This Privacy Policy (this “Policy”) describes the ways in which VareCo, LLC (together with its affiliates, “Provider”) collects, uses, and discloses information about you, including personally identifiable information, in connection with your use of the website https://thevareco.com/ (the “System”). Please read this notice carefully to understand what we do. Throughout this Policy, “you” refers to the individual or entity that is visiting the System. By using the System, you consent to the use and retransmission of your information as set forth in this Policy (subject to applicable law).
(a) Scope. The types of personal information we collect and share depends on the product or service you have with us. This information can include:
- (i) Social security number
- (ii) Income
- (iii) Assets
- (iv) Risk tolerance and
- (v) Transaction history..
(a) Information that You Provide. Provider collects from you the personal information you voluntarily provide in connection with your use of the System, including, but not limited to, any information you choose to disclose if you meet with us to discuss our business, if you complete a subscription agreement, or communicate with us about an investment.
(b) Automatically Collected Information. Provider may automatically collect certain technical information from your computer or mobile device when you use the System, such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the System, the pages you view immediately before and after you access the System, and the search terms you enter on the System. This information allows Provider to recognize you and personalize your experience if you return to the System using the same computer or mobile device, and to improve the System and the Services.
(c) Information about Legal and Other Materials. Provider may collect technical information from your computer or mobile device concerning your receipt of communications, access to materials and approval or execution of contracts, consents or other statements or agreements by means of the System, including the System’s Terms of Use and this Policy.
(d) Cookies. Provider may collect information using “cookies,” which are small text files that the System saves on your computer or mobile device, or similar technologies. You can disable cookies in your browser settings, but doing so may affect the functionality of the System. Provider may also collect information using “web beacons,” which are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon or using unique links that can distinguish when individual users click the link. Web beacons and unique links, alone or in conjunction with cookies, may help Provider compile information about your interactions with electronic mail sent to you in connection with the Services.
(a) Accessing the System and Providing the Services. Provider uses your Personal Information to provide you with the services, or products, services or information related to the System, including: providing you with information about the System, services or required notices; customizing your experience when using the System, such as by providing interactive or personalized elements on the System; and providing you with content based on your interests. The legal basis for such use are the System’s Terms of Use and this Policy.
(b) Internal Business Uses. Provider uses your Personal Information for its everyday business purposes – such as to process your transactions, maintain any accounts(s) or respond to court orders and legal investigations.
(c) Analysis. Provider uses your Personal Information for improving the System and/or the services, including by (i) combining or aggregating any of the information collected through the System or elsewhere for generating and analyzing statistics about your use of the System and user demographics and traffic patterns and (ii) using anonymized data that may or may not be derived from Personal Information but does not personally identify you, both for disclosure to third parties and affiliates and for the purpose of enhancing the System’s services and developing new service offerings. The legal basis for such use are the System’s Terms of Use and this Policy and Provider’s legitimate interest in improving the System and any services related thereto.
(d) Security. Provider may use your Personal Information for safety and security purposes, including sharing of your information for such purposes, when it is necessary to pursue Provider’s legitimate interests in ensuring the security of the System, including detecting, preventing and responding to fraud, intellectual property infringement, violations of the System’s Terms of Use, violations of law or other misuse of the System; and when Provider believes in good faith that disclosure is necessary (A) to protect Provider’s rights, the rights of other users of the System, the integrity of the System, or your safety or the safety of others, or (B) to detect, prevent or respond to fraud, intellectual property infringement, violations of the System’s Terms of Use, violations of law or other misuse of the System.
(e) Marketing. If you submit your information to Provider, Provider may provide you with information about the System, services or required notices. In addition, Provider, and its affiliates, may use collected information for delivering marketing communications that may be of interest to you. You have the right to ask Provider not to process your Personal Information for marketing purposes.
(f) Other Disclosure. Provider may collect information using “cookies,” which are small text files that the System saves on your computer or mobile device, or similar technologies. You can disable cookies in your browser settings, but doing so may affect the functionality of the System. Provider may also collect information using “web beacons,” which are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon or using unique links that can distinguish when individual users click the link. Web beacons and unique links, alone or in conjunction with cookies, may help Provider compile information about your interactions with electronic mail sent to you in connection with the Services.
(a) Jurisdiction. Information collected through the System will be stored in, processed in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the System, you consent to such transfer to, storage in and processing within the United States.
(b) Security. Provider is committed to protecting your information from unauthorized access, use or disclosure. The system and its operators maintain administrative, technical and physical safeguards designed to protect the information collected through the System. However, no information or communication system can be 100% secure, so Provider cannot guarantee the absolute security of your information. In addition, Provider is not responsible for the security of information that you transmit to the System over networks that Provider does not control, including the Internet and wireless networks.
(c) Retention. Provider will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. If you wish to access or correct any information Provider holds about you, you may have your data deleted, blocked or corrected (as long as compliant with applicable law). Provider also collects and retains information through the System in an anonymized form, i.e. tracking the pages you visit and how long was spent on each page.