Effective: June 4, 2020
TenViz LLC (collectively, “TenViz,” “we,” “us,” or “our”) are committed to
protecting the privacy of all individuals who utilize our website or investment
products and services. TenViz is the data controller of the personal data
collected, and is responsible for the processing of your personal data.
the information you may provide to us via this website and other domains
owned and/or operated by TenViz. The Policy also informs you about your
privacy rights and how the law protects you. Certain other TenViz website
(e.g., file sharing platforms) may be operated under separate agreements
having additional terms and conditions.
It is important that you read this Policy together with any other notice we may
provide on specific occasions when we are collecting or processing personal
data about you so that you are fully aware of how and why we are using your
data. This Policy supplements the other policies and is not intended to
override them. In the event of a conflict between this Policy and another policy
which applies to a specific site or engagement (i.e., file sharing platforms), the
latter shall prevail over this Policy to the extent of the conflict.
Please review the following to understand how we process and safeguard personal
data about you. By using our website and services from us, and/or by voluntarily
providing personal data to us, you acknowledge that you have read and understand
time, so please ensure that you check this Policy periodically to remain fully informed.
What Information Do We Collect?
We collect a variety of personal data (meaning information about an individual
from which that person can be identified) from and about you, in a number of
situations. What data we collect will depend on the specific circumstances:
- when you provide your personal data to us in direct communications with
us through our website, by email, phone, or otherwise, such as when you
subscribe to receive publications or product updates, including your name,
employer information, and contact details;
- when you instruct us in connection with the provision of investment
products and services, you may provide us with personal data, including
your name, contact details, and such other information as may be
appropriate in context;
- we may also ask you to provide, in certain circumstances, additional
personal data in order for you to apply for a job or to comply with legal
obligations to which we are subject;
- automatically through logging and analytics tools, cookies, and as a result
of your use of and access to our website. We utilize commonly-used
logging and analytics tools to collect information about your device, the
network used to access the website, and occasionally about your use of
the website (such as how you navigate and move around the website).
You have choices about certain information we collect. When you are asked
to provide information, you may decline to do so; but if you choose not to
provide information that is necessary for us to collect by law or to perform a
contract, we may not be able to enter into or perform such contract or perform
other obligations with respect to you. In addition, as noted below in the section
captioned “Your Choices” it is possible to change your browser settings to
block the automatic collection of certain information.
We also collect data that is not identifiable to you or otherwise associated with
you, such as aggregated data, and is not personal data. To the extent this
data is stored or associated with personal data, it will be treated as personal
data; otherwise, that data is not subject to this Policy.
In the event that you provide us with information about another person, you
must ensure that you have the right to provide that information and, as
appropriate, that they understand how their information will be used by us.
How Do We Process Personal Data?
We process personal data as follows:
Operational and Marketing Uses. We process your personal data as part of our
business operations and for marketing, which include:
- providing you with information tailored to your requests, responding to
inquiries, and delivering and managing investment products and services;
- screening and other activities in connection with employment or other
engagement by us of you;
- communications with you regarding our investment products and services;
- compliance with our legal obligations, including compliance checks, and
- endeavoring to protect our rights, property, or safety, and the rights,
property, and safety of our users and other third parties;
- in connection with the exercise or defense of our legal rights, as well as in
response to court orders.
Legal Bases for Processing. We process personal data for, or based on, one or
more of the following legal bases:
- to facilitate your investment in products and services offed by TenViz on
an ongoing basis which are necessary to fulfill all contractual and
regulatory obligations related to your investment;
- as is necessary for our legitimate interests, including direct marketing;
- to comply with the law and our legal obligations, as well as to protect you
and other individuals from certain harms;
- in certain circumstances, based on your express consent.
Sharing of Personal Data. Some of the above processing involves sharing
collected personal data with third parties, including service providers and
affiliates. This occurs in the following circumstances:
- we share personal data with third parties when you ask us to do so;
- we share personal data among our affiliated entities;
- we share personal data with our service providers, including, as
applicable, IT service providers, commercial email providers, security consultants,
and other vendors we engage so that they may provide
services to us or on our behalf;
- we share personal data with third parties when we believe it is required by,
or necessary to comply with, applicable law.
We do not sell or rent your personal information to third parties.
Protecting Personal Data
Because security is important to both TenViz and you, we employ reasonable
and appropriate physical, technical, and organizational safeguards designed
to promote the security of our systems and protect the confidentiality, integrity,
availability, and resilience of personal data. If you suspect unauthorized
access to your information, you should contact TenViz immediately as
provided in the section captioned “Additional Information and Assistance”
No method of safeguarding information is completely secure. While we use
measures designed to protect personal data, we cannot guarantee that our
safeguards will be effective or sufficient. In addition, you should be aware that
Internet data transmission is not always secure, and we cannot warrant that
information you transmit to us through the Internet is or will be secure.
Retention of Personal Data.
We retain personal data for as long as is necessary to fulfil the purpose for
which it was collected, as well as to the extent we deem necessary to carry
out the processing activities described above, including compliance with
applicable laws, regulations, rules and requests of relevant law enforcement
and/or other governmental agencies, and to the extent we reasonably deem
necessary to protect our rights, property, or safety, and the rights, property,
and safety of our users and other third parties. For details on the retention
periods applicable to specific elements of your personal data, please contact
us as provided in the section captioned “Additional Information and
Your Rights Regarding Personal Data
You have a variety of legal rights regarding the collection and processing of
personal data. You may exercise these rights, to the extent they apply to you,
by contacting us as provided in the section captioned “Additional Information
and Assistance” below, or by following the instructions provided in this Privacy
Policy or in communications we send to you. Please be prepared to provide
reasonable information to identify yourself and authenticate your requests.
Note, however, that we may request certain reasonable additional information
(that may include personal data) to help us authenticate the request and/or to
clarify or understand the scope of such requests.
These rights vary depending on the particular laws of the jurisdiction
applicable to you, but may include:
- the right to know whether, and for what purposes, we process personal
data about you;
- the right to be informed about the personal data we collect and/or process
- the right to access, modify, and correct personal data about you (as set
forth in more detail below under “Accessing, Modifying, Rectifying, and
Correcting Collected Personal Data”);
- the right to know with whom we have shared personal data about you, for
what purposes, and what personal data has been shared (including
whether personal data was disclosed to third parties for their own direct
- where processing of personal data about you is based on consent, the
right to withdraw your consent to such processing;
- the right to lodge a complaint with a supervisory authority located in the
jurisdiction of your habitual residence, place of work, or where an alleged
violation of law occurred.
Accessing, Modifying, Rectifying, and Correcting Collected Personal Data. We
strive to maintain the accuracy of any personal data collected from you, and
will use commercially reasonable efforts to respond promptly to update our
database when you tell us the information in our database is not accurate.
However, we must rely upon you to ensure that the information you provide to
us is complete, accurate, and up-to-date, and to inform us of any changes.
Please review all of your information carefully before submitting it to us, and
please notify us as soon as possible of any updates or corrections.
In accordance with applicable law, you may obtain from us certain personal
data that we process about you. If you wish to access, review, or make any
changes to personal data you have provided to us through our website or
related services, you may do so at any time by contacting us as provided
below. Please note, however, that we reserve the right to deny access as
permitted or required by applicable law.
In addition to your choices with respect to the collection of personal data (see
“What Information Do We Collect?” above), you have the ability to make
certain choices about how we communicate with you, and how we process
certain personal data.
Communications Opt-Out. You may opt out of receiving marketing or other
communications from us at any time through a given communications channel
(such as email or telephone) by following the opt-out link or other unsubscribe
instructions provided in any email message received and/or by contacting us
as provided in section captioned “Additional Information and Assistance”
Cookies, Web Tracking, and Advertising. If you wish to disable the storage of
cookies on your computer, you may do so by using the settings on your
browser or device. Most browsers will tell you how to stop accepting new
cookies, how to be notified when you receive a new cookie, and how to
disable existing cookies. For mobile devices, you can manage how your
device and browser share certain device data by adjusting the privacy and
security settings on your device. Please note, however, that without cookies,
you may not be able to use all of the features of our websites and file sharing
Other Important Information About Personal Data.
respect to personal data, including:
Collection of Personal Data from Children. The website is designed for a general
audience and is not directed to children under the age of 13. We do not
knowingly collect or solicit personal information from children under the age of
13 through the website. If we become aware that we have collected personal
information from a child under the age of 13 through the website, we will
promptly delete the information from our records. If you believe that a child
under the age of 13 may have provided us with personal information through
the website, please contact us as provided in the section captioned “Additional
Information and Assistance” below.
Third-Party Websites and Services. As a convenience, we may reference or
provide links to third-party websites and services, including those of
unaffiliated third parties, our affiliates, service providers, and third parties with
which we do business. When you access these third-party services, you leave
our website, and we are not responsible for, and do not control, the content,
security, or privacy practices employed by any third-party websites and
services. You access these third-party services at your own risk and this
privacy notices or policies for such third-party services for information about
how they collect, use, and process personal data.
Business Transfer. We may, in the future, sell or otherwise transfer some or all
of our business, operations or assets to a third party, whether by merger,
acquisition or otherwise. Personal data we obtain from or about you via the
website or through investment products and services we provide to you may
be disclosed to any potential or actual third-party acquirers and may be
among those assets transferred.
Do Not Track. We use analytics systems and providers that may process
personal data about your online activities over time and across third-party
websites or online services. We do not currently process or comply with any
web browser’s “do not track” signal or similar mechanisms.
International Transfers. We may share your personal data as noted in the
section “Sharing of Personal Data” with third parties, including service
providers and affiliates, and this may involve the transfer of your personal data
to jurisdictions outside of the United States. Also, if you are using the website
from outside the United States, by your use you acknowledge that we will
transfer your data to, and store your personal data in, the United States.
you about our information practices with respect to the website and any
publications or services which are otherwise available through our website.
We reserve the right, at any time, to modify, alter, and/or update this Privacy
Policy, and any such modifications, alterations, or updates will be effective
to notify you in the event material changes are made to our processing
posting a notice for a period of time on the website. Your continued use of the
website and any publications or services which are otherwise available
By using this website and voluntarily providing your personal data to us, you
acknowledge the processing of your personal data in accordance with this
Additional Information and Assistance
we process personal data, or would like to exercise any of the legal rights set
forth above, or to make a complaint about the way TenViz has collected, used
or retained your personal data please contact us at: