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• Personal Data Collected
  • We only collect personal data that you provide to us.
  • If you register for certain Services on iRely’s website (the “Website”), you will be asked to provide certain personally identifiable information as part of the registration process, such as first and last name, e-mail address, telephone number.
  • In addition, in using the services provided by iRely (the “Services”), you may be asked to provide additional information about the hedge funds that you represent or manage (if applicable), investment parameters, personal financial and account information, information relating to services performed for or transactions entered into on behalf of a hedge fund or another registered user, and data or analyses derived from such non-public personal information.
  • You may visit our Website and choose not to provide some personal information, but that will limit our ability to communicate with you or fulfill your requests. By using our Website and providing personal information, you consent to our privacy policy.
  • We also may use personally identifiable information to develop, offer, and deliver products and services; respond to inquiries from you or your representative; or to fulfill legal and regulatory requirements.
  • iRely may collect non-public personal data about you from any of the following sources:
    • From you or your representative on applications, registrations, or other forms (for example, your name, address, assets and income);
    • From you or your representative regarding your preferences (for example, based on your activity on our Website);
    • From other sources with your consent or with the consent of your representative (for example, from other institutions such as credit reporting agencies);
    • From investment activity (for example, your investments in private placements);
    • From information you have listed on any public area of your company’s website.
    • From other interactions with IRely iRely (for example, discussions with our customer service staff or your entry of information into our interactive tools); and
    • From email correspondence from you or phone conversations with you (we may gather the information in a file specific to you).
• Non-Personal Information Collected
  • We also may collect certain non-personally identifiable information when you visit the Website.  This information includes the type of Internet browser and operating system you are using, the domain name of your Internet service provider, the URL that you visited before you came to our Website, the URL to which you next go, and your IP (Internet Protocol) address, pages visited, and average time spent on our Website. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Website design and functionality. When you use the contact features of the Website, you consent to the review and internal use of your communication by iRely. We also may use non-personally identifiable information in the aggregate to analyze Website usage and to gather broad demographic information.
• Cookies
  • We also receive information through cookies, clear GIFs, pixel tags, and other similar technologies. This information often does not reveal your identity directly, but in some countries, including the EEA, it is considered personal data.
  • We use cookies to improve and customize your browsing experience. For example, cookies permit the Website to remember that you have registered, which makes it possible for you to enter your log in ID and password less frequently and which allows us to speed up your activities on the Website.
  • Most web browsers are initially set to accept cookies. However, you can block, disable, or delete cookies, if desired. This often can be done by changing your internet software browsing settings. It also may be possible to configure your browser settings to enable acceptance of specific cookies or to notify you each time a new cookie is about to be stored on your computer enabling you to decide whether to accept or reject the cookie. To manage your use of cookies there are various resources available to you, for example the “Help” section on your browser may assist you. You also can disable or delete the stored data used by technology like cookies, such as Local Shared Objects or Flash cookies, by managing your browser’s “add-on settings” or visiting the website of the browser’s manufacturer.  To learn more about how cookies can be managed, blocked, disabled, or deleted, visit allaboutcookies.org.  However, as our cookies allow you to access some of our Website’s features, we recommend that you leave cookies enabled, because, otherwise, if the cookies are disabled or deleted, it may mean that you experience reduced functionality or will be prevented from using the Website altogether. 
  • By accessing or using our Website or online services, you consent to iRely using cookies. If you refuse to accept cookies by adjusting your browser setting or taking any of the other kinds of actions discussed above, some or all areas of our Website or online services may not function properly or may not be accessible.
• Our Use of Personal Data
  • Generally, iRely will not share, rent, sell or otherwise disclose any of your personal information except with your permission.  However, iRely may disclose personal information in the following ways:
    • If you are a qualified investor, as necessary to enable managers or representatives of private investment funds to make determinations with respect to the eligibility and suitability of you as a qualified investor, and to contact you for purposes of discussing investment opportunities in private investment funds;
    • If you are a manager or representative of a private investment fund, as necessary to enable qualified investors who are registered users to make determinations with respect to the eligibility and suitability of such investment fund, and to contact you for purposes of discussing such investment opportunities;
    • In using certain of the services, some of your personal information will be displayed either to other persons or entities whom you designate, or to the public;
    • Affiliates, including affiliated services providers;
    • We may disclose your personal information to our third-party contractors, service providers, and agents who perform services for iRely. These contractors and service providers are permitted to use the personal information only for the purposes of such services;
    • We may be legally obligated to disclose personally identifiable information to the government, law enforcement officials or third parties under certain circumstances, for example, in response to legal process, court order or a subpoena and tax reporting. We also may disclose such information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, unauthorized access, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, abuse of this Website, security breaches of this Website, or as necessary to protect our systems, business, users or others or as otherwise required by law;
    • We may disclose and transfer your information as part of a merger, acquisition or other sale or disposition of our assets or business;
    • Other organizations, with your consent or as directed by your representative; and
    • Other organizations, as permitted or required by the laws that protect your privacy (for example, for fraud prevention).
    • We require each of the above parties to adhere to our privacy standards or substantially similar standards for non-disclosure and protection of personal information and to use this information only for the limited purpose for which it was shared. Individuals interact with us in a variety of ways, and under some of these variations, we may exchange information with parties in addition to those described above.
    • We may also share all individual investor information, under joint marketing agreements with nonaffiliated financial services business partners, to offer discounts or other special access to products and services. In addition, we may disclose aggregated information to advertisers and for marketing or promotional purposes. In these situations, we do not disclose to these entities any information that could be used to personally identify you.
    • If you are a former customer, your personal data is treated in the same manner as the personal data of current customers.

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The Website and its services are not directed toward children under the age of 14.  iRely will not knowingly request personally identifiable information from anyone under the age of 14, and if IRely iRely becomes aware that any such information has been collected, iRely will delete it.

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If you have any questions regarding this Policy, you can write to iRely’s Data Privacy Officer, who may be contacted by telephone at 1-800-433-5724, by e-mail at billing@irelybilling@iRely.com, or by postal mail at:

IRelyiRely

Attn: Data Privacy Officer

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