PRIVACY POLICY

Point Capital Services has created this privacy statement in order to demonstrate our firm commitment to privacy.

OVERVIEW

Point Capital Services, LLC (collectively, “Point Capital Services”, “we”, “us” or “our”) respect your privacy and are committed to complying with this privacy policy (the “Privacy Policy”). This Privacy Policy describes our information collection and sharing practices that apply to the information collected on the websites on which this Privacy Policy is posted (each, a “Website”), any current or future mobile application associated with a Website (each, a “Mobile Application”), and any associated functionality contained on a Website or Mobile Application (collectively, the “Services” and, together with a Website and the Mobile Application, the “System”)

In this Privacy Policy, “you” and “your” refer to you, the individual accessing the System and/or using the Services.

This Privacy Policy applies to information we collect through the System only. If you are a consumer or our customer, please refer to the GLBA privacy notice which you may have received from us for a description of our practices and procedures regarding compliance with privacy laws and/or regulations which may also be applicable to you, such as the federal Gramm Leach Bliley Act (“GLBA”).

BY ACCESSING OR USING THE SYSTEM, OR ANY PORTION THEREOF, YOU ACKNOWLEDGE THAT YOU HAVE READ, AND UNDERSTAND OUR PRIVACY POLICY.

This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party.

WHAT PERSONAL INFORMATION IS BEING COLLECTED?

The following information may be collected when you use this web site: – your server address; – the date and time of your visit to the web site; – the pages you accessed and the documents downloaded; – the previous web site you visited; and – the type of browser you are using. This information is collected for statistical purposes and to enable us to improve the navigation functions of our web site. Where permitted by applicable law, third parties may be used from time to time to collect the above listed information and information on your online activities. Additionally, this web site may ask for specific personal information in order to respond to requests for information or to register users for particular services. This can include but may not be limited to:

COOKIES AND USAGE REPORTS

By placing a small file known as a “cookie” on your computer (or other device), Point Capital Services and our third party service providers’ servers passively gather information about all visitors’ use of the System for several reasons, including, but not limited to, the following: statistics collection and analysis, System optimization, analytics (as described below), market research, and maintenance of user login information. The information that we and our third party service providers track with cookies includes, but is not limited to, the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the System, your Internet protocol (“IP”) address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the System), how you were directed to the System, which specific pages you access on the System, how long you view each page, the time and date you access our System and the total number of visitors to the System and any portions thereof. We and our third party service providers, may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience while visiting the System. This data helps us and our third party service providers improve our respective product and services.

Most popular Internet browser applications will allow you to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of the System (or some portion thereof) and its capabilities, or cause some features of the System to function improperly or more slowly.

THIRD-PARTY SERVICE PROVIDERS AND WEB BEACONS

Our Websites may use third-party services such as Google Analytics, Facebook Pixels, and similar web analytics services.

We use Google Analytics, a web analysis service provided by Google, in order to better understand your use of our Websites and how we can improve them. Google Analytics collects information such as how often users visit a Website, what pages you visit when you do so, and what other websites you used prior to coming to such Website.

Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a Website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the Websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Websites to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the Websites, please review “How Google uses information from sites or apps that use our services” (located here or any successor URL).

We may also use Facebook Custom Audience Pixels (“Facebook Pixels”), a tool that permits third parties, including Facebook, to use cookies, web beacons, and other storage technologies to collect or receive information from our Websites and elsewhere on the internet and use that information to provide measurement services and target ads. Please click here if you would like to opt out of the collection and use of information for ad targeting through Facebook Pixels. Other mechanisms for exercising such opt-out choices are available including, without limitation, on websites such as http://www.aboutads.info/choices.

Some of the areas of the System contain electronic images known as web beacons (sometimes known as clear gifs) that allow us, and our third party providers or affiliates, to count and track users who have visited certain portions of the System. Web beacons collect only limited information and do not collect any of your personal information. Specifically, we use a type of web beacon by FullStory, which tracks in-browser interactions by you on a Website. FullStory collects information on your use of our Websites, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, cookie information, and Internet Service Provider (collectively, “Usage Data”). FullStory’s purpose in collecting Usage Data is to better understand how you and other visitors use a Website. We and FullStory do not use the Usage Data to identify the Website visitors and we do not disclose the Usage Data other than under the circumstances described in this Privacy Policy. All contact form input fields on our Websites are excluded from FullStory’s tracking and collection. You may opt-out of the use of FullStory here: https://www.fullstory.com/optout/.

CORRESPONDENCE

We appreciate your questions and comments about the System and Services and welcome your messages at our “Contact Us” page, which you can find at https://www.pointcapitalservices.com/contact-us/. If you correspond with us through the System or via email, the Collected Information may include the content of, and metadata regarding, any correspondence you may have with us. We may share your messages with those within our organization who are most capable of addressing the issues contained in your message. We may archive your message for a certain period of time or discard it.

HOW TO OPT OUT OF PROMOTIONAL CORRESPONDENCE

We may send you emails with promotional offers only if you opt in to receiving such emails. If you would no longer like to receive information, newsletters or other promotional messages from us, please click the link at the bottom of any such email you receive from us and follow the instructions, or alternatively you may contact our Customer Service (as provided below) in order to unsubscribe or have your email address removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process.

ONLINE ACCOUNT MANAGEMENT

If you elected to subscribe to any online services provided via the System, including the ability to access any password-protected areas of the System, you will be required to submit personal information (including some Collected Information) for the purpose of verifying your identity and your authority to manage the account. This Collected Information will be used exclusively by us, our agents, suppliers and third-party service providers for internal use and to respond to your service requests.

HOW WE USE THE INFORMATION THAT WE COLLECT

We and our third party services providers collect and use the Collected Information to operate the System and deliver the Services, including to provide certain services and improve the user experience, address System integrity or security issues, and conduct research and analysis to maintain, protect, develop, and improve the System, sell certain merchandise, and, additionally, use any information submitted by you as described below or elsewhere in this Privacy Policy. We may send you information that you request from us, promotional materials regarding Point Capital Services or any other entity or individual affiliated with our corporate family, and any other communication for any other legitimate and lawful business purposes. Additionally, we may retain and use certain Collected Information to facilitate and otherwise address certain inquiries or requests regarding the Services or the System, or respond to your questions or requests for information about or from us. We may also use Collected Information as necessary to ensure compliance with any of our policies and any applicable law, regulation or order.

Except as set forth in this Privacy Policy, we will not use, disclose, or transfer your Collected Information unless:

  1. you expressly authorize us to do so;
  2. it is necessary to allow our service providers, agents, or other third parties to provide products or services for or to us;
  3. it is necessary in order to provide the System or the Services;
  4. subject to applicable legal restrictions, we are sending you other information that may be useful to you;
  5. subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements;
  6. it is necessary to protect the confidentiality or security of your records;
  7. it is necessary in connection with other business purposes including, without limitation, verifying identity, age, or payment details; investigating complaints about the System; risk assessment, security, fraud and crime prevention/detection; monitoring, research and analysis; marketing, customer purchasing preferences, and trends; and dispute resolution;
  8. it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity;
  9. subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all of the assets of one of our companies or the merger of one of our companies into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which our company is not the survivor; or
  10. it is otherwise necessary for us to disclose it as required or permitted by law.

WITH WHOM WE SHARE THE INFORMATION THAT WE COLLECT

In addition to the uses mentioned or described elsewhere in this Privacy Policy, we may catalog and add Collected Information to our database which may be shared with our affiliates.

We do not sell, rent, or lease our user lists or the identity of individual users to third parties, except as permitted or required by applicable law. However, we may use and disclose certain aggregated, anonymized information, such as System usage data, to our trusted business partners. Such information may also be shared as permitted or required by applicable law.

We may also disclose Collected Information if we become subject to a subpoena or court order, or if we are otherwise legally required to disclose information. We may also use and disclose Collected Information to establish or exercise our legal rights, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

As we grow and develop our business, it is possible that our corporate structure or organization might change or that we might merge or otherwise combine with, or that portions of our business might be acquired by, another company. In any such transactions, customer information generally is, and should be expected to be, one of the transferred business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.

PROMOTIONS AND SURVEYS

On the System, you may wish to participate in certain online polls, surveys and other promotions that may be offered from time to time by us, a partner, or other entity through which you are using the System. Participation in these polls, surveys and promotions is completely voluntary; you have a choice about whether or not to disclose information required to enter. Information requested may include Collected Information such as your name, address, date of birth, phone number, mobile phone number, e-mail address, username, and/or similar information. Through these online polls, surveys and promotions, you may choose to participate in activities such as sharing information with others and sending email invitations. In connection with any online polls, surveys and other promotions that may be offered from time to time via the System by us, we use the information you provide to administer the polls, surveys and other promotions. Subject to applicable contractual or legal restrictions, we also may use the information to communicate with you, or the other people you select, about our services or products.

YOUR CHOICES REGARDING OUR PRIVACY PRACTICES

When submitting information, corresponding, making requests for information, and otherwise interacting with us and our representatives through or in connection with the System, including by utilizing the Services, you choose what information to supply or submit, whether you wish to receive further information, and how you may be contacted. Please take care to share only such information as is needed or that you believe is appropriate. Any promotional email we send to you will contain a link which will allow you to opt out of receiving any further correspondence.

HOW WE PROTECT INFORMATION COLLECTED ABOUT YOU

We take commercially reasonable measures to secure and protect information transmitted via or stored on the System. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the System may happen to transmit or otherwise supply will be totally secure.

LINKED WEBSITES

For your convenience, some hyperlinks may be posted on the System that link to other websites not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that we do not own or control, and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. We encourage you to seek out and read the privacy policy of each website that you visit.

If you initiate a transaction on a website to which our System links, even if you reached that site through the System, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy policies to understand how personal information that is collected about you is used and protected.

USER-PROVIDED CONTENT

Any information, communications, or material of any type or nature that you submit to the System by e-mail, posting, messaging, uploading, or otherwise (collectively, a “Submission”) is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of the System and we are therefore not responsible for any Submissions contained on a Website.

Additionally, in the event that we offer a message board or any other interactive or social-type feature on a Website, including comments to blog posts, please be aware that these areas may allow you to post, and share with other users, certain messages, content, or other information. We encourage you to be wary of giving out any personal information, or any personal information of others to which you may have access, in such forums. The information you post can be collected and used by other people. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk.

SOCIAL MEDIA PLATFORMS AND WEBSITES

Any Submission that you submit to any of our pages contained on a social media platform or website by e-mail, posting, messaging, uploading, or otherwise is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of a social media platform and we are therefore not responsible for any Submissions contained on a social media platform or website. We encourage you to review the applicable privacy policy and terms of use of any such social media platform or website prior to making any such Submissions.

RIGHT TO VERIFY THE ACCURACY OF INFORMATION WE COLLECT

Keeping information accurate and up to date is important to us. An individual may see and correct their personal information that they provided to us, subject to certain legal or contractual limitations. Contact us as described below if you wish to verify your personal information.

INFORMATION COLLECTED FROM CHILDREN

The System is intended for a general audience and is not intended for use or view by children under 13 years of age, and we do not knowingly collect information about children or sell products to children. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13. If you are under the age of 13, you are not permitted to submit information to the Site.

All information submitted through our Websites must be submitted by the parents or legal guardians of the children to whom any such information relates.

VISITING THE SYSTEM FROM OUTSIDE THE UNITED STATES

If you are visiting the System, or any part thereof, from outside of the United States, please be aware that your information may be transferred to, stored, or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using any portion of the System, you understand and consent to the transfer of your information to our facilities in the United States and those third parties with whom we share your information, as described in this Privacy Policy.

DO NOT TRACK REQUESTS

California and Delaware laws require that we indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. We adhere to the standards set out in this Privacy Policy, and do not monitor or follow any Do Not Track browser requests.

FOR MORE INFORMATION

If you have any questions about this Privacy Policy, please contact us at https://www.pointcapitalservices.com/contact-us/.
This Privacy Policy was last updated on May 16, 2021.

OPT-OUT POLICY

Opt out of Movement marketing messages and limit information sharing (to the extent applicable, per the Gramm-Leach-Bliley Act) by Contacting US at https://www.pointcapitalservices.com/contact-us/.

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