How We Use & Protect Your Information
Digital Capital Management, LLC (doing business in California as DCM MGT, LLC) (“DCM” or “we”) is providing this notice on its behalf, and on behalf of the funds it manages, to explain their information collection practices and other important information. These measures reflect our commitment to maintaining the privacy of your confidential information. We appreciate the confidence you have shown by entrusting us with your assets.
Information We Collect
We may collect several types of nonpublic personal information about you from the following sources:
- Information we receive about you on applications and other forms including subscription documents, questionnaires and online registration forms, whether we receive the form in writing or electronically. For example, this information may include your name, address, telephone number, e-mail address, tax identification number, income and other financial data, investment experience, and possibly your personal bank account information.
- Information about your transactions and account history with us, our affiliates and others, including initial and follow-on subscriptions, transfers and withdrawals or redemptions.
- Information we receive about you from third parties such as solicitors, brokers, selling agents, advisers, product sponsors, exchanges, clearing firms and/or their respective service providers.
- Information from online forms you complete and data we receive when you visit our website (such as internet protocol address, and browser software).
- The website is not directed toward children under the age of 13, and we do not knowingly collect personal information from children under 13.
Disclosure and Use of Your Information
We do not disclose your personal or financial information, whether you are our current or former client, without your authorization or direction, except as disclosed below.
We may share information about you with affiliated or nonaffiliated service providers or other third parties (i) for them to assist us in providing services to you, (ii) as part of marketing arrangements designed to jointly offer a product or service, (iii) as may be required by regulatory authorities or law enforcement officials, (iv) to the extent reasonably necessary to prevent fraud and unauthorized transactions, or (v) as otherwise as permitted by law. Those receiving information about you under the circumstances described above are not permitted to use your information for any purpose other than to assist our servicing of your account(s), including helping us improve the services we offer, or as permitted by law. If you choose to withhold personal information requested by us, we may not be able to provide services to you, and you may not be able to gain access to certain area of our website.
Confidentiality and Security; Control of Your Information
We restrict access to nonpublic personal information about you to those employees and third parties who need to know that information to assist us in providing services to you. We maintain physical, electronic and procedural safeguards consistent with applicable US and international standards to protect your nonpublic personal information.
DCM stores and uses the information it collects about you in roles as both a “Controller” (i.e., data user) and a “Processor” (i.e., data storage) of that information. DCM will also utilize third parties as Processors to store and archive information it collects from you (e.g., via cloud-based services offered by Google, SalesForce and others), for which service agreements are in place to address confidentiality, security and compliance with applicable privacy directives and laws.
International Privacy Laws
Use of Internet “Cookies”
Access to Information; Questions; Contact
You may contact us to request access to information we have collected about you, and if you do so, DCM will first need to verify your identity before it shares any such information. Once verified, we will send a copy of the information collected about you electronically, unless you specifically request a different method. If you believe the information about you is incorrect, please contact us so that we can correct any errors. Data about you that is no longer needed to providing services to you will be deleted (unless required to be retained by applicable books and records retention regulations or other laws).
La Jolla, CA 92037
7855 Ivanhoe Avenue STE 300
La Jolla, CA 92037
There is no guarantee that any investment will achieve its objectives, generate profits or avoid losses, and past performance is not necessarily indicative of future results.
Investments in digital currencies or funds pursuing investments in digital currencies and related assets (“digital assets”) are very speculative and can involve a high degree of risk. Investors must have the financial ability, sophistication, experience and willingness to bear the risks inherent with digital assets, and the ability to weather a potential total loss of their investment. Digital assets are not suitable or desirable investments for all investors. Digital assets may have limited operating histories, and the fees and expenses associated with funds pursuing investments in digital assets may be substantial.
The information provided on this website is not intended to be, nor should it be construed or used as investment, tax or legal advice, a recommendation, or an offer or solicitation to buy or sell an interest in any crypto asset.
Copyright © 2019 Digital Capital Management, LLC (doing business as DCM MGT, LLC in California). All rights reserved.