Privacy Policy

Malartu, Inc. respects your privacy and is committed to protecting it through our compliance with this policy.

*Last Modified: October 9th, 2017

Malartu (the “Company,” “we,” “ours,” “us”) respects and values your privacy, and we are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide when you visit or utilize www.malartu.co (the “Site,” a component of the Service) or the Malartu application programming interface (the “API,” a component of the Service), or utilize or interact with any other products, applications, or features provided by us (collectively, the “Service”), as well as our practices for collecting, using, maintaining, protecting, and disclosing that information. Any capitalized terms used herein that are not defined herein shall be given the meaning ascribed to them in our Terms of Use. 

By accessing or using the Service, you fully agree to all the terms of this Policy. If you do not agree with this Policy, or our other policies and practices, you must not use the Service. This Policy may change from time to time. Your continued use of this Service after such changes are made is deemed to be acceptance of those changes. It is your responsibility to check this Policy periodically for updates.

How this Privacy Policy Applies

This Policy applies to information we collect: (1) on this Site; (2) in any electronic communication between you and the Service; (3) through any mobile or desktop application (if any and when available) you download, which provides off-browser interaction between you and this Site; (4) through the API,  and (5) when you interact with our advertising or applications on third-party websites and services.

This Policy does NOT apply to information collected by: (1) us offline or through any other means, including on any other website or service operated by the Company or any third party (including our affiliates and subsidiaries); or (2) any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Service.

Children Under the Age of 18  

The Service is not intended for persons under the age of 18, and persons under the age of 18 are not permitted to register for access to the Service. We do not knowingly collect personal information from persons under the age of 18. If you are under 18, do not use or provide any information on this Site or attempt to register or use any features of the Service. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our privacy policy by instructing their children never to provide personal information on the Site. If you have reason to believe that a child has provided personal information through the Site, please contact us by email at Info@MalartuFunds.us. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.

Types of Information We Collect

We, along with any third-party companies or individuals with whom we work, may collect information directly and voluntarily from you when you use the Service. We consider the information we collect in two broad categories: “Non-Personal Information” and “Personal Information.”

a. Personal Information. Personal Information is generally information that can be used to identify you, either by itself or in conjunction with other information, which may be Non-Personal Information. Personal Information includes, without limitation:

  • Your name, postal address, e-mail address, telephone number, and Internet Protocol (“IP”) address;
  • Information and content that you provide or upload for use in connection with the Service, which may include information pertaining to a company you manage as an officer, director, and/or which is part of your investment portfolio; and
  • Demographic information such as date of birth, gender, and geographic area, when that information is linked to other Personal Information or Non-Personal Information that allows that individual to be identified.

*The preceding list of information we may collect is illustrative, not exhaustive.

b. Non-Personal Information. Non-Personal Information includes information that is about you but does not identify you personally, such as, without limitation:

  • Anonymous usage data, general demographic information we may collect;
  • Referring/exit pages and URLs; and
  • Preferences you submit and preferences that are generated based on the data you submit and number of clicks.  

We may also collect information from you that is about your internet connection, the equipment you use to access our Website, and usage details, including but not limited to: 

  • Browser or platform type, 
  • Internet connection, 
  • Equipment used to access the Service, 
  • Language preference, referring site, 
  • Additional websites requested, and 
  • The date and time of each user’s request.

 

How We Collect Information from You

Information we collect from you on or through the Service depends on how you utilize the Service and what information you agree to provide. We may collect information that you provide when you register to use the Service, and when you import and analyze Client Data through the Service, which may include information obtained from third party platforms or services. Additionally, we may collect information from you based on your interaction with our API; such information may be the information of third parties with whom you have interaction. We may also collect information from you when you enter a contest or promotion sponsored by us, report a problem with our Service, search the Service, or respond to polls or surveys distributed for research purposes. We require that you have the requisite consent and legal permission to provide us any Client, third party, or other entity’s information.

Our API also collects information, which may or may not be Personal Information, based upon the inputs to and utilization of the API by the third-party using the API. We cannot control how a third-party uses our API, but any information provided to us through the API will be collected and stored in accordance with this Privacy Policy and our Terms of Use. Furthermore, a third-party may use our API to extract information from the Service, in which case we cannot control how that third-party uses such information.

 

Client Data and Other Third-Party Information

As part of the Service, we collect, aggregate, and analyze data from other platforms or services maintained by our Clients (“Client Data”). Client Data we collect may contain information about: (a) Client’s own company, (b) one or more companies in which Client is an investor (each a “Portfolio Company”), (c) Personal Information and/or Non-Personal Information about individuals who may be officers, directors, customers or target customers of Client’s Company or a Portfolio Company. We collect Client Data only after the Client or authorized User has prompted the Service to obtain the Client Data. Client Data may include Personal Information and Non-Personal Information, and will be collected and stored in accordance with this Privacy Policy and our Terms of Use.

By submitting or authorizing us to collect Client Data, you hereby represent and warrant that you: 

  • Own, or possess all legal right to provide, use, and process such Client Data, as contemplated by this Agreement;
  • Have obtained all necessary consents for the disclosure and use of the Client Data under this Agreement, including use of Client Data by Malartu, and 
  • Have provided all notices to individual persons represented in the Customer Data and to the appropriate officers or directors of entities represented in the Customer Data as required by law or otherwise for the Company’s use of the Customer Data both during and after termination of this Agreement. 

 

Client and each User acting on Client’s behalf, acknowledges that in accessing or submitting data from External Platforms for use in connection with the Service, Client’s username(s), password(s), and any other security or access information for Client’s account(s) on such External Platforms, and data and other information in such account(s) (collectively, “External Platform Data”), may be collected and stored through the Service. In connection with Malartu’s provision of the Service, Client authorizes Malartu to: (a) access Client’s account(s) on External Platforms, and collect and process Client’s External Platform Data; (c) access the applicable third party websites and External Platforms using Client’s External Platform Data; and (c) take such other actions as are reasonably necessary to perform the actions described in (a) and (b) above. Client hereby represents and warrants that Client is the legal owner of Client’s External Platform Data and that Client has the authority to appoint, and hereby expressly does appoint, Malartu as Client’s agent to access and retrieve Client’s External Platform Data on Client’s behalf. Client further acknowledges and agrees that all External Platform Data is subject to the applicable terms and conditions of the Agreement. For further explanation regarding how we protect your External Platform Data, please see our Data Security page.

 

Automatic Data Collection and How We Use It

In an effort to improve the quality of the Service, the Company and our service providers may track information provided to us by your device or browser, or by our analytics tools when you use the Service. As you access, use, and interact with the Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to the Service, including traffic data, location data, logs the device from which you connected to the Service, website you came from (known as the “referring URL”), and other communication data and the resources that you access and use on the Service;
  • Information about your computer and internet connection, including your IP address, operating system, and browser type; 

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically is statistical data and may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve the Service and deliver a better and more personalized user experience.

 

Automatic Data Collection Technologies May Include

The technologies we use for the automatic data collection described above may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.
  • Flash Cookies. Certain features of the Service may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Components of the Service and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

 

Location Information

We may, from time to time, track use location through IP logging for security and fraud prevention purposes.

 

Do Not Track Disclosure

You may set your web browser to transmit a “Do Not Track” signal to websites and online services you visit. At this time, Malartu does not respond to or alter its practices when it receives a Do Not Track signal from a user’s web browser. For more information on Do Not Track, please visit www.allaboutdnt.com.

 

How We Use Personal Information

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent, or otherwise share for marketing purposes your Personal Information with third parties without your consent. We may share Personal Information with vendors who are performing services for the Company, such as the providers of servers for our email communications who are provided access to user’s email address for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy. 

*The following is a non-exhaustive list. 

We may use your Personal Information to:

  • Communicate with you. For example, we use Personal Information to contact Users in response to questions, solicit feedback from Users, provide technical support, and inform Users about promotional offers;
  • Facilitate and carry out the functions of the Service;
  • Verify your identity, including during account creation and password reset processes;
  • Enforce our Terms of Use and other policies, and preventing prohibited or illegal activities, or violations of our Terms of Use;
  • Improve the Service, including by customizing your user experience;
  • Provide targeted marketing, provide service update notices, and deliver promotional offers based on your communication preferences;
  • Administer referral programs, rewards, surveys, contests, or other promotional activities or sponsored events;
  • Comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements; 
  • For any other purpose disclosed to you and to which you consent.

 

How We Use Non-Personal Information

In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Site. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information, and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion. 

 

Malartu may compile information and data in an aggregated form related to the performance, operation, and use of the Service, and may use such aggregated data for security, statistical, or operations analyses, and for research and development purposes (collectively, “Data Reports”). Malartu may use and share Data Reports without restriction for its business purposes. Data Reports shall not incorporate Client Data in a form that would identify Client, sensitive information of Client, or any individual. Data Reports do not constitute Client Data, and Malartu shall retain all right, title, and interest in and to the Data Reports, including all associated intellectual property rights.

 

How We Disclose Information

We may disclose aggregated information about our users and any information that does not identify any specific individual, without restriction. We may also disclose any Personal Information or Non-Personal Information you share with us for the purpose of facilitating and carrying out the Service. We may also share Client Data, which may or may not include Personal Information, with other Users as authorized by you. For example, we may share information about a Portfolio Company with both the President of that Company and Investor of that Company if both the President and Investor have accounts on the Site

In the event that Client or any User on Client’s behalf shares or provides access to Client Data, including any External Platform Data or other information stored on the Service, with any third party who is not an authorized representative or otherwise permitted to access such Client Data or information, or instructs Malartu to provide access or release such Client Data or information with such third party, Client acknowledges and agrees that the Company (and its officers, directors, agents, subsidiaries, joint ventures and employees) will not be liable or responsible for any disputes, claims, losses, damages, or liabilities that are in any way related to or arising from such third-party obtaining or gaining access to such information. 

We may also disclose your personal information: (1) to comply with any court order, law, or legal process, including to respond to any government or regulatory request; (2) to ensure compliance with our Terms of Use and other agreements, such as billing; and (3) to protect the rights, property, or safety of the Company, our customers, or others. In addition, we retain the right to share your personal information with other companies and organizations for purposes of fraud protection.

 

Third Party Use of Cookies and Other Tracking Technologies 

Certain third party services or applications may be given access to data (which may include personally identifiable information) from your account or generated in connection with your use of the Service in accordance with this Privacy Policy, such as if we share data with any third party service provider or vendor for the purpose of facilitating the Service. While we will only disclose information to such third parties in accordance with the terms of this Privacy Policy and as necessary to facilitate the Service, we cannot control or verify how any such third parties may collect, use, or track information. Malartu shall not be responsible or liable for the policies or practices of any third party service provider. Users are strongly encouraged to review the Terms of Use and privacy policies of any third-party application or service with which they integrate or otherwise use in connection with the Service.

 

Data Security

We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks, and the Company shall not be responsible for the circumvention of any of the Service’s privacy settings or security measures. For further explanation about how we protect your information, please see our Data Security page.

 

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Site and visiting your account profile page.

You may also send us an e-mail at info@malartu.co to request access to, correct or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your Client Data from the Site, copies of your Client Data may remain viewable in cached and archived pages, or might have been copied or stored by other Site users to whom you previously granted access. Proper access and use of information provided through the Service, including Client Data, is governed by our Terms of Use.

 

California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to info@malartu.co or write us at: 310 S Harrington St, Raleigh, NC 27603.

 

Links to Other Websites

As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Policy applies solely to information collected by us through the Site and the Service. Therefore, this Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy Policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

 

Changes to Our Privacy Policy

We reserve the right to change this Policy and our Terms of Use at any time. We will notify you of significant changes to our Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our site. Significant changes will go into effect thirty (30) days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.

In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. 

 

Contact Us

If you have any questions regarding this Policy or the practices of this Site, please contact us by sending an email to info@malartu.co