Last Updated: October 3, 2022 Gridline Holdings, LLC and its affiliates (collectively, “Gridline,” “we”, “us” or “our”) know that privacy is very important to you. We have created this privacy policy (the “Privacy Policy”) to describe what kinds of personal information we may obtain through:
Our website located at
www.https://gridline.co (the “Site”);
Any other website, mobile application, or digital property that links to this Privacy Policy; and
When you interact with us in any other way.
By accessing or using the Site or any other website, web application, or digital property that links to this Privacy Policy (collectively, the “Digital Properties”), you may (i) access our proprietary interactive platform (the “Platform”); (ii) register with Gridline as a customer (“Customer”), open an account (“Customer Account”), and invest in Gridline alternative investment funds (“Gridline Funds”); or (iii) register with Gridline as an investment advisor (“RIA”), open an account (“RIA Account”), onboard your clients and investors (“RIA Clients”), and select and manage your RIA Clients’ investments in Gridline Funds (collectively, the “Services”). If you are under the age of 18, you may not use our Services.
Gridline provides investment advisory services to the Gridline Funds, with an investment strategy focused on private market alternative investments. If you invest (or have taken steps to invest) in Gridline Funds as our Customer, or through your RIA, please also review our Gramm-Leach Bliley Act (“GLBA”)
Privacy Notice for a description of our processing and disclosure activities regarding the non-public personal information that we (i) collect from you as our Customer, or (ii) receive about you from your RIA, in our capacity as a financial institution subject to the GLBA.
By accepting this Privacy Policy, visiting our Digital Properties, or accessing or using any of the Services, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy and the accompanying
Terms of Use, which together make up the Agreement. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy or any other terms of the Agreement, you may not access or use the Services. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our
Terms of Use.
This Privacy Policy will help you understand the following:
We may collect or receive the following types of information from or about you, which may include personal information.
We collect contact information through our Services, which may include your name, email address, phone number, business contact data (e.g., title, company name, office phone number and company email address), and any information you provide in messages to us (“
Contact Information”). We use Contact Information for purposes such as starting an application to obtain a Customer Account or an RIA Account, providing you with information about the Services, responding to your inquiries, sending you email alerts (including marketing emails), or providing you with the Services.
Customer Accounts: Our Customers include a variety of individuals and institutions that invest in Gridline Funds by registering for one or more Customer Accounts. Depending on the type of account (personal or institutional), we may require that you provide certain information in addition to Contact Information such as your date and country of birth, nationality, passport numbers (or numbers associated with other government issued identification), Social Security Number or Tax ID, education, gender, interests, photo, employment status, occupation, employer name and address, marital status, financial information such as bank account and payment card details, suitability information, income, revenue, and other sources of funds, net worth, trusted contact information, account balance, credit scores, tax information and other information about financial situation and risk preferences. We reserve the right to accept or decline any application(s) for Customer Accounts in our sole and absolute discretion.
Customer – Investment Agreements: If you decide to invest in a Gridline Fund, additional or updated information may be required, and you will be required to acknowledge certain disclosures and enter into various agreements with the Gridline Funds which may include, but are not limited to, operating agreements and subscription agreement(s) (collectively, “Investor Agreements”). Investor Agreements will be furnished to Customers for signature by Gridline. Gridline shall retain the executed Investor Agreement(s).
RIA Accounts: SEC registered investment advisors may register for an RIA Account. We may require that you provide information in addition to your Contact Information such as confirmation of your SEC registration, identity verification data, and other information. We reserve the right to accept or decline any application(s) for an RIA Account in our sole and absolute discretion. If your application is approved, you will be required to enter into certain agreements with Gridline.
RIA Client(s): RIAs are required to input Contact Information into their RIA Account regarding each RIA Client. Depending on the type of RIA Client (personal or institutional), RIAs will be required to provide certain additional information such as date and country of birth, nationality, passport numbers (or numbers associated with other government issued identification), Social Security Number or Tax ID, education, gender, interests, photo, employment status, occupation, employer name and address, marital status, financial information such as bank account and payment card details, suitability information, income, revenue, and other sources of funds, net worth, trusted contact information, account balance, credit scores, tax information and other information about financial situation and risk preferences.
RIA Client – Investment Agreements: RIAs may select one or more Gridline Funds for investment by an RIA Client, and use app.gridline.co to submit their investment interest (e.g., a completed and signed sub-agreement). Gridline may request additional or updated information regarding the RIA Client, and reserves the right to accept or decline any request to invest in any Gridline Funds. When an RIA Client is approved for investment, Gridline will prepare and provide to the RIA required Investor Agreement(s) for the selected Gridline Funds. Upon RIA’s approval, the Investor Agreement(s) will be furnished to RIA Clients for signature by Gridline. Gridline shall retain the executed Investor Agreement(s).
Investor Agreements and Fees: Investor Agreements are strictly between the Gridline Fund(s) and the Customer and/or RIA Client, as applicable. Gridline is not a party to any Investor Agreements and assumes no obligations, duties, or liabilities related to or arising from any Investor Agreement. Gridline may request that Customers and/or RIA Clients, as applicable, provide ACH transfer information or wiring instructions in connection with their investment. Applicable fees and payment terms are described, as applicable, in the Investor Agreements or the RIA Services Agreement.
When you access or use any of our Services, we use browser cookies, pixels, web server logs, web beacons, and similar technologies (collectively,
“Tracking Technologies”) to automatically collect or receive certain standard technical information and other data (such as traffic data, location data, logs and other communications data) sent to us by your computer, mobile device, tablet, or any other device over time on our Digital Properties, and your online activity across third party websites, apps, and devices. We may also evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of the Services.
When you access or use any of the Services, advertising companies, analytics networks and providers, and other third parties may also use Tracking Technologies to collect information about your online activities over time on our Digital Properties and across different websites, apps, online services, digital properties and devices.
The data we or third parties collect automatically may include personal information and/or statistical data that may not identify you personally; however, we or third parties may maintain, combine, or associate it with personal information collected in other ways or received from third parties. We and/or third parties use this information to (i) enhance the performance and functionality of our Services; (ii) personalize your experience with the Services, understand how you use the Services, maintain a persistent session, and improve and further develop our Services; and (iii) serve targeted and other advertising, and provide custom experiences, across other sites, apps, online services, digital properties and devices, measure how the ads perform, and for analytics purposes.
The Tracking Technologies used on the Services include the following, among others:
Cookies: Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. In addition to collecting information, we use cookies to help us authenticate users, provide content of interest to you, analyze which features you use most frequently, and measure and optimize advertising and promotional effectiveness. To do this, we may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them. For information regarding your choices regarding Cookies, please see Section III of this Privacy Policy.
Local Storage Technologies: We may use local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web Beacons: We use Web beacons, also known as pixel tags or clear GIFs, to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.
Third Party Sites: When access to the Services is made available to you through third-party sites, such as social media, please be aware that these other sites maintain their own policies regarding Tracking Technologies and the collection and use of information. You are responsible for reviewing those policies.
To provide access to the Services while you are using an electronic device, we automatically collect geolocation information from your mobile device, your wireless carrier, or certain third-party service providers (
“Geolocation Information”). Collection of such Geolocation Information occurs only when the Services are running on your mobile device. You may control the collection of Geolocation Information through the user settings on your device. You may decline to allow us to collect such Geolocation Information, in which case we may not be able to provide access to the Digital Properties or certain Services to you. Please be sure to manage your mobile device and privacy preferences on the Platform on an ongoing basis.
Service Providers: We may collect or receive your personal information from third party service providers such as credit bureaus and service providers (e.g., providers of Anti-Money Laundering (
“AML”) or Know Your Customer (
“KYC”) services).
Social Media/Third Party Websites: We may collect or receive your personal information when you visit, use, or access the Services from third-party websites. We will do so in accordance with the Terms of Use and privacy policies of the third-party websites and applicable law. This includes any social media pages we may have on third-party services such as Twitter and LinkedIn. For example, we may collect the information you shared on our social media pages through an application or form, which will have a hyperlink to this Privacy Policy. Personal information may also be collected by the third-party social media sites that host our social media pages. These sites may provide aggregate information and analysis to us about their visitors’ use of our social media pages. This allows us to better understand and analyze our user growth, general demographic information about the users of these pages, and interaction with the content that we post. This Privacy Policy does not cover personal information collected by such third-party sites. For more information on their privacy and security practices please review the privacy policies and Terms of Use on their respective websites.
Government and Public Sources: As permitted by applicable law, we may also collect or receive your personal information from publicly available government records, directories, and sources such as courts, tax authorities, government agencies, regulatory authorities, and law enforcement.
Inferences: We may collect or receive inferences, which are assumptions or extrapolations that have been drawn from your information to create a profile which may include your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Text Messaging Program: This information includes your name, mobile phone number, and texting preferences (opt-ins and opt-outs). We use this information to send you text messages and manage our text messaging program. Please note that your mobile phone carrier may collect data about your wireless device usage, and that its practices are governed by the provider’s own policies.
Data Providers: We may license or otherwise acquire demographic and other information from third party information services, data licensors, and data brokers.
Marketing and Advertising Partners: We may receive information from our marketing and advertising partners, such as joint marketing partners and event co-sponsors.
We use third-party analytics services (such as Google Analytics) to evaluate your access and use of the Digital Properties and the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to device and internet usage. These third party analytics services use cookies and other Tracking Technologies to help analyze and provide us the data. By accessing or using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. The information used by such analytics services is generally at the aggregate level. Google and other services may associate such data with visitation information collected from our Digital Properties.
We may change these third-party analytics services from time to time. For more information on our analytics services, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services. If you have any questions, or to request a current list of our third-party analytics services, please contact us as set forth in Section XI.
Update Information: If the personal information we have for you changes, you may correct, update, or delete it by contacting us as set forth in Section XI of this Privacy Policy. Customers and RIAs may correct, update, or delete some of their personal information directly in their respective accounts. RIA Clients should contact their RIA to correct, update or delete their personal and other information. We will use commercially reasonable efforts to process all such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. Additionally, we will retain and use your information (or copies thereof) as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.
Marketing Communications: You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing emails. Please note that you cannot opt out of receiving transactional e-mails. If you are part of our text messaging program, you can opt out of receiving marketing and non-transactional messages by texting “STOP” in response.
Cookie Management: Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies or other Tracking Technologies, the Services may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit
www.allaboutcookies.org.
Advertising choices: You can limit use of your information for interest-based advertising by:
- Browser settings. Blocking third-party cookies in your browser settings (above);
Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block Tracking Technologies;- Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:
- Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
You will need to apply these opt-out settings on each device from which you wish to opt-out. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
We follow commercially reasonable and generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. Please understand, however, that no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security regarding our The Services, please contact us.
Our Services are only available to individuals aged 18 or older, and we do not knowingly collect personal information from any person under the age of 18. If an individual under the age of 18 has provided us with personal information , a parent or guardian of that child may contact us and request that such information be deleted, and we will endeavor to delete that information from our databases.
As discussed above, third parties such as advertising networks and analytics providers may collect information about your online activities over time and across different websites when you access or use the Services. Currently, various browsers offer a “Do Not Track” option, but there is no standard for commercial websites. At this time, we do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
The Digital Properties and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us maybe transferred to, processed, maintained, and used on computers, servers, and systems 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 are located outside the United States and choose to access or use the Services, you consent to any transfer and processing of your personal information in accordance with this Privacy Policy, and you do so at your own risk.
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may update this Privacy Policy from time to time without notice to you. We will indicate at the top of this Privacy Policy when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes. By accessing the Services after we change this Privacy Policy, you are deemed to have accepted such changes.
