Commitment to Privacy
We consider client privacy to be fundamental to our relationship with our clients. Since we were founded, we have been committed to maintaining the confidentiality, integrity, and security of clients’ personal information entrusted to us. Internal guidelines have been developed to protect this confidentiality, while allowing client needs to be served. These guidelines address how we handle confidential information within our administrative, technical and physical systems.
In the course of providing products and services, we may collect non-public personal information about clients. We may collect this information from sources such as account applications and other communications with us, third-parties (such as financial advisers, brokers or data vendors), and other forms of information captured on our website (including any information captured through the use of “cookies” or other technologies that uniquely identify and maintain session information).
We do not disclose any non-public personal information about clients or former clients to non-affiliated parties, except as allowed by clients, as we believe necessary or advisable in order to service a client account or as otherwise permitted by law. Your information is used by us, our affiliates, or our service providers primarily to complete transactions or account changes that you request or authorize. In the normal course of serving clients, information we collect may be shared with our affiliates and companies that perform various services for us, such as transfer agents, custodians, proxy solicitation firms, or printers or mailers that may assist us in the distribution of investor materials. The organizations that receive client information receive information we believe are necessary or advisable to carry out their assigned responsibilities and are authorized to use that information for the services required. In addition, such organizations are not permitted to share or use this information for their marketing and sales purposes.
We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted by law (for example, to cooperate with regulators or law enforcement authorities, such as responding to a subpoena or other legal process, or to protect accounts from fraud), or to resolve client disputes.
The EntrepreneurShares entities do not generally obtain any information from a consumer reporting agency or information that is derived from a consumer report that identifies an individual. If EntrepreneurShares obtains a consumer report on an individual, EntrepreneurShares will erase and/or destroy such information that identifies an individual and that is not required to be kept for recordkeeping purposes.
We do not sell client information — whether it is your personal information or the fact that you are a EntrepreneurShares client—to anyone.
The Information We Collect
If you are an individual who is or will have an account with our funds, you typically provide personal information when you complete a EntrepreneurShares fund account application or when you request a transaction.
This information may include your:
- Name and address, including e-mail address.
- Social Security or taxpayer identification number.
- Assets.
- Account balance.
- Investment activity.
- Information captured on our Website.
In addition to personal information you provide to us, we may receive information about you that you authorize third parties to provide to us. We also may obtain personal information from third parties in order to verify your identity, to prevent fraud, or to help us identify products and services that may benefit you. For example, funds advised by EntrepreneurShares use a third-party transfer agent and third-party providers of systems who use your information to process or analyze transactions you have requested. Our contracts with these organizations contain provisions restricting their use of your nonpublic personal information to those purposes for which they were hired.
The information we collect and store during normal website usage includes your Internet address, the name and version of your Internet browser, the website that referred you to us, the pages you request and the date and time of those requests. We may also collect data from third party analytic tools. We use this information to generate statistics and measure site activity to improve the usefulness of customer visits. During normal website usage, we do not collect or store personally identifiable information such as name and email address.
There are instances where we require personally identifying information such as name and address to provide the website visitor a service (registration to our password-protected website). The information you provide is used by us and our affiliates to understand who our service users are, and to contact you regarding our and our affiliates’ services. The personal information we collect is never provided to any other company for that company’s independent use.
Access to clients’ non-public personal information is restricted to employees and third parties hired to perform services for us who we believe need to access such information to provide products or services. To guard clients’ non-public personal information, we have imposed physical, electronic, and procedural safeguards that we believe are reasonably designed to comply with federal standards to guard clients’ non-public personal information. A client’s right to privacy extends to all forms of contact with us, including telephone, written correspondence, and electronic media, such as the Internet.
This privacy policy summary describes our privacy practices for both current and former clients. We may disclose non-public personal information about former clients to the same extent as for current clients.
The Internet And Third – Party Sites
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
We may provide experiences on social media platforms and third-party sites that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media or other third-party sites. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms or third-party sites, is also subject to the terms of use and privacy policies of those platforms or sites. Please refer to them to better understand your rights and obligations with regard to such content.
Notices And Future Changes
We may revise our policy or this summary in the future, and will promptly post the new policy summary on our website.
Contact Us
If you believe that your privacy has been breached or your personal information that we store is in error, please contact our Compliance Department using the contact information below and provide details of the incident so that we can investigate it. We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome. If we receive a response from you, we will assess it and advise if we have changed our view. For questions concerning this policy, please contact us by writing to: Privacy Policy c\o Compliance, EntrepreneurShares LLC, 175 Federal Street Suite 875 Boston, MA 02110.
