Privacy Policy

This Privacy Policy governs this website (the “Site”), email, text, and other electronic messages between you and 10 Point Capital, LLC and its affiliates (together, “10 Point,” “we” or “us”). We respect your privacy as a user of the Site. This Privacy Policy describes whether and how we collect and use information about you when you visit the Site.

Your visit to the Site is subject to this Privacy Policy. By visiting the Site, you agree to this Privacy Policy, which may be updated by us at any time and constitutes a legal agreement between you and 10 Point. We will post any updates to this Privacy Policy here, and any updates will be effective upon posting. You should consult the Privacy Policy on this Site each time you visit the Site. If you do not agree with its terms, please do not use the Site.

This Privacy Policy concerns only the Site and does not concern any website to which the Site may link. Should you choose to visit these third-party sites, you should review their privacy policies to ensure that you are comfortable with their terms. Further, this Privacy Policy does not govern information that you submit to 10 Point outside of your use of the Site, including in your role as an investor in 10 Point or in investments or funds that we sponsor or manage. We address these practices in separate notices.

1. The Types of Information We Collect About You

When you enter and browse the Site, we may collect two different types of information about you: information you provide to us, and information we collect through technology.

Information You Provide to Us. To obtain access to certain information or materials provided via the Site, you may have to provide information that we collect and store in a way that allows us to identify you personally, including your name, e-mail address, postal address, telephone number, social security number, company name, title, or any other personal information by which you may be contacted online or offline. We refer to such information as personally identifiable information. Additionally, we may collect and retain a record of all communications with you.

Information We Collect Through Technology. We may collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to the Site. (An IP address is often associated with the portal through which you enter the Internet.) At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site. The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send to our Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that identifies you personally. We use software tools such as Google Analytics to measure and collect session information about your Site visits, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

2. Cookies and How We Use Them

Cookies are small text files that may be placed on your browser when you visit our Site. Cookies are used primarily for administrative purposes, to improve your experience with our Site. For instance, when you return to the Site after logging in, cookies provide information to the Site, including personal information, so that the Site will remember who you are.

10pointcapital.com uses cookies primarily to capture anonymous analytics to improve your experience with the Site and its performance. This includes compiling statistical information concerning, among other things, the frequency of use of our site, the pages visited, and the length of each visit, as well as information about your computer, operating system, browser, language, and country. We do not use cookies to store any personal information that could be read or understood by others.

Using the settings of your Internet browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Consult your browser’s Help menu to learn the correct way to modify your cookies. If you choose to turn off cookies, you may not have access to many features that make your browsing of our Site smoother, and some of our services may not function properly. You may at any time delete any cookies set by us by using the relevant option of your Internet browser or by deleting the cookies on your hard drive. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to https://www.aboutcookies.org. If you continue without changing your settings, we’ll assume that you accept receipt of all cookies on the Site.

As mentioned above, we use Google Analytics to collect information about your use of the Site. Google Analytics collects information such as how often users visit the Site, what pages users visit, and what other sites they visited prior to or after coming to the Site. More information on how Google Analytics uses your data can be found at www.google.com/policies/privacy/partners. By using the Site with your browser set to accepting cookies, you consent to our and Google Analytics’ use of cookies on the Site.

3. How We Use Your Personally Identifiable Information

10 Point does not use or disclose any nonpublic personally identifiable information about its Site users to any nonaffiliated third party, except as set forth below.

We may use or disclose certain personally identifiable information we collect about you when you visit and browse the Site as part of our normal business operations, or to send you administrative communications either about your interactions with us or about features of the Site, including any future changes to this Privacy Policy.

We may also store your personally identifiable information and share it among our affiliates. We may use or disclose this information for marketing, research and other business purposes, and we may associate your personally identifiable information with other information we collect about you, such as details about your usage patterns and interests, but we will not sell this information or disclose it to third parties.

We may also use service providers to facilitate our services or platform functions on our behalf. These companies and individuals may have access to your personally identifiable information, as needed to perform their functions, but may not use it for another purpose.

We will use or disclose personally identifiable information when we believe that such disclosures are required by law, regulation, legal process, subpoena, document request or governmental request. For example, it may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them. We may also do so to help enforce our Terms of Use or to protect the safety or security of our websites and other assets, our users (including you) and their property and the rights of third parties. Also, in the event that 10 Point or any of its assets or businesses are acquired or merged with another entity, whether an affiliate or a third party, user information (including personally identifiable information) may be one of the transferred assets.

4. How We Use Your Non-Personally Identifiable Information

Non-personally identifiable information is information that does not personally identify you, including anonymous information and aggregate data. We may use this information to understand better how our visitors use the Site, research our visitors’ demographics, interests, and behavior, improve the Site, provide visitors with customized services and information, and for other similar purposes. We may combine this information with personally identifiable information. We may use this information in any manner permitted by law, but any disclosure that identifies you personally will be governed by Section 3.

5. Do Not Track Signals

10 Point does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

6. Children

Although this Site is not targeted toward children, we are concerned about the safety and privacy of children who use the Internet. We do not knowingly collect personally identifiable information from children under the age of 13, nor do we disclose such information to third parties. However, if a child under the age of 13 provides personally identifiable information to us through the Site, a parent or guardian may inform us at the address for legal notices below, and we will allow the parent or guardian to review the information and will delete it from our database, subject to applicable law.

7. International Use

Our databases are located in the United States, and your data is stored in the United States. If you access this website from outside the United States, you do so at your own risk and are responsible for compliance with local laws, rules and regulations. By sending us your data, you consent to its transfer to and storage within the United States.

8. Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

9. Governing Law and Forum

The laws of the State of Georgia govern this Privacy Policy. Any dispute relating to this Privacy Policy or your use of the Site shall be resolved solely in the state or federal courts located in Atlanta, Georgia. You agree to waive trial by jury in any such action.

10. Miscellaneous

If any provision of this Privacy Policy is deemed unlawful, void, or for any reason unenforceable, that provision will be deemed severable from this Privacy Policy and will not affect the validity or enforceability of the remaining provisions.

11. How to Contact Us

If you have any questions or comments about this Privacy Policy, you can email us at admin@10pointcapital.com, call us at (404) 444-3110, fax us at [(xxx) xxx-xxxx], or write to us at Web Admin, 10 Point Capital, LLC, 3575 Piedmont Road NE, Building 15, Suite 730, Atlanta, Georgia 30305.

Last updated: June 28, 2019