Privacy and Security

ACE Portal, a Delaware corporation (“ACE Portal”, “we”, “our” or “us”), owns and operates the website located at www.aceportal.com (“ACE” or the “ACE Site”).  By visiting, using and/or submitting information to ACE, you are accepting the practices described in this Privacy and Security Policy and the terms and conditions set forth in the ACE Terms of Use

By becoming a Member (and thereby accepting and agreeing to the terms and conditions of the ACE Member Agreement), you agree to allow us to collect and use personal information as explained herein.  The term “personal information” or “personally identifiable information” as used herein refers to non-public information that personally identifies you or relates to you as an individual or entity.

This Privacy and Security Policy applies to current and former Members.  “Members” refers to Accredited Investors, Qualified Purchasers, Qualified Institutional Buyers and Placement Agents that are Members with access to the ACE Site.  The information we collect and how we may use that information may vary depending upon the relationship with a particular Member.

COMMITMENT TO YOU

We are committed to protecting the identities and personal information of our Members.  Our primary concern is the security of Member personal information, and we use personal information only as necessary.  In light of this commitment, we:

  • Recognize and appreciate the trust you place in us and the confidential nature of the information you provide us;
  • Limit the collection and use of personal information to what we believe would be useful to service your membership, except as you may otherwise expressly approve;
  • Educate our employees on the importance of confidentiality and Member and user privacy;
  • Restrict employee access to Member and user information to those who need the information to service you;
  • Respond quickly to your requests to correct inaccurate information; and
  • Maintain appropriate security standards and procedures to protect your personal information (See “Safeguarding Your Information; ACE Security Protocol” below).

HOW WE COLLECT INFORMATION

  • We collect personal information about you in a number of ways, including the following:
  • Membership Application Process:  During the application process, we collect personal information from you, including but not limited to, name, address, Social Security number and/or taxpayer identification number and date of birth.  We do not sell your personal information to anyone, for any reason. We are committed to protecting the confidentiality, integrity and security of personal information you provide us.
  • Activity Information:  Once your membership has been activated, we collect and maintain information about your membership activity, including but not limited to, pages viewed, communications made and transactions in which you participate.  This information allows us to administer your membership and provide the services you have requested.
  • Website Usage:  When you visit ACE, we may use devices known as “cookies,” web beacons, or other similar web tools to enhance your web experience.  These tools help us to recognize you, maintain your web session, and provide a more personalized experience.

USE OF INFORMATION

We use your personally identifiable information as follows:

  • To confirm your identity;
  • To internally improve ACE Portal’s marketing and promotional efforts, analyze site usage, improve content and service offerings and customize ACE’s layout;
  • To fulfill legal and regulatory requirements;
  • To contact you and deliver information to you that, in some cases, is targeted to your interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of the ACE Site;
  • To fulfill your requests for certain products and services;
  • To troubleshoot problems and detect and protect against error, fraud or other criminal activity;
  • To enforce the ACE Terms of Use and/or your ACE Member Agreement (if applicable), for other internal purposes, and as otherwise described to you at the time of collection;
  • To compile ACE Member information for purposes of data analytics and aggregation, provided that a Member’s personally identifiable information will not be used or disseminated in a manner that would enable anyone to identify any Member;
  • To share information we collect about you within our affiliated companies (if any) to provide better, more efficient services and respond to communications from you; and
  • As otherwise set forth in this Privacy and Security Policy.

HOW WE SHARE YOUR INFORMATION OUTSIDE OF ACE Portal

We may share your information with outside companies and other third parties in certain limited circumstances, including:

  • When we use a third party to confirm your identity using information you provide in your application, including, but not limited to, your name, address, telephone number, Social Security number and date of birth.  In these instances, use of your information is strictly limited to performance of the task we request.
  • When we use other companies to provide services to you, such as printing and mailing you information about your membership.  We may also provide a third party with information from our database to help us analyze and identify user needs to improve our products and services.  In these instances, use of your information is strictly limited to performance of the task we request.
  • When disclosure is required or appropriate by law (for example, to cooperate with regulatory authorities, legal proceedings or law enforcement), when requested by any regulatory authority or agency, to protect against misuse or unauthorized use of the ACE Site, to limit our legal liability and protect our rights, to protect the rights and safety of visitors to the ACE Site or to otherwise process or service your account.
  • When we compile league tables, market data and historical investment information from transaction data derived from the operation of ACE.  In these instances, we will disclose such data only if such data is otherwise generally available to the public other than by disclosure by us (such as through filings made with the Securities and Exchange Commission or Issuer or Placement Agent press releases) or with your consent.

SAFEGUARDING YOUR INFORMATION; ACE Security Protocol

Protecting your identity and personal information is of the utmost importance.  We take precautions to ensure the information we collect about you is protected and is accessed only by authorized individuals who are trained regarding ACE Portal’s privacy and information safeguarding practices. ACE Portal maintains physical, electronic and procedural safeguards to guard your personal information.

ACE uses industry leading technology and systems to protect its Members’ information and privacy.  Below are some of the technologies and practices we’ve put in place to protect you.

  • User ID and Password: To access your Membership, you must provide a unique user ID and password.  Each Member-created password requires a minimum of 8 characters, which must include a combination of lower & upper case letters and a number.  Accounts are locked after 5 invalid account access attempts.
  • Session Timeout:  ACE uses a time-out feature to log Members out after 15 minutes of inactivity. This reduces the risk of others accessing your information from an unattended computer.
  • Encryption:  ACE provides a 256-bit encryption for a secure browsing experience.  ACE uses Secure Sockets Layer (SSL) to ensure that any data entered into the ACE Site is encrypted.  You can verify that SSL is enabled by looking for the padlock or key icon on your browser.
  • The ACE Site is built upon a secure infrastructure with multiple layers of protection.  Physical protection for ACE servers includes facility perimeter security via biometric authentication, key card access and video surveillance.  In addition, we have service agreements in place with security software partners who provide us with continuous vulnerability scans, intrusion detection services, and anti-virus server protection.  We continually evaluate new software and technologies to ensure we are up to date with the highest levels of standards.

PRIVACY AND THE INTERNET

We have taken substantial efforts to protect our Members’ information; however, it is also important that you take an active role in protecting your personal information.  We ask that you take some time to review the security suggestions provided below:

  • Never share your user ID or password to your ACE Membership with anyone or pre-fill the user ID or password fields.
  • If you believe that another person has gained access to, and/or may be using, your User ID or password, you should notify us immediately and discontinue their use.
  • Logout of your Membership when you have finished your session.  The “Logout” button can be easily found in the upper right hand corner when you are logged in.
  • We recommend that you change your password periodically and avoid using passwords that you commonly use for other purposes.
  • Install and update anti-virus and anti-spyware software and use personal firewalls to protect your computer.
  • Do not open or enter personal information into a form within an email message or a pop-up if you do not recognize the sender.  Be particularly cautious of any attachments to emails from unrecognized sources.

“Cookies” are small text files that may be placed on your web browser when you visit the ACE Site.  Cookies make it easier for you to navigate the ACE Site by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you navigate between our website pages and/or access our services.  Authentication (i.e., verifying that you are who you say you are) is an essential component of site security.  You can set your web browser to inform you when cookies are set, or to prevent cookies from being set.  Please note that if you decline to use cookies, you may experience reduced functionality and slower site response times, and declining to use our authentication-related cookies may prevent you from using the ACE Site altogether.

Web surfing data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by ACE Portal itself, or by our service providers.  This may be accomplished by using cookies, web beacons, page tags or similar tools that are set when you visit ACE. Web surfing data and similar information may be shared internally within ACE Portal and used for the following purposes: to assess the usage, value and performance of our products and services; to improve your experience with the ACE Site; for administrative purposes; and as otherwise permitted by applicable law or regulation.  If you are an ACE Member, this information helps us suggest products or service offerings that may be of interest to you.  This information may be processed by us for the purposes described above, or on our behalf by third parties solely in accordance with our instructions.

OTHER RESOURCES TO LEARN ABOUT IDENTITY THEFT:

We are not responsible for the privacy policies or the content of sites to which we link (including those of broker-dealer firms that are Members, if applicable) and have no control over information provided by you or collected by those sites.  If you elect to hyperlink to a linked website, you may be asked to provide registration or other information.  Please note that the information you are providing is going to a third-party, and you should familiarize yourself with the privacy policy provided by that party.  We expressly disclaim any responsibility for the privacy of any information that you provide to a third party through a link or otherwise.

UPDATES AND CHANGES TO PRIVACY AND SECURITY POLICY

We reserve the right to make changes to this Privacy and Security Policy at any time.  In the event of any changes to this Privacy and Security Policy, we will promptly post a revised Privacy and Security Policy to the ACE Site.  You agree that posting of a revised Privacy and Security Policy electronically on the ACE Site will be deemed as actual notice to you.  Any dispute over this Privacy and Security Policy is subject to this notice.

ASSIGNMENT

We reserve the right to transfer any and all information that we collect to an affiliated entity or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including, without limitation, in connection with any bankruptcy or similar proceedings).

REVIEWING, CHANGING OR CORRECTING INFORMATION

It is your responsibility to help us maintain the accuracy and completeness of your personal and other information.  Please do not share your User ID or password with any other person, and review your information regularly to ensure that it is correct and complete.  If you would like to review your personal information or if you believe that any of your information is incorrect, please contact us by email at membership@aceportal.com.

CONTACT US IF YOU HAVE ANY QUESTIONS OR CONCERNS

If you have any questions, comments, concerns or feedback regarding this Privacy and Security Policy or any other privacy or security concern, send an email to security@aceportal.com.