Privacy Policy

AIGA Capital Partners LLC and all its affiliates (hereinafter referred to as "AIGA", "we" or "us") are committed to maintaining the privacy of every current, former and prospective customer. We recognize that you entrust important personal information to us, and we wish to assure you that we take seriously our responsibilities in protecting and safeguarding this information. This Privacy Policy ("Privacy Policy") describes in detail how we deal with information that we collect when you access or use this website (the "Site"), contact our personnel, or otherwise interact with us (collectively, the “Services”). For California residents, there is a “California Privacy Rights” section in this Privacy Policy. For individuals located in the EEA, Switzerland and/or the UK, there is a “EEA, Switzerland and/or UK Privacy Rights” section in this Privacy Policy.

By using or accessing the Site or the Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy. This Privacy Policy may change from time to time (see the “Changes to Our Privacy Policy” section in this Privacy Policy).  Your continued use of the Site after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Remember that your use of the Services is at all times subject to our Terms of Use and Disclosure Notice, which incorporates this Privacy Policy. 

Information We Collect

We may collect information about you when you use this Site or when you apply for or use other services offered by AIGA in the following ways:

  • We may collect personal information about you as a result of us recording certain telephone calls which our employees may have with you, and storing those recordings, in order to satisfy our legal and regulatory obligations or for our business purposes.

  • If you register to use the password-protected or country-specific portions of the Site, we will ask you to provide us with certain information about yourself. This information may include your name, company name, title, address, country of residence, e-mail address, telephone number, account number, assets, income and financial situation. We use such information about you to verify your identity and eligibility to receive certain products or services, to provide information to you about products and services that we believe may be of interest to you, to record your interest in products and services that we offer, and to respond to your requests for information. We may also use cookies or web bugs on such portions of our Site to collect usage Information, and to facilitate your movement within the Site (e.g. remembering passwords during a session and recording the country you may have elected as your country of residence).

  • We may collect information concerning the attachments you open within newsletters that are sent to you electronically.

  • We may collect personal information about you from applications, forms or questionnaires you may complete or agreements you enter into with us or in the course of your establishing or maintaining a customer relationship with us, including information about your credit history or financial situation, and your transactions with us or others who provide services to us.

  • We may collect records and copies of your correspondence (including e-mail addresses), if you contact us.

  • We may collect information about your computer or mobile device and internet connection, including your IP address, operating system, and browser type.

  • We may collect details of your visits to the Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.

If you decline to provide us with the personal information we require, then we may not be able to make investment products available to you or to provide other services to you.

Security of Data Transfers

Please note that data transferred via a public network, such as the internet or an email service, may be viewed by others. Information transmitted via the internet (such as online forms) and content received online may under certain circumstances be transmitted via third-party networks. AIGA cannot guarantee the confidentiality of messages or documents transmitted via such open networks or networks from third parties.

If you disclose personal information via an open network or a third-party network, you should be aware that your data may be lost or that third parties may be able to gain access to this information and consequently gather and make use of the data without your consent. In particular, while individual data packets are often encrypted, the names of the sender and recipient are not. A third party could therefore be able to draw conclusions about existing bank accounts or business relationships or ones that are subsequently established. Even if both the sender and recipient are located in the same country, data may also be transmitted regularly and without controls via such networks to other countries, including to countries that do not afford the same level of data protection as your country of domicile. We accept no responsibility for the security of your data during transmission via the internet and cannot be held liable for any direct or indirect losses. We ask that you use alternative methods of communication if you deem this to be necessary or appropriate for security reasons.

Data you provide in online forms can be communicated to commissioned third-party companies for order processing and be processed by such companies.

For certain services, we use strong encryption to transfer your data. In these cases you will be informed separately about the treatment of this data and details concerning encryption.

How We Process and Use Personal Information

We use your Personal Information for the following reasons:

  • To enhance the quality of the products or services we wish to provide to our customers or in connection with your investments with or through us and to maintain contact details for those with whom we deal;

  • To complete investments between you and AIGA;

  • To respond to your requests, questions and comments and provide customer support;

  • To support our legitimate interests of maintaining and improving our user experience and the Site;

  • To monitor the performance of our Services including metrics such as total number of visitors and traffic; 

  • To interact with you, including to notify you regarding investments, services, and promotions that may be of interest to you and inform you about important changes to this Privacy Policy, our Terms of Use and Disclosure Notice or other policies;

  • To tailor the content we display to you in our Services and communications, including advertising, and offer products and services that we believe may be of interest to you;

  • To manage, operate, and improve the Services and grow our business, including understanding our customer base and the effectiveness of our marketing, events, promotional campaigns, and publications, and diagnose or fix technology problems;

  • In a support context, to view details of your account to ensure that it complies with your contractual obligations to us;

  • To evaluate, recruit, and hire personnel;

  • To perform any other function that we believe in good faith is necessary to protect the security or proper functioning of the Site or Services; and

  • To comply with legal requirements and industry standards, detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and protect the rights of AIGA, you, or others.


We restrict access to Personal Information about you to those employees, agents or other parties who need to know that information to provide products or services to you or in connection with your investments with or through us. We may create aggregated, de-identified or anonymized data from the Personal Information we collect, including by removing information that makes the data personally identifiable to a particular user. We aggregate and de-identify data in accordance with applicable laws. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you. 

We may disclose your personal information, usage information, and other information about you to parties acquiring part or all of our assets, as well as to attorneys and consultants. If we transfer your information to an acquirer, we will use reasonable efforts to direct the acquirer to use your information in a manner that is consistent with this Privacy Policy. 

If any bankruptcy or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties. We may disclose information about you to others if we have a good faith belief that we are required to do so by law or legal process, to respond to claims, or to protect the rights, property or safety of AIGA or others.

We do not use your information for purposes other than as set out above, or disclose to any third party any personal information about our customers or former customers, except with such customer’s consent or as otherwise permitted or required by law. In cases where we believe that additional products and services may be of interest to you, we may share your personal information with affiliates of AIGA to the extent permitted by applicable law. We may also disclose this information to firms that perform services on our behalf to the extent permitted by applicable law. These service providers are required to treat the information confidentially and use it only for the purpose for which it is provided. Certain jurisdictions may have more stringent privacy requirements that will prevent disclosure of your personal information to any other person or entity, including affiliates.

How We Share Your Information

  • Service Providers. We may share your information with service providers that we believe need the information to perform a technology, business, or other professional function for us such as billing and collection, IT services, maintenance and hosting of our Services, payment processors, marketing partners, accounting, auditing, and tax services, and other professional services. 

  • Analytics. We partner with analytics providers, who collect information via tracking technologies on our websites to assist us with measuring visits and traffic on our websites so we can measure and improve the performance of the websites.

  • Advertising. We partner with third parties who assist us in serving advertising regarding the Services to others who may be interested in the Services, or who use cookies to display interest-based advertising to you on the Services. These third parties may use tracking technologies on our Site or applications to collect or receive information from the Services and elsewhere on the internet and use that information to provide measurement services and target ads. Third parties may allow other companies to access information about you so that they may market other products you may be interested in.

  • Social Media. If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.

  • Affiliates. We share information with other entities in our corporate family, for purposes consistent with this Privacy Policy. 

  • Corporate Event. We reserve the right to transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.

  • Legal. We share information where necessary to comply with applicable law, regulations, subpoenas, or to respond to requests from law enforcement agencies or other government authorities or third-parties, as required by law and without your consent when it is necessary to protect our customers, employees, or property; detect, prevent, or otherwise address fraud, security, or technical issues; in emergency situations; or to enforce our rights under our terms of service and policies.

Please note that AIGA only discloses information to our employees and third-party organizations that (1) need to know such information in order to process it on AIGA’s behalf or to provide services as described above, and (2) have agreed not to disclose it to any other parties without AIGA’s consent.  

Retention of Your Personal Information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the volume, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Online User Activity, Cookies and Information Collected by Other Automated Means

When you interact with the Services, we may automatically collect certain information about your use of our Services. This information may include:

  • Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);

  • Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type); 

  • Location information where you choose to provide the website with access to information about your device’s location.

The website uses cookies for statistical purposes and to improve user experience and online advertising campaigns. For more information on our cookie collection practices, please check out our Cookie Policy.

Your browser or device may include “Do Not Track” functionality. If you have selected this feature, we will continue to use cookies and other tracking technologies to provide you the features of our website but will block third parties from being able to collect data regarding your interactions with our website via cookies.

Links

This Site may contain hyperlinks to other websites that are not operated or monitored by AIGA. These other websites are not subject to this Privacy Policy and we are not responsible for their content or for the policy they apply to the treatment of Personal Information. We recommend that you read the privacy policy on these websites and check how these websites protect your Personal Information and whether they are trustworthy.

Persons Under the Age of 18

The Site is not intended for persons under 18 years of age. No one under age 18 may provide any information to or on the Site.  We do not knowingly collect personal information from persons under 18.  If you are under 18, do not use or provide any information on this Site or on or through any of its features.  If we learn we have collected or received personal information from someone under 18 years of age without verification of parental consent, we will delete that information as soon as possible and cease the use of that information in accordance with applicable law.  If you believe we might have any information from or about a person under 18 years of age, please contact us privacy@aigacapital.com.  

Internet Security

At AIGA, client confidentiality is the cornerstone of our business.  Accordingly, ensuring data security of our clients is a top priority.

While AIGA employs various security practices and measures in order to protect the confidential information of its clients, as the end user, you play an important role in safeguarding against risks such as those related to virus attacks, unauthorized access and fraudulent online transactions.

We maintain physical, electronic and procedural safeguards to guard your personal information, including firewalls, individual passwords and encryption and authentication technology. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site.  Any transmission of personal information is at your own risk.  We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

International Transfers

Your Personal Information may be transferred and stored in countries outside the EU or UK that are subject to different standards of data protection. We will take appropriate steps ensure that transfers of Personal Information are in accordance with applicable law and carefully managed to protect your privacy rights and interests. Furthermore, transfers will be limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:

  • we ensure transfers within AIGA will be covered by an agreement entered into by members of AIGA (an intra-group agreement) which contractually obliges each member to ensure that Personal Information receives an adequate and consistent level of protection wherever it is transferred within AIGA;

  • where we transfer your Personal Information outside of AIGA or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your Personal Information; or

  • where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information are disclosed.

You have a right to contact us at AIGA for more information about the safeguards we have put in place to ensure the adequate protection of your Personal Information when this is transferred as mentioned above.

Jurisdiction-Specific Notices

Certain jurisdictions may provide additional rights to individuals with respect to the collection and use of Personal Information that we have collected. For example, you may have the right to request that we: (i) disclose to you any Personal Information that we have about you; (ii) correct or delete Personal Information that we have about you (subject to certain exceptions); or (iii) not disclose or sell your information to a third party (excluding qualified service providers). If you are a resident of any of the following jurisdictions, click on your location to learn more.

California Residents

Your California Privacy Rights

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties for those third parties’ own direct marketing purposes. If you are a California resident, you may opt-out of such sharing by emailing us at Privacy@aigacapital.com.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of information about them, as well as rights to know/access, delete, and limit sharing of Personal Information. You have the right to be free from discrimination based on your exercise of your CCPA rights.

AIGA may disclose your Personal Information to commercial providers for a business purpose.  When we disclose Personal Information for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not to use it for any purpose except for the purposes set forth in the contract.

Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. The categories we use below to describe the information are those enumerated in the CCPA.

Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. Service providers are restricted from using Personal Information for any purpose that is not related to our engagement.

The following chart describes information we collect when you act as a customer or prospective customer of our products and services or visit our website. We do not sell Personal Information. We collect this Personal Information for the purposes described in the “Information We Collect” section above.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting.  We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

California Privacy Rights

If you are a California resident, the CCPA may provide you with additional rights regarding our use of your personal information. We may extend these rights to all users, within the limitations of this privacy policy, including the following: 

  • Right to Access/Right to Request.  The CCPA permits you to request and obtain from us information regarding the disclosure of your personal information that has been collected in the past twelve months by the us or our subsidiaries to a third party for the third party’s direct marketing purposes.

  • Right to Delete.  Except as required by the Health Insurance Portability and Accountability Act of 1996 or other applicable law, you also have the right to request the deletion of your personal information that has been collected in the past twelve months.


How to Submit A Request

In order to exercise any of your rights, you can contact us at privacy@aigacapital.com. 

Upon submission of your request, we will contact you via the email address provided in your request.  To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.  In some instances, such as a request for  data deletion, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.  With all requests, we will aim to complete requests as soon as reasonably practicable and consistent with any timeframes mandated by applicable laws. If we require more time, we will inform you of the reason and extension period in writing. You may authorize another individual or a business registered with the California Secretary of State, or designate an authorized agent, to make requests on your behalf through these means. 

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

  3. Debug products to identify and repair errors that impair existing intended functionality;

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);

  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

  8. Comply with a legal obligation; or

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

EEA, Switzerland and/or UK Privacy Rights

If you are located in the EEA, Switzerland, or the UK, you are entitled to certain rights, subject to applicable exceptions, under the GDPR, Swiss, and UK data protection laws. Please note that, in order to verify your identity, we may require you to provide us with information prior to accessing any records containing information about you.

We typically will process your information pursuant to the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services to you; or (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy. We also may process your information where it is necessary to comply with a legal obligation to which we are subject.

EU/UK Privacy Rights

If you are an EU or UK a resident, applicable laws may provide you with additional rights regarding our use of your personal information. We may extend these rights to all users, within the limitations of this Privacy Policy, including the following: 

  • Right of Access: You have the right to obtain confirmation as to whether we are processing personal data about you, and if so, request a copy of the personal data. If you would like a copy of the personal data that we hold about you, please send a description of the personal data you would like a copy of and proof of your identity to our email as set forth below.

  • Right to Correction: You have the right to correct any inaccuracies in the personal data that we hold about you and, where applicable, to complete any incomplete personal data that we hold.

  • Right to Erasure: You have the right to request that we erase the personal data that we hold about you if one of the conditions in Article 17 of the GDPR applies. The right to erasure does not apply in certain circumstances, including where the processing is necessary for the establishment, exercise, or defense of legal claims.

  • Right to Restriction of Processing: You have the right to restrict our processing of your personal data if one of the conditions in Article 18 of the GDPR applies.

  • Right to Data Portability: You have the right to receive personal data concerning you in a structured, common, and machine-readable format or request transmission of the data to a third party, if the conditions in Article 20 of the GDPR are met.

  • Right to Object: You have the right to object to the processing of your personal data based on our legitimate interests at any time. We will no longer process the data, unless there are compelling legitimate grounds for our processing that override the interests, rights, and freedoms of the data subject, or the processing serves the purpose of asserting, exercising, or defending legal claims. You also have the right to object at any time to the use of your data for direct marketing.

  • Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.

How To Submit a Request

To submit a request to exercise your rights, please email us at privacy@aigacapital.com. We may have a reason under the law why we do not have to comply with your request, or may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Cross-border Transfer of Data

If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. By using the Services, you consent to the collection, international transfer, storage, and processing of your data.

Lodging a Complaint

Users that reside in the EEA, Switzerland, or the UK have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.


Changes to Our Privacy Policy

It is our policy to post any changes we make to the Policy on this page.  The date the Policy was last revised is identified at the bottom of the page.  You are responsible for periodically visiting the Site and the Policy to check for any changes.

How to Contact AIGA

Contact AIGA when you notice any suspicious account activity or experience any information security related events.


(Latest Update: August 4, 2022).