Last Updated: October 3, 2022
Our website located at www.https://gridline.co
When you interact with us in any other way.
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.
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:
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:
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 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.
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.