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We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.
Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or means of enforcement.
In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, FundGuard, Inc. (together, “FundGuard” “we”, “our” or “us”) use, collect, and store personal data we collect or receive from or about you (“you”) such as in the following use cases:
When you browse, visit and/or interact with our website, www.fundguard.com/ (“Website”)
This Privacy Policy can be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy. If we implement significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our website or by other means.
FundGuard provides a next generation asset management true-SaaS platform that is powered by artificial intelligence. It helps asset managers, custodian banks and fund administrators manage investment portfolios including mutual funds, ETFs and separate accounts, and provides greater digital engagement and transparency. For the avoidance of doubt, for the purposes of this Privacy Policy, a “Customer” is an entity which has executed an agreement with FundGuard. If you are an individual, using FundGuard’s services as a result of our relationship with Customer (“Individual(s)”), please note that the Customer is the responsible party for obtaining the required consents and complying with any applicable laws or regulations.
| Specific personal data we collect | Cookies: Fundguard.com uses the default HubSpot tracking code to store cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. You have the option to accept or decline cookie tracking upon visiting our website. If you decline, your information will not be tracked when you visit fundguard.com. A single cookie will be used in your browser to remember your preference not to be tracked. You can learn more about HubSpot’s cookie tracking codes here. |
| Why is the data collected and for what purposes | We use this information to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media. |
| Legal basis (GDPR only, if applicable | Consent and/or Lawful Basis: Legitimate Interest |
| Third parties with whom we share your data | Cookies consent tracking is captured and stored in HubSpot. Read more about the purposes of each cookie here. |
| Period of storage | We will store your Personal Information for a period of time as reasonably required or permitted by law for the purpose of business development, customer and prospect communications, relationship management, legal negotiations, and customer support - and/or until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period. |
| Consequences of not providing the data | Certain Website features and/or content, Customer Knowledge information and product access may not be available. |
| Specific personal data we collect |
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| Why is the data collected and for what purposes |
If you are an Individual (as defined above), please note that our Customer is legally responsible for the collection, transfer and use of your personal data. FundGuard is providing a service on behalf of the Customer, so you should contact the Customer for any privacy-related questions |
| Legal basis (GDPR only, if applicable |
Consent and/or legal basis: Legitimate Interest
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. |
| Third parties with whom we share your data | FundGuard’s authenticator systems, including: Cognito within AWS and Active Directory B2C in Azure. As of July 2023, we will be using SAML IDP integration. |
| Period of storage |
Until you send a deletion request or unsubscribe, or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period. |
| Consequences of not providing the data |
We cannot verify your credentials and therefore, we:
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| Specific personal data we collect |
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| Why is the data collected and for what purposes |
To respond to support requests (e.g., to solve problems, resolve bugs or other issues)
To improve overall client services
If you are an Individual (as defined above), please note that our Customer is legally responsible for the collection, transfer and use of your personal data. FundGuard is providing a service on behalf of the Customer, so you should contact the Customer for any privacy-related questions. |
| Legal basis (GDPR only, if applicable |
Consent and/or legal basis: Legitimate Interest
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. |
| Third parties with whom we share your data |
FundGuard’s authenticator systems, including: Cognito within AWS and Active Directory B2C in Azure. As of July 2023, we will be using SAML IDP integration.
And:
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| Period of storage |
Until you send a deletion request or unsubscribe, or we proactively decide to delete the data.
Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period |
| Consequences of not providing the data |
Cannot provide you support Cannot assist you to solve problems Cannot improve your customer experience and services |
| Specific personal data we collect |
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| Why is the data collected and for what purposes |
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| Legal basis (GDPR only, if applicable |
Consent and/or legal basis: Legitimate Interest Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. |
| Third parties with whom we share your data | Requests for demos submitted via the Website are logged and managed in HubSpot |
| Period of storage |
Until you send a deletion request or unsubscribe, or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period. |
| Consequences of not providing the data |
Cannot provide you with the request demo
Cannot communicate with you with respect to the demo and related coordination |
| Specific personal data we collect |
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| Why is the data collected and for what purposes |
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| Legal basis (GDPR only, if applicable | Consent and/or legal basis: Legitimate Interest |
| Third parties with whom we share your data | Subscription forms submitted via the Website are logged in HubSpot Webinar registrations are logged in HubSpot and eWebinar. Please view the eWebinar privacy policy |
| Period of storage |
Until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period. |
| Consequences of not providing the data |
You will not receive FundGuard news and insights, including blog content, company announcements, webinar launches and other marketing communications re: thought leadership. You cannot access FundGuard webinars |
| Specific personal data we collect |
All information is captured within the Comeet portal. Please Refer to FundGuard's Use of Comeet for Job Applicants policy outlined in item 11 below. |
| Why is the data collected and for what purposes |
|
| Legal basis (GDPR only, if applicable |
Consent and/or legal basis: Legitimate Interest
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract |
| Third parties with whom we share your data | Contact and/or information requests submitted via the Website are logged in HubSpot, and may also be logged in G-Suite for the purpose of direct email communications. |
| Period of storage |
Until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period. |
| Consequences of not providing the data |
Cannot process and answer your questions Cannot customize your experience |
| Specific personal data we collect |
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| Why is the data collected and for what purposes |
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| Legal basis (GDPR only, if applicable |
Consent and/or legal basis: Legitimate Interest Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. |
| Third parties with whom we share your data | Personal Data received via a marketing event is logged in HubSpot |
| Period of storage |
Until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period. |
| Consequences of not providing the data |
Cannot establish a business connection
Cannot send you marketing communications or company/product information. |
| Specific personal data we collect |
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| Why is the data collected and for what purposes |
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| Legal basis (GDPR only, if applicable |
Consent and/or legal basis: Legitimate Interest Dependent on the context, relevance in relation to partner and customer relationship management, business development, investor relations, etc. |
| Third parties with whom we share your data | Personal Data received via a business card exchange is logged in HubSpot. |
| Period of storage |
Until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period. |
| Consequences of not providing the data |
Cannot establish a business connection. Cannot send you company products, thought leadership and marketing communications of interest. |
| Specific personal data we collect |
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| Why is the data collected and for what purposes |
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| Legal basis (GDPR only, if applicable |
Processing is necessary for the performance of a contract to which our customer is a party. Compliance with a legal obligation (e.g., tax laws, bookkeeping laws, etc.). Legitimate interest (e.g., send you contract-related communications) |
| Third parties with whom we share your data |
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| Period of storage |
Until you send a deletion request or unsubscribe, or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period. |
| Consequences of not providing the data |
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| Specific personal data we collect |
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| Why is the data collected and for what purposes |
|
| Legal basis (GDPR only, if applicable |
Consent and/or legal basis: Legitimate Interest Dependent on the context, relevance in relation to partner and customer relationship management, business development, investor relations, etc. |
| Third parties with whom we share your data |
|
| Period of storage |
Until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period. |
| Consequences of not providing the data |
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| Specific personal data we collect |
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| Why is the data collected and for what purposes |
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| Legal basis (GDPR only, if applicable | Depending on the context, legitimate interest (e.g., certain B2B marketing practices or replying to your requests/questions), pre-contractual discussions (e.g., if you show interest in our products/services) or consent |
| Third parties with whom we share your data |
Third party platforms such as for the following purposes:
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| Period of storage |
Until you send a deletion request or unsubscribe, or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period. |
| Consequences of not providing the data |
Cannot reply or respond to your request Cannot establish a business connection |
Finally, please note that some of the aforementioned personal data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience
with them).
2.1 Security.
We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
2.2 Retention of your personal data.
In addition to the retention periods mentioned above, in some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, we defer to the HubSpot default cookie policy, which you can read here.
In addition to the recipients described above, we may share your personal data as follows:
3.1 With our business partners with whom we jointly offer products or services.
We may also share Personal Data with our affiliated companies.
3.2 To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local
laws), and requests of law enforcement, regulatory and other governmental agencies or
if required to do so by court order;
3.3 If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
3.4 In the event that we are acquired by, or merged with, a third-party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or
3.5 Where you have provided your consent to us sharing or transferring your personal data
(e.g., where you provide us with marketing consents or opt-in to optional additional
services or functionality).
If you want to receive the list of the current recipients of your personal data, please make
your request by contacting us to privacy@fundguard.com.
4.1 Storage: AWS and Microsoft Azure with servers located in North America and Europe, Microsoft Azure, G Suite (Google maintain servers around the world), HubSpot. For more information, regarding Google’s legal frameworks for data transfers, please visit the following links: https://policies.google.com/privacy/frameworks and https://support.google.com/policies/troubleshooter/7575787?visit_id=637039011088496587-3381196795&hl=en&rd=2#ts=7576505. Please see the HubSpot Data Processing Agreement at https://legal.hubspot.
4.2 Internal transfers: We ensure transfers within the FundGuard group will be covered by an agreement entered into by members of the FundGuard group (an intra-group agreement) which contractually obligates each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.
4.3 Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
4.4 External transfers: Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.
5.1 The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals (some of which only apply to individuals protected by the GDPR): You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
You can exercise your rights by contacting us at privacy@fundguard.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
5.2 Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@fundguard.com. If you terminate your account, any association between your account and personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of 18. If you are under the age of 18, do not provide any personal data to us without the involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@fundguard.com.
We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third-Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third-Party Service.
Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
10.1 California Civil Code Section 1798.83: permits our customers who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email privacy@fundguard.com. Please note that we are only required to respond to one request per customer each year.
10.2 Our California Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
10.3 Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
This privacy notice (the “Notice”) describes the ways that FundGuard recruiting you as a candidate (“Company”, “we”, “us”, “our”), collects and uses your personal data as a candidate (“you” or “candidate”). We work with data processors to whom we have instructed to collect, store and process personal information on our behalf for the purposes of providing our services, for example, Comeet, as a recruiting and applicant tracking platform (“Platform”) in order to handle your personal data as a candidate. It also describes the rights and options available to you with respect to your personal data.
The additional privacy notice within this page explains our own specific privacy practices related to your personal data (“Privacy Policy”).
Please note that this Notice is provided only for transparency purposes. If you have any questions related to your personal data, you should contact FundGuard directly: privacy@fundguard.com.
We are the responsible party for the candidates’ personal data when provided to the Platform in the context of your candidacy. We determine the means and purposes for the processing of your personal data.
11.1 PERSONAL DATA PROCESSED
We receive personal data about you as a candidate for positions at the Company, such as: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you, the Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the Company about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy. If you submit your candidacy by email, or online, then you are the main source of the personal data. Your personal data can also originate from other sources, such as LinkedIn profile, recruitment agencies, headhunters and referrals.
11.2 HOW YOUR PERSONAL DATA IS USED. LEGAL BASIS.
We will use your personal data in accordance with our Privacy Policy, including to evaluate and consider you as a candidate for positions, in accordance with its processes and policies for evaluating employment candidates, to contact you for your candidacy status and interviews, to schedule meetings and interviews, amongst others.
The lawful bases we rely on for processing personal information are (if applicable to us under privacy law):
If you have questions about these uses, please contact us. Please note that the legal basis is provided for GDPR purposes only.
11.3 WHO WILL PROCESS YOUR DATA
We may share your personal data with our service providers and vendors who assist us to collect, process and store your personal data, including, Comeet (who provide us with the Platform) in the context of your candidacy. These companies are authorized to use your personal data as necessary to provide these services or as otherwise authorized by us. Comeet’s privacy policy is available here.
Personal data may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly).
We may share your general recruitment status with third parties who submitted your candidacy to us.
If your details are submitted to the Company by a third-party (such as an employee of the Company or a recruiting agency), the Company can give the third-party access to your name, photo and some of the general recruitment status.
If you apply to a job opening using a unique referral link that was provided to you by an employee of the Company to which you are applying, the Company may share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link.
The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of the Company and to provide feedback to third-parties who submit candidates to the Company regarding their submission.
If we are required to disclose your information by a judicial, governmental and/or regulatory authority to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.
If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events.
In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.
If you wish to receive further information, please contact us.
11.4 SECURITY AND DATA RETENTION
11.5 INTERNATIONAL DATA TRANSFERS
We host your personal data in connection with our use of the Platform either in the European Economic Area, in the US, in the country where we are located, or in countries deemed as providing an adequate level of data protection.
Your data will be accessible in the country where we or our service providers are located, the UK, the US, and countries deemed as providing an adequate level of data protection.
See here the Platform’s vendors. For more information, please contact us.
11.6 YOUR RIGHTS
Your rights may vary, depending on the applicable law. These rights may not be available in certain jurisdictions and/or may be subject to certain derogations or limitations. You may have the following rights:
If we rely on consent, please note that you have the right to withdraw consent at any time; and/or to lodge a complaint with a supervisory authority.
If you wish to exercise any of these rights, please contact us. If you choose to exercise any of your rights, we will handle these requests in accordance with applicable law but please note that exercise of some of those rights may have some consequences in your application as a candidate.
In the context of the Platform we do not use any automated decision-making related to your personal data.
11.7 MINORS
We do not intend to collect personal data of children. If you have reason to suspect that children data is collected, you are kindly requested to immediately report it to us. If you have questions regarding children’s personal data contact us.
11.8 CHANGES TO THIS PRIVACY NOTICE
From time to time, we may change or update this Notice. If we do so, we will make efforts to notify you of such changes by any means.
11.9 CONTACT US
You may send requests, responses, questions and complaints by contacting us at privacy@fundguard.com.
(GDPR only) If your question relates to our data protection officer (DPO) or representative in the EU, we will forward the request accordingly.
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@fundguard.com.
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