Effective date 05 August 2009
• Protecting the privacy and anonymity of our registered users is important to OSOL. All Registered Users must select a unique username that is their public identity on the system. It is the responsibility of Registered Users to not include personally identifiable information in their username.
• Registered Users of the FOIDB must complete a registration process. OSOL will collect personally identifiable information from our Registered Users during the registration process. Business-related registration information will be included into the FOIDB unless our Registered Users choose opt out by unselecting the “Add me to Family Office Database” checkbox.
• OSOL does not use or share personally identifiable information other than as described in this privacy statement. We may however disclose such information as required by law or to protect our interests or the rights of third parties.
• Aggregate information that is gathered up across all member accounts is not shared together with personally identifiable information.
• OSOL communicates with our Registered Users by email. We do not give or sell email addresses to anyone for their marketing purposes. Registered Users may opt out from these email communications by clicking on the Unsubscribe link at the bottom of every email.
• OSOL secures information we collect using generally accepted industry standards.
• This privacy statement may change at any time and changes take effect when posted unless otherwise indicated.
• We will cooperate with legal inquiries and requests made by third parties to enforce laws or to protect their rights. Although members are anonymous while using our system, the improper or illegal use of our system can jeopardize that anonymity.
Notice about Children
Our system is directed to adult, hedge fund professionals. Children under the age of 18 are not permitted to use our system, and we prevent this by not allowing free access to the FOIDB. The minimum charge for accessing the FOIDB is listed in our Pricing page, and payment can only be made by Credit Card or Wire Transfer. We do not knowingly collect information from or about children.
Maintaining the anonymity of our Registered Users is important to us. During registration, Registered Users must set a unique username that will be publicly attributed to their use of the FOIDB. Usernames are the key to keeping our Registered Users anonymous. We do not share usernames together with personally identifiable information.
Collection of Registration Information
All FOIDB users must complete a registration process. We will collect personally identifiable information during this process that includes name, email address and other personal contact information as indicated. Billing information is also collected and processed by our Payment Gateway (“Worldpay”), and is not collected by OSOL directly. When members provide payment information, it is protected using secure socket layer technology (SSL). OSOL uses registration information to process registrations, maintain subscription accounts, and communicate with our Registered Users and to provide our services. We do not share registration information together with personally identifiable information.
Collection of System Use Information
We use usernames to compile and process historical and statistical information about how and when our Registered Users use the FOIDB. Historical and statistical information includes information about selected actions that our members take while on the website. We will also aggregate (gather up across all member accounts) and store historical and statistical information.
System use information is collected, surveyed, evaluated and scored by the website to assess the quality of data. Registered Users’ actions are effectively confirmed or challenged by the later actions of other members. We use this evaluation process to maintain our collaborative, self-correcting system and to promote the development of the most accurate, complete and up-to-date data possible. Members are objectively rated by the system based upon their actions.
The FOIDB uses points as an incentive and a point balance will be maintained for each Registered Users based upon system use information. We may also use this information to add, adjust or discontinue certain services or functionality and to enforce our policies and procedures. System use information may be stored indefinitely, but may also be deleted at our discretion.
We use both session ID cookies and/or persistent cookies. We use session cookies to make it easier for users to navigate our system. A session ID cookie expires when a user closes their browser. A persistent cookie remains on a user’s hard drive for an extended period of time. Users can remove persistent cookies by following directions provided by their Internet browser. We use persistent cookies to store members’ email addresses, so they do not have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the experience and functionality on our site.
If users reject cookies, they may still use our system, but their ability to use some areas of our site may be limited.
Clear Gifs (Web Beacons)
OSOL uses clear gifs in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
The FOIDB website gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
OSOL uses this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We link this automatically collected data to personally identifiable information. OSOL uses Google Analytics to track and analyze this information. More information about Google Analytics can be found on www.google.com/analytics.
In the event we go through a business transition, such as a merger, acquisition by another company, or a sale of all or a portion of its assets, member information will likely be among the assets transferred to a third party. The third party would then have the right to continue using such information as set forth in this policy. Members will be notified via email and prominent notice on our site for 30 days of any such change in ownership or control of member information.
Links to Other Sites
The FOIDB contains links to other sites that are not owned or controlled by us (for example, websites of Asset Managers). OSOL is not responsible for the privacy practices of those other sites. This privacy statement applies only to information collected by us through our system, specifically, the FOIDB. You should keep aware of when you leave our site and read the privacy statements of each and every other web site that collects your personally identifiable information.
OSOL reserves the right to change this privacy statement at any time, so please review it frequently. This policy was last updated on: 05 August 2009. We will post changes to this statement, our homepage, and other places that we deem appropriate so our members are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Changes shall automatically be effective when posted unless otherwise indicated. If we make material changes to this policy, we may notify members by email or by other prominent means online.
We will cooperate with law enforcement inquiries. In response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we may disclose member information, including personally identifiable information, without a subpoena.
Except as otherwise described herein, we will not disclose member information, including personally identifiable information, without a subpoena, court order or substantially similar legal process or procedure, except when we believe in good faith that the disclosure of such information is necessary to report suspected illegal or improper activity, protect our rights or interests, protect our members’ rights or interests, protect the rights or interests of third parties, or enforce our policies and procedures.