Privacy Policy
Access Industries, Inc. (together with its affiliates, “Access”, “we”, “us”, or “our”) is committed to protecting your privacy. The following policy (the “Privacy Policy”) describes our practices respecting the collection, storage, use, and processing of personal data that you share with us, including through this website (the “Site”).

Privacy Policy Updates
This Privacy Policy was last updated on October 23, 2019. It provides a general overview of the ways in which Access uses your personal data and important information on electronic communication. This Privacy Policy may be changed at any time to reflect changes in Access’s practices concerning the collection and use of personal data or where required to comply with applicable law. Any revised Privacy Policy will be effective immediately upon posting to this Site. Access recommends checking this section of the Site frequently to view the latest updates.

The Type of Personal Data Access May Collect
Access may collect and use the following types of personal data, without limitation:

  • Contact details (including names, postal addresses, email addresses, telephone numbers, and fax numbers);
  • Information required for Access to meet legal and regulatory requirements, in particular respecting anti-money laundering legislation – including information on source of funds, source of wealth, investor qualifications, and tax-related information – and employment-related information;
  • Information provided in the course of the provision of its services (e.g., information on professional relationships and background, financial wealth and assets held, transactions entered into, birth date, nationality, passport or other identification number, and employment information);
  • Financial information;
  • Technical information about interactions with our Site, such as your IP address;
  • Meetings attended and visits to Access offices; and/or
  • Any other information you may provide to Access.

How Access Collects Personal Data
Access may collect your personal data from the following sources:

  • Information provided by you in writing, in person, by telephone, electronically (including via the Site), or by any other means;
  • Publicly available sources, such as the corporate website of the organization you are working for;
  • Interactions with social media and use of other websites that display our advertisements, if any;
  • Cookies on our Site (for more information regarding the use of cookies, please see the additional guidelines printed below);
  • Third-party vendors who may analyze the use of the Site; and/or
  • Our IT systems.

How Access Uses Personal Data
Access may use your personal data for the following purposes:

  • To facilitate the provision of our services to you;
  • To operate and improve our Site, such as resolving technical issues, supporting security, analyzing user trends, detecting fraud or other types of abuse, and gathering broad demographic information for aggregate use;
  • To carry out anti-money laundering checks and related actions that Access consider appropriate or necessary to fulfill any of its legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with Access’s anti-money laundering policies and procedures;
  • To comply with its legal obligations and, in particular, to report tax-related information to tax authorities;
  • To monitor and record electronic communications for any of the purposes specified herein;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred; and/or
  • To otherwise pursue the legitimate interests of Access relating to our business.

Where required under applicable law, Access is able to legally collect and use your personal data because:

  • You have consented to its doing so;
  • Collecting and using your personal data is necessary to fulfill legitimate business interests, which may include (i) fulfilling contractual obligations or otherwise performing services for you, (ii) maintaining, protecting, and improving our business, including the operation of the Site, or (iii) investigating, defending against, or prosecuting any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum or otherwise protecting our legal rights; and/or
  • It is necessary to comply with any applicable regulatory, judicial, or other legal obligation.

Withdrawal of Your Consent
To the extent permitted by applicable law, you have the right to withdraw consent to Access’s collection and use of your personal data at any time by emailing the Access Legal Department at legalnotices@accind.com. Please note that your withdrawal of consent will not be retroactive, and Access may be legally required to retain some or all of your personal data notwithstanding your withdrawal of consent.

With Whom Access Shares Personal Data
Access may share your personal data with:

  • Any and all of the Access entities;
  • Service providers we use to help deliver our services to you, such as attorneys, auditors, accountants, tax advisers, administrators, custodians, depositaries, distribution managers and brokerage firms, event organizers, or other agents, advisers, or service providers engaged by Access;
  • Other third parties we use to help run our business, such as website hosts; and
  • Our banks.

These parties may have access to your personal information but are permitted to use the information solely to provide the specific service or as otherwise permitted by law.

If you are a resident of the European Union (“EU”) or the European Economic Area (“EEA”), Access will ensure appropriate safeguards are in place as required by applicable law to adequately protect your personal data if it is processed by third parties outside the EU and EEA, including the execution of standard contractual clauses if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission).

Affiliates and Business Transitions
Access may share your personal data with its affiliates that are subject to privacy policies that protect your information from disclosure to third parties in a manner similar to this Privacy Policy. In the event that Access goes through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of its assets, our users’ personal data will, in most instances, be part of the assets transferred. Access may in its discretion notify you of any such business transition via email, to the extent you have elected to provide Access such information and elected to receive such communications, and/or notice on this Site.

Cookies and Similar Technologies
A “cookie” is a small data file that a website places on your computer when you first connect to the website. First-party cookies are cookies set by the website you are visiting. A website may also use external services that set their own cookies, known as third-party cookies.
Access uses first-party cookies to let us know that you have visited our Site before, and recognize you so that you can avoid re-entering information each time you visit the Site. We also use first-party cookies to help us analyze the use of our Site.
You can refuse these types of cookies either via the cookie banner you will see on the first page of the Site you visit, or by setting your browser to refuse cookies from the Site. However, some portions of the Site will not function properly or may function more slowly if you choose to reject cookies. For information on how to limit, delete, or disable cookies for some commonly used browsers, please visit:

Additionally, some or all of this Site makes use of Google Analytics, a web analytics service that uses cookies. This Site makes use of Google Analytics Demographics and Interest Reporting. This Site may also make use of Google Analytics for Display Advertising features, including Remarketing, Display Network Impression Reporting, and/or the DoubleClick Campaign Manager integration.

Access is required by Google to disclose the following information to you in our Privacy Policy in connection with our use of any Google Analytics features on our Site:

  • You may opt-out of Google Analytics for Display Advertising or customize Google Display Network ads by using the Google Ads Settings page, which can be found at https://adssettings.google.com.
  • If this Site makes use of the Google Analytics for Display Advertising Remarketing feature, Access will use such Remarketing feature to advertise online and third-party vendors, including Google, which may show Access ads on websites across the Internet.
  • Access and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to (a) inform, optimize, and serve ads based on a user’s past visits to this Site and/or (b) report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to this Site.
  • Data from Google Analytics Demographics and Interest Reporting may be utilized by Access to help recognize and understand user preferences, to make improvements to this Site, to choose content and advertising to display to you, and for other business purposes that will allow us to better serve you.
  • You may prevent your data from being collected and used by Google Analytics by opting-out through the use of the Google Analytics Opt-out Browser Add-on, which can be found at https://tools.google.com/dlpage/gaoptout?hl=en.

In addition, we may also process other technical information about you, including but not limited to: (1) your IP address, browser type and version, device identifier, location and time zone setting, network and/or service provider, operating system and platform, page response times and download errors; (2) details about your visit, including the websites you visit before and after our Site and the products and services you viewed or searched for; and (3) length of visits to certain pages, interaction with elements on the Site and methods used to browse away from the page.

Browser “Do Not Track” Signals
Access does not honor “Do Not Track” (also known as “DNT”) signals or similar mechanisms transmitted by your web browsers. More information about browser tracking signals and Do Not Track signals can be found at http://allaboutdnt.org.

Retention of Your Information
Access and its service providers will retain your personal data for the purposes described in this Privacy Policy as long as required for the purposes described above. In particular, and without limitation to the foregoing, Access and its service providers have legal obligations imposed on them under applicable legal systems that require them to retain your personal data for certain minimum time periods.

Protection of Your Information
Access maintains appropriate administrative, technical, and physical security measures to protect your information and data against loss, misuse, and alteration. Access uses standard industry practices to help prevent unauthorized use of, access to, or alteration of visitor and user information and hosted data. In addition, Access restricts access to personal information to those employees who need to know that information in the course of their job responsibilities.
At the same time, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while Access strives to protect your personal data to the best of its ability, Access cannot guarantee or warrant the security of information you transmit to our Site or over the Internet.

Protecting Children
Access takes special care to protect the safety of children in accordance to the Children’s Online Privacy Protection Act of 1998. While this Site is a general audience website, Access does not permit children under the age of 13 to register or purchase any products or services. Access also does not collect or maintain personal data about children under the age of 13.

Rights Individuals May Have in Relation to Their Data
If you are a citizen or resident of the EU or EEA, the following rights may be available to you according to applicable data privacy laws:

Delete Personal Data: You can ask Access to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide services to you).

Right to Rectification: You also have the right to ask Access to change, update, or fix your personal data in certain cases, particularly if it is inaccurate.

Object to, or Limit or Restrict, Use of Personal Data: You can ask Access to stop using all or some of your personal data (e.g., if Access has no legal right to keep using it) or to limit Access’s use of it (e.g., if your personal data is inaccurate or unlawfully held).

Right to Access and/or Take Your Data: You can ask Access for a copy of your personal data and can ask for a copy of personal data you provided in machine-readable form.

To make any requests as listed above, to the extent permitted by applicable law, please contact Access by emailing the Access Legal Department at legalnotices@accind.com. Access will respond to any requests relating to your rights above within one month of receipt of your request, or within three months of receipt of your request where the request is more complex.

Making a Complaint
If you would like to make a complaint about the way Access has collected, used, or retained your personal data, please contact the Access Legal Department at legalnotices@accind.com.

If you are a citizen or resident of the EU or EEA, then you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by Access or its service providers infringes applicable data privacy laws.

Further Information
The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive. You may have additional rights under other foreign or domestic privacy laws in addition to those that are described above. If you have any questions about this Privacy Policy, please contact us at:

Access Industries, LLC, 40 West 57th Street, 28th Floor, New York, NY 10019, telephone: (212) 247-6400, legalnotices@accind.com.

Additional Information for California Residents
The following information is provided for California residents pursuant to the California Consumer Privacy Act. This information supplements the foregoing Privacy Policy for individuals who have rights pursuant to California law and shall not be construed as creating any right or duty that is not otherwise provided by law.

Access may collect and use the following types of personal information, without limitation:

Categories of Personal Information Specific Types of Personal Information Collected
A. Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) Real names, postal addresses, email addresses, Internet Protocol addresses, passport numbers, social security numbers, driver’s license numbers
B. Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information Real names, postal addresses, email addresses, telephone numbers, fax numbers, birth dates, passport numbers, social security numbers, driver’s license numbers, employment, employment history, financial information, tax-related information
C. Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) Past transactions entered into
D. Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) Browser type and version, device identifier, location and time zone setting, network and/or service provider, operating system and platform, page response times and download errors, browsing history, search history, length of visits to certain pages of websites
E. Professional or employment-related information Professional relationships and background, investor qualifications, financial wealth and assets held, sources of wealth

 

In the preceding 12 months, Access has not sold or disclosed for a business purpose any personal information.

If you are a California resident, the CCPA and other applicable California data privacy laws provide you with the following rights:

  • Right to Access and/or Take Your Personal Information: On receipt of a verifiable request from you, we will disclose:
  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any;
  • The specific pieces of personal information we have collected about you; and
  • If we sold or disclosed your personal information for a business purpose:
    • The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
    • The categories of personal information that we disclosed about you for a business purpose.

Right to Delete: On receipt of a verifiable request from you, subject to certain exceptions permitted under applicable law, we will:

  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.

To make any access or deletion requests as listed above, to the extent permitted by applicable law, please contact Access by emailing the Access Legal Department at legalnotices@accind.com. You will need to provide us with enough information to identify you, proof of your identity and address, and a description of what right you wish to exercise. Please note that you may only make a data access request twice within a 12-month period.

Protection from Discrimination: You have the right to not be discriminated against by us, to the extent permitted under applicable law, because you exercised any of the rights as described above.
California residents are also entitled once per year to request and obtain certain information regarding Access’s disclosure, if any, of your personal data to third parties for their direct marketing purposes during the immediately prior calendar year. To make such a request, please send an email to the Access Legal Department at legalnotices@accind.com with your full name, email address, and postal address in your message. In response to your request, Access will provide you with a notice describing the cost-free means to opt-out of our sharing your personal data with third parties with whom Access does not share the same brand name, if the third party will use it for their direct marketing purposes.

You can contact Access at: Access Industries, LLC, 40 West 57th Street, 28th Floor, New York, NY 10019, telephone: (212) 247-6400, legalnotices@accind.com.