy when we post changes to it. At minimum, Compound generally updates its Privacy Policy on an annual basis.

SECTION 3. 
NO USE OF THE COMPOUND SITE BY PERSONS UNDER 18 PERMITTED
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Compound intends for only persons who are 18 years or older to use the Compound Site. Personal information submitted by a person under the age of 18 will not be accepted, unless otherwise authorized by the appropriate parental consent. Any general information provided by a person under the age of 18 and gathered (for example, through the use of cookies) during his or her visit may be used as indicated in this Privacy Policy. Compound is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 18. 

SECTION 4. 
INFORMATION COLLECTION
PRACTICES.
Depending on how you use the Compound Site, we may ask you to share personal information with us. Whether you choose to give us information is completely up to you; however, if you choose to withhold information, you may not be able to fully utilize the Compound Site. What Information Does Compound Collect? We will receive, collect, store, and process information, including personal information and non-identifying information, when you interact with us and access the Compound Site, including our online store, or participate in a voluntary survey offered by us or an affiliate of Compound. Non-identifying information means information that alone cannot identify you, including data from cookies (discussed in greater detail below). Personal information means information about you that specifically identifies you, or, when combined with other information we have, can be used to identify you. You choose to give us certain information when using the Compound Site. This generally includes, but is not limited to the following types of information: Contact Information: your name, user name(s), password(s), postal address(es), business information, email address(es), telephone number(s), or other addresses at which you are able to receive communications, including your street address or post office box, city, state, and zip code.  Locational and Demographic Information: locational and geo-locational information, such as communities or neighborhoods; and demographic information, such as birth date, age, and gender. Transaction Information and general feedback: information you provide when you interact with us and the Compound Site, such as email, online form, and other communications, as well as content you post on the Compound Site, including on message boards or social media, or information, reviews, opinions, or testimonials you submit about us.

When Does Compound Collect This Information? We may collect information when you interact with Compound or our Site, for example when you: Access or use the Compound Site. Access our services, on or through the Compound Site. Register or create or edit your account via the Compound Site.  Sign up to receive our email newsletter and receive news, information, and exclusive offers, etc. Contact us and submit inquiries regarding general information and marketing. Post comments, or submit or upload photos or videos, reviews, testimonials, or other information and content to the Compound Site, including to our social media. Send emails to us, including attached files. Open or respond to our emails.  Contact customer support.

How Do We Use Your Information? In general, information you submit or share with us is used by Compound for various purposes, including but not limited to the following:  To enable your access to and use of our services and the Compound Site features to allow you to participate in interactive features offered by the Compound Site when you choose to do so. To create and manage your account. To personalize your experience and to allow us to deliver the type of content, advertising, and offerings in which you are most interested. To provide, maintain, protect, develop, and improve the Compound Site.  To provide you with information in response to your inquiries, and to provide you with customer support. To send periodic emails regarding your account. To email you information about the Compound Site. To assist us in taking data security precautions and to engage in fraud prevention, detection, and remediation. To detect, prevent, and address technical issues. To comply with applicable international, federal, state, provincial and local laws, directives, rules, regulations, and ordinances; civil, criminal or regulatory investigations; or other legal requirements, such as court orders. Information Collected Via Technology – Do We Use “Cookies”? As you use the Compound Site certain information may be passively collected and stored on our service providers’ server logs, including your device information, which may include, but not limited to, Internet Protocol address, browser type, device settings, operating system, and usage information (i.e., the Compound Site you use, the time and duration of your use of the Compound Site, and other information about your interaction with content offered through the Compound Site) (collectively, “Log Data”). We use Log Data to administer the Compound Site and we analyze, and may engage third parties to analyze, the Log Data to improve, customize, and enhance the Compound Site by expanding features and functionality and tailoring them to our users’ needs and preferences.

We also use cookies and navigational data, like Uniform Resource Locators (“URLs”), to gather information regarding the date and time of your visit and the solutions and information for which you searched and viewed, or on which of the advertisements displayed on the Compound Site you clicked.  

“Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the Compound Site. They are used to help us understand your preferences based on previous or current Compound Site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about Compound Site traffic and interaction so that we can offer you better online experiences and tools in the future. We may use both session cookies and persistent cookies to identify that you have logged into the Compound Site and to tell us how and when you interact with the Compound Site. We may also use cookies to monitor aggregate usage and web traffic routing on the Compound Site and to customize and improve the Compound Site. Unlike persistent cookies, session cookies are deleted when you log off from the Compound Site and close your browser. You can manage your cookie preferences via your particular browser settings.  

Information from Third Party Sources. We may use third party web trend analytical services, including Google Analytics, to collect visitor information, such as IP addresses, browser types, referring pages, pages visited, and time spent on a particular site. While these analytical services collect and report information on an anonymous basis, they may use cookies to gather web trend information. In addition, if you access and/or make use of third-party services, such as Facebook, Google, or Twitter, from the Compound Site, to log into the Compound Site, or to share information about your experience, we may collect information from these third parties. We encourage you to review the privacy policy and any terms and conditions for the social media platform and/or third parties whose services you use.

Mobile and Location Information. The Compound Site features may be accessible from web-enabled mobile devices. The intent is to provide screens that are optimized for the size of the screen and operating systems. On some devices, functionality may be limited. If you use mobile-enabled services provided by the Compound Site, we may receive information about you from your mobile device. This may also include information about your precise location, if you have enabled location-based services on your mobile device, access to your camera, microphone, or other device services or hardware.

Other Information We Collect. We also may collect other information about you, your device, or your use of the Compound Site in ways that we describe to you at the point of collection or otherwise with your consent.

Modifying, Deleting Your Collected Information. You can access and modify the information you provide to us via your account on the Compound Site or by contacting us in accordance with the “Contact Us” section below. If you want us to delete your information, please contact us in writing with your request, at info@withcompound.com or via mail in accordance with the “Contact Us” section below. We will take steps to delete your information as soon as is practicable, but some information may remain in archived/backup copies for our records or as otherwise required by law. You can adjust your communication preferences at any time, including opting out of promotional mailings, from your account.

How Long We Keep Your Collected Information. We will retain your information for as long as you use the Compound Site, and for a limited period after you cease using the Compound Site for certain administrative purposes.

SECTION 5. THIRD PARTY ACCESS TO YOUR INFORMATION.  
Although you are entering into an agreement to disclose your information to us pursuant to this Privacy Policy, we may use third party individuals and organizations to assist us, including contractors, web hosts, developers, and others. Throughout the course of our provision of the Compound Site to you, we may delegate our authority to collect, access, use, and disseminate your information. For example, our web host stores the information that you provide us, and we may hire outside contractors to perform maintenance or assist us in securing our Site, or, our online and mobile interface provider develops and hosts certain aspects of our Site for us. It is therefore necessary that you grant the third parties we may use in the course of our business the same rights that you afford us under this Privacy Policy. For this reason, you hereby agree that every authorization that you grant to us in this Privacy Policy, you also grant to any third party that we may hire, contract, or otherwise retain the services of for the purpose of operating, maintaining, repairing, or otherwise improving or preserving our Site or its underlying files or systems. You agree not to hold us liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you.  

THIRD PARTY USE AND DISCLOSURE OF INFORMATION.
Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent, or otherwise share for marketing purposes the personal information that we collect with third parties, unless you ask or authorize us to do so.  

However, we may provide your personal information to third party service providers or affiliates to perform business functions on our behalf or in conjunction with us. Our service partners may use your personal information to operate the Compound Site and to deliver their services. We limit information provided to the aforementioned affiliate and third-party service providers to the extent necessary for them to provide the services and require such service providers to promise not to use such information except as necessary to provide the relevant services to us. The use of your personal information by our service partners is governed by the privacy policies of those service partners and is not subject to our control.  

You hereby consent to us sharing your personal information under the circumstances described herein. If you do not want us to use or disclose personal information collected about you in the manner identified in this Privacy Policy, you may not use the Compound Site.

SECTION 6. 
SECURITY
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We are committed to protecting the security of your personal information. We use a variety of industry-standard security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. Even though we have taken significant steps to protect your personal information, no company, including us, can fully eliminate security risks associated with personal information. The Compound Site has security measures in place to prevent the loss, misuse, and alteration of the information that we obtain from you. Please keep in mind, however, that whenever you give out personal information online there is a risk that third parties may intercept and use that information. While we strive to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. Therefore, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us through the Compound Site, and that any personal information, general information, or other data or information received from you through the Compound Site are provided to us at your own risk, which you expressly assume.

SECTION 7. 
SPECIAL INFORMATION FOR NEVADA RESIDENTS
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Nevada law (SB 220) requires website operators to provide a way for Nevada residents to opt out of the sale of certain personal information that the website operator may collect about them. We do not sell your personal information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please email us at info@withcompound.com.

SPECIAL INFORMATION FOR MAINE RESIDENTS.  
Maine law (LD-946), also known as “An Act to Protect the Privacy of Online Customer Information”, requires particular website operators to provide a way for Maine residents to opt out from the sale of certain personal information that the website operator may collect about them. We do not sell your personal information to third parties as defined by Maine law, and will not do so in the future without providing you with notice and an opportunity to opt out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Maine data privacy law, please email us at info@withcompound.com.


NOTICE TO RESIDENTS OF COUNTRIES OUTSIDE THE UNITED STATES OF AMERICA.
Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you live outside the United States, and you use the Compound Site or provide us with personal information, your information will be handled in accordance with this Privacy Policy. By using the Compound Site or giving us your personal information, you are directly transferring your personal information and non-identifiable information to us in the United States. The United States may not have the same level of data protection as your jurisdiction. However, you agree and consent to our receipt, collection, transfer, and processing of your personal information and non-identifiable information in accordance with this Privacy Policy. You are solely responsible for compliance with any data protection or privacy obligations in your jurisdiction when you use the Compound Site or provide us with personal information.

CONTACT US.  
If you have any questions about this Privacy Policy, our practices related to the Compound Site, or if you would like to have us modify or remove and delete your personal information from our database, please contact us at:

Compound Advisers, Inc.
2261 Market Street #4301
San Francisco, CA 94114
Main: (415) 417-1180
Email: info@withcompound.com




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