How We Use & Protect Your Information
Digital Capital Management, LLC (doing business in California as DCM MGT, LLC) (“DCM”, “we”, “us” or “our”) 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:
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 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 areas 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.
We store and use the information we collect about you in roles as both a “Controller” (i.e., data user) and a “Processor” (i.e., data storage) of that information. We will also utilize third parties as Processors to store and archive information we collect 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, we 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 provide services to you will be deleted (unless required to be retained by applicable books and records retention regulations or other laws).