PRIVACY POLICY

GENERAL INFORMATION

Slatt Capital (“Slatt”) has created this Privacy Notice to apply to all users and clients of this website, and all mobile applications and digital assets offered by us (collectively, our “Services”).

This Privacy Notice describes the types of information we collect, how we use it, and your rights concerning your Personal Information (defined below).

This Privacy Notice is for use and for persons in the United States only.

CONSENT

This Privacy Notice is integrated into our Terms & Conditions of Use (“Terms & Conditions”)  By using our Services and providing us with Personal Information, you agree to the practices described in this Privacy Notice and to the updates posted here from time to time. If you withdraw consent, you agree that despite withdrawal, Slatt may continue to use your Personal Information previously provided to use to the extent that we are legally or contractually obligated to do so and to the extent necessary to enforce any contractual obligations you may have to us. You also understand that by withdrawing your consent, we may no longer be able to provide you with Services previously available with consent.

If you consented to receiving email communications from Slatt, you will continue to do so unless you unsubscribe. You may choose to opt out or unsubscribe from receiving future marketing email messages from us. Each marketing email sent from us contains a link with instructions on how to remove yourself from our email list.

PERSONAL INFORMATION

In this Privacy Notice, when we use the term “Personal Information,” and except where a different definition is noted, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to you, directly or indirectly, as defined under applicable laws and regulations. Personal Information does not include information that is not covered by applicable privacy laws, including that which cannot be reasonably linked to you (e.g., de-identified or aggregated data) or publicly available information.

PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect the following types of information about you which are described in more detail below:

• Personal Information you provide to us, which may include your name, address, telephone, facsimile, email address, Social Security number, tax identification number, and investment objective;
• Personal Information we may automatically collect; and
• Personal Information we may receive from third parties.

All the information listed above is detailed below and referred to as “Personal Information.”

• Personal Information You Provide to Us:

In using our Services, you may provide us with Personal Information, including, without limitation, the list below. You may provide us with this Personal Information when you upload materials for us to perform tax, audit, assessment, or other Services, pay your bill online, submit materials related to a request for a quote, complete forms online, or submit or provide other documentation and information to us.

• Identifiers

• • First and last name, email address, name, home, or work address, and/or telephone number

• Government Issued Documents

• • Driver’s license or passport information

• Background Information

• • Occupation

• • Nationality

• • Hobbies or other background information

• Other Persons’ Information

• • Emergency contact information or relatives or other person’s Personal Information

• Financial Information

• • Tax records, payment information, financial information, such as account balances, income information, assets, credit score, credit history and transaction history, bank information, payment card numbers, expiration dates, security codes, and other financial and tax documents and supporting documentation

• Credentials/Account Log-In Information

• • Account username and log in credentials, including unique identifiers such as username and password

• Comments and Opinions

• • Survey or content submissions

• • Reasons why you have selected or heard about our Services

• • When you contact us directly, by email, phone, mail, text, chat, when you post on message boards, blogs or complete an online form, we may record your comments and opinions

• Marketing and Event Information

• • Participation and registration in events and seminars, opt-in marketing selection, and document or resource download references

• Commercial Information

• • Products and Services purchased, transaction information and other data obtained or considered or other purchasing or consuming histories or tendencies

• Sensitive Information

• • Such as age, gender, country, language preferences, religious or political views or membership, criminal history

• Job Applicant and Employee Information

• • Resume, occupation, work samples, benefits, competition requirements, educational history, certifications, protected classifications (e.g., age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, and veteran or military status) , or other information provided in applications for employment

• • This may also include information about your employing entity, business unit, manager and management reporting structure, job title, function and the nature of your duties and responsibilities, and non-publicly available education information

• Communications

• • Preferences for communications and Services, chats, posts, or interactions and communications with us or our third-party providers

• Preferences

• • Information derived from other Personal Information about you, which could include your preferences, interests, and other information used to personalize your experience

• • Preferences set for notifications, marketing communications and how our website is displayed

• Consent

• • Additional information as otherwise described to you at the point of collection or pursuant to your consent

• Other

• • Any other information you choose to directly provide to us in connection with your use of the Services

You are responsible for ensuring the accuracy of the Personal Information you submit to us. Submitting inaccurate Personal Information or failing to maintain the accuracy of Personal Information that changes (for example, a change of email address) may disrupt your ability to use our Services, may affect the information you receive from us, and may impact our ability to contact you. You can update your Personal Information at any time by logging into and visiting your user account page or Contact Us.

• Personal Information We May Automatically Collect About You:

Our Services may automatically collect certain Personal Information. We may collect Personal Information automatically through your use of our Services, including the website, such as through the use of cookies, or through security monitoring and recording at our offices and facilities, on phone calls, and through third parties.  We use this information to help us design our Services to better suit our users’ needs and for other business purposes as described in this Privacy Notice.

This Personal Information may include:

• System and Device Information
  • We collect information about the computer, tablet, smartphone, or other electronic device you use to connect to our Services.
  • Every computer on the Internet has a unique address called an Internet Protocol (“IP” Address). An IP Address is just like a telephone number in that it is a long string of numbers. IP Addresses are automatically assigned to all Internet Users by their Internet Service Providers (“ISP”). However, since it would be difficult to remember everyone’s IP Address, the Internet allows you to type in an easy to remember name, i.e., a domain name or e-mail address which corresponds to the IP Address. When you use the Internet, your IP Address, as well as other information is automatically logged by web servers.
  • Along with your IP Address, we collect browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers.
  • Internet or other electronic network activity information, including browser and app logs, content you view or engage with, and app, browser, and device information.
  • Domain server from which you are using our Services.
  • Type of computer, web browsers, software, search engine used, operating system, or platform you use.
  • Mobile device information, including the type of device you use, operating system version, your device’s telephone number (if it has one), the device identifier (or “UDID”). This also includes behavior, use, and aggregated usage, performance data, and from where the application was downloaded.
  • Location information related to the IP address of devices used to access the Services, type of browser software, operating system, or mobile device in use, associated region or location data, Internet domain and service provider used, and referring/exit pages from which you linked to our Services.
• Date and Time
  • Date and time of your visit or use of our Services.
• Activity
  • Data identifying the website pages you visited prior to and after visiting our website or use of our Services.
  • Your movement and activity within the website, which is aggregated with other information.
  • For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Services, the time you access the Services and how long you use them, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, interaction with email content, access times, error logs, and other similar information, and other actions you take on the Services. Information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services.
• Location Related Information
  • Location Data generally, or with your consent, your precise GPS location.
• Social Media
  • Information provided by social networks connected to the Service, in accordance with your privacy settings on the social media platform. The connected social network may provide us with information such as your name, ID, profile picture, network, gender, username, user ID, email address, friend list, age or age range, language, country, friends list, follower list, photos, location, generated contact, and any other information you have agreed it can share or that the social network provides to us. It also includes information you provide to us directly through our Services on social media networking and blogging platforms (e.g., Facebook, Instagram, YouTube, and Twitter).

Inferences drawn from any of the information identified above reflecting your preferences and characteristics.

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Cookies & Technologies Used to Collect Information About You

We collect the above Personal Information directly and through the use of third parties. We collect this Personal Information by using certain technologies, such as cookies, web beacons, and other technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons. The use of these technologies by such third parties is subject to their own privacy notices and is not covered by this Privacy Notice, except as required by law.

Cookies (or browser cookies)

Cookies and similar technologies are small files of letters and numbers that we store on your web browser or the hard drive of your computer or mobile device. Cookies contain information that is transferred to the hard drive of your computer or mobile device and enable the website’s or service provider’s systems to recognize the user’s browser and capture and remember certain information.

Cookies may be sent to your browser’s temporary memory system to assist you in navigating during a particular session only, or a cookie can be sent to your hard drive to serve you better when you return to the website (for example to recognize you when you return to the website, to save your password and to offer you customized content).

There are three types of cookies that we may use:

1. Strictly Necessary: These cookies are essential to enable you to browse our Site and use its features. The information collected by these cookies relate to the operation of our Site (e.g., website scripting language and security tokens to maintain secure areas of our Site).
2. Performance/Analytics: These cookies collect anonymous information about how you use our Site (e.g., which pages you visit most often, whether you receive any error messages, and how you arrived at our Site). Information collected by these cookies is used only to improve your use of our Site and never to identify you.
3. Functionality: These cookies remember choices you make (e.g., the country you visit our Services from, your language and any changes you have made to text size or other parts of web pages that you can customize), to improve your experience of our Services and to make your visits and use more tailored and enjoyable. The information these cookies collect may be anonymized and cannot be used to track your browsing activity on other websites.

Most Internet browsers are automatically set up to accept cookies. However, if you want to refuse or delete any cookies (or similar technologies), please refer to the help and support area on your Internet browser for instructions on how to block or delete cookies. Please note you may not be able to take advantage of all the features of our Site, including any personalized features, if you delete or disable cookies.

You can set your browser to notify you when you receive a “cookie” giving you the opportunity to accept or refuse it. See “Help” in your browser. Deleting or not accepting cookies will not prevent you from accessing this website or participating on the website. However, if you do not employ the technology your navigation may be less convenient or personalized given the purposes for cookies.

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 our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.

Some website browsers have incorporated “Do Not Track” features that send an automated signal to the websites that you visit using that browser. Currently, the Services do not recognize or respond to these signals. However, you can adjust your preferences regarding the data we collect using the tools and methods described above.

For more information on managing cookies, please go to www.allaboutcookies.org or http://www.aboutads.info which have further information about behavioral advertising and online privacy.

Flash Cookies

We may use local shared objects, also known as Flash cookies, to store your preferences such as volume control or display content based upon what you view on our site to personalize your visit. Third parties, with whom we partner to provide certain features or to display advertising based upon your browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount and type of data stored and the method of storing this data. Cookie management tools provided by your browser will not remove Flash cookies.

For Flash cookies, you can access Flash management tools from Adobe’s website. In addition, some, but not all, browsers provide the ability to remove local shared objects within cookie and privacy settings.

Web Beacons

Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of information either directly to us or to a third party authorized by us to collect information on our behalf. Our Services may use retargeting pixels from Google, Facebook, and other ad networks. We may also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

Analytics

Analytics are tools we use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. Learn more about Google’s Privacy Notice here: https://policies.google.com/privacy?hl=en-US. You can opt out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout.

Mobile Application Technologies

If you access our website and Services through a mobile device, we may automatically collect information about your device, your phone number, and your physical location.

By using our Services, you agree that we may contact you by calling or sending messages to your phone, including messages sent to your personal telephone device, i.e., “Mobile Push Notifications.” You can use the settings on your mobile device to enable or turn off mobile push notifications from us or Contact Us directly at info@slatt.com.

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3. Personal Information We May Receive from Third Parties

We may collect additional Personal Information about you from our affiliates, partners or vendors, third-party websites, social media platforms, such as, but not limited, to Facebook, Twitter, Instagram, LinkedIn (“Social Media Platforms”), and/or sources providing publicly-available information (e.g., from the U.S. Postal Service) to help us provide the Services to you, confirm, enhance, or supplement our existing information about you (e.g., with your consent, background checks for credit and criminal history), help prevent fraud, maintain security, and for marketing, advertising and other business purposes.

Personal Information we may access about you, with your consent, may include, but is not limited to, your basic social media platform information, your location data, your list of contacts, friends or followers and certain information about your activities on the social Media Platform. This information is used by Slatt for the operation of our Services, to maintain quality of the service, and to provide general statistics regarding the use of Slatt Services. Please keep in mind that when you provide Personal Information through Slatt public message boards or on a third-party website or platform (for example, via our applications), the information you provide may be separately collected by the third-party website or the social media platform. Note: Slatt does not read any of your private online communications.

We may also collect Personal Information to perform our Services, including tax records, public filings, and other information available from third-party websites.

The Personal Information we collect is covered by this Privacy Notice, and the information the third-party website or social media platform collects is subject to the third-party website or platform’s privacy practices. We encourage you to review the privacy statements of websites you choose to link to from Slatt so that you can understand how those websites collect, use, and share your Personal Information. Slatt is not responsible for the privacy statements or other content on websites outside of Slatt. You are responsible for reading those privacy statements on third party websites.

HOW WE USE YOUR PERSONAL INFORMATION

We use and process your Personal Information for purposes that may include, but are not limited to, the following:

• Operate the Slatt website and deliver the Services you have requested
• Inform you of other products or services available from Slatt
• Provide related products, promotions, newsletters, and information you request
• Contact you via surveys to conduct research about your opinion of current Services or of potential new services that may be offered
• Provide you with financial services or related information
• Respond to your inquiries and provide you with requested information and other communications, including by email, text, or chats, including customer support services
• Personalize or customize your experience
• Allow you to participate in interactive features when you choose to do so
• Deliver location-based Services and comply with the territorial requirements and restrictions
• Fulfill contracts we have with you
• Maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and Services
• Comply with our Terms & Conditions
• Assess your application for employment
• Perform analytics for business purposes and business intelligence, including how Services are used so we can improve and expand upon them
• Comply with any applicable laws and regulations and respond to lawful requests
• Operate our business
• For any other purposes disclosed to you at the time we collect your information and/or pursuant to your consent 

SHARING OF YOUR PERSONAL INFORMATION

Slatt does not sell or share your Personal Information to third parties for monetary or other valuable consideration as defined under the California Consumer Privacy Act.  However, Slatt may share your Personal Information as set forth in this Privacy Notice and in the following circumstances:

• Third-Party Service Providers. We may share your Personal Information with third-party service providers (such as Lender or other Capital Providers) or data processors that perform certain functions or services on our behalf (such as to host the Services, store or manage the data, perform analyses, provide customer service, or send communications for us). These third-party service providers will process this data only for purposes specified by us and will be bound by contract to meeting our obligations under applicable law. Third-party service providers may include: Lenders, Capital Providers, sources of equity, and title companies.
• Third-party vendors that operate software platforms that enable us to provide our Services or inform you of our goods and products, such as Salesforce, Microsoft, Active Campaign, Campaign Monitor, or social media platforms.
• Disclosure of Personal Information for Legal and Administrative Reasons.We may disclose your Personal Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Personal Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.
• Safety and Security.We may share your Personal Information to protect the safety and security of our users and customers, to prevent fraud, abuse, or unauthorized activities, to protect the rights of property of us, third parties, you, or others, including enforcing the terms of our agreements.
• Business Purposes. To fulfill our everyday business purposes.
• With Your Consent. We may share Personal Information consistent with this Privacy Notice with your consent.

• Lawful Purpose. For other purposes permitted by law.

LINKS TO THIRD-PARTY WEBSITES

Slatt may occasionally provide links to sites operated by outside parties (“third-party websites”) that we believe may be of interest to you. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. We do not disclose your Personal Information to these third-party websites without obtaining your consent. In addition, from our Services you may be able to interact with social media platforms, for example, by “liking” us on Facebook. If you choose to click on a link to one of these third-party websites or choose to interact with or through a social media platform, your activities are not governed by this Privacy Notice and will be governed by the Privacy Notice on that third-party website or social media platform. This Privacy Notice only applies to Personal Information collected by us. Please review their privacy notices and terms of service before disclosing any Personal Information to determine their respective privacy practices. Slatt does not review, does not endorse, and is not responsible for the privacy practices of these third-party websites and social media platforms.

• We may also maintain a page on Facebook or other social media platforms. Those pages and your interaction with them are governed by the privacy notices of Facebook or other relevant social media platform, and not our Privacy Notice. As with other third-party websites, we do not endorse and are not responsible for the privacy practices of these forums, although we may have a presence on them.
• We are not responsible for the privacy and security practices of those other websites or social media platforms or the information they may collect (which may include IP address). You should refer to such third parties’ privacy notices on their sites to determine their respective privacy practices.

SECURITY OF YOUR PERSONAL INFORMATION

Slatt employs commercially reasonable measures as it relates to physical, electronic, and procedural safeguards to help protect your Personal Information. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, nor should you expect, that your information or private communications will always remain private or secure. We do not guarantee that your Personal Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Personal Information.

It is your responsibility to maintain the confidentiality of your log-in credentials and unique identifiers used to access the Services. You are also responsible for ensuring the accuracy of the Personal Information you submit to Slatt. Submitting inaccurate Personal Information or failing to maintain the accuracy of Personal Information that changes (for example, a change of email address) may disrupt your ability to use our Services, may affect the Services you receive from us, and may impact our ability to contact you. You can update your Personal Information at any time by logging into and visiting your user account page.

If you believe that your Personal Information has been accessed or acquired by an unauthorized person, promptly Contact Us at info@slatt.com so that necessary measures can quickly be taken.

CHILDREN’S PERSONAL INFORMATION

Slatt’s services are only intended for individuals over the age of eighteen (18).  If you believe that we have mistakenly or unintentionally collected Personal Information from a child under the age of eighteen (18), please Contact Us immediately at info@slatt.com.

DATA RETENTION AND DISPOSAL

Slatt will retain your Personal Information for as long as needed to provide you with our Services. Slatt will also retain and use your Personal Information as necessary to comply with our legal obligations, including any applicable rules on statute of limitations, any relevant litigation, or regulatory investigations, to enable us to defend or bring potential legal claims, resolve disputes, enforce our agreements, and in accordance with our routine recordkeeping that considers the duration of your use of our Services.  We are under no obligation to store Personal Information indefinitely.  We disclaim any liability arising out of, or related to, the disposal of your Personal Information.

DATA STORAGE AND TRANSFERS

We operate in the United States. Your Personal Information may be transferred to and processed in any country where we have offices or in which we engage service providers or licensed independent contractors. These countries may be outside the United States and may have different data protection laws than in the United States.

Thus, we transfer your Personal Information to third parties as stated in this Privacy Notice, and some of these parties may be located in countries other than your own, whose privacy and data protection laws may not be equivalent to those in your country of residence.

When we transfer your Personal Information to other countries, we apply appropriate safeguards to protect your Personal Information and comply with applicable laws.  If you have questions about how we transfer your Personal Information, please Contact Us.

CONTACT US

For general inquiries, please contact us at info@slatt.com. For consumers who would like to limit information sharing with our affiliates and subsidiaries (but not from the sharing of information necessary for us to follow the law, as permitted by law, or to give you the necessary service on your accounts with us), please contact us using the information below.

Email: info@slatt.com
Address: 819 Mitten Rd
Burlingame, CA 94010
Office: 650.342.6755
Fax: 650.342.3964

If you feel that you are in a jurisdiction or reside in a place that affords you rights not addressed by this Privacy Notice, please contact us.

CHANGES TO THIS NOTICE

We reserve the right to update, modify, or amend this Privacy Notice to reflect company and customer feedback, changes in our services, accommodate new technologies or regulatory requirements, or for other purposes. If we modify our Privacy Notice, we will update the “Effective Date” below, and such changes will be effective upon posting. Slatt Capital encourages you to periodically review this Notice to stay informed and be aware of any changes.

Last updated:  March 19, 2024