Privacy Policy

How We Use and 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:

• a) Information we receive about you on applications and other forms including subscription documents, questionnaires and online registration forms, whether we receive the form in writing or electronically. For example, this information may include your name, address, telephone number, e-mail address, tax identification number, income and other financial data, investment experience, and possibly your personal bank account information.
• b) Information about your transactions and account history with us, our affiliates and others, including initial and follow-on subscriptions, transfers and withdrawals or redemptions.
• c) Information we receive about you from third parties such as solicitors, brokers, selling agents, advisers, product sponsors, exchanges, clearing firms and/or their respective service providers.
• d) Information from online forms you complete and data we receive when you visit our website (such as internet protocol address, and browser software).
• e) The website is not directed toward children under the age of 13, and we do not knowingly collect personal information from children under 13.

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

If you are visiting this website or accessing services from us or the funds we manage, from outside the United States, be aware that you are sending information (including your nonpublic personal information) to the United States where our principal office is located.  That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored.  These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will always continue to be governed by this Privacy Policy.

Use of Internet “Cookies”

We may use cookies on our website to enhance a visitor’s experience on the site and to make decisions about ways to improve the website. A cookie (or browser cookie) is a small file placed on the hard drive of your computer. It contains information about preferences for using a website that have been established by someone using a browser on that computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you access or use our website. Cookies are used to store visitors’ preferences, collect information about how and how often visitors use the website, analyze user trends and improve the website.

We may disclose the presence of a cookie to third parties to advertise our services. For example, we may ask advertisers to display ads promoting our services on other websites based on the presence of a cookie. We may also contract with third-party advertising networks, including Google, that use cookies, or other tracking technologies to collect certain non-personal information about your activities on the website and on third-party websites to provide you with targeted advertising based upon your interests. We may also use cookies delivered by third parties to track the performance of our advertisements.

You may be prompted to accept our use of cookies on the website. You may refuse to accept the use of cookies when prompted on the site, or you may refuse to accept by activating the appropriate privacy settings on your browser. Most browsers provide the flexibility to reject all cookies, accept all cookies, or accept cookies only from sites you trust. Please note that if you refuse to accept browser cookies, your access to or use of certain portions of the website may be limited.

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 we share 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).