Privacy Policy | Prisere

EFFECTIVE DATE: JULY 3, 2024

This Privacy Policy describes how Prisere LLC or its affiliates (“Prisere LLC”, “we”, “us”) collects and handles your information in connection with our websites including, without limitation http://www.Prisere.com and any downloadable mobile applications (collectively, the “Platform”). On the Platform, Prisere LLC provides services, including the climate scoring of investment portfolios and the third-party investment advisor programs (“Services”).

This policy has been provided to you to describe the information we may gather and the situations under which we may need to share it. If you have any questions about this Privacy Policy, please email us at support@Prisere.com.

How to Understand this Privacy Policy

The information that we collect and how it is used depends on your relationship with us and your engagement with the Platform. This Privacy Policy is organized based on the following relationships you have with our Platform:

“Visitors” means individuals who use and visit our Platform.
“Users” means individuals who establish an account with us and use our Services.
“Advisers” means individuals who are third-party investment advisers recommended by our Services.

You may fall into more than one relationship category at once, depending on your use of the Platform and/or Services. If you fall under more than one relationship category, the policies for each relationship apply concurrently to your use of the Platform and/or Services.

How We Collect Information

Visitors

When you visit our Platform, we consider you a Visitor. This section describes our privacy practices for Visitors.

What do we collect?	Information from Cookies and Web Beacons
What does this include?	We may use cookies, locally-stored objects and web beacons to automatically collect information about your use of the Platform. This collected information may include: information about your transactions and interactions with Prisere LLC and the Platform.
Can you limit collection?	You can set your browser to reject or disable cookies or to notify you when you are sent a cookie. However, if you reject or disable cookies, you may not be able to use all portions or all functionality of the Platform and Services. Most modern browsers allow you to delete or limit cookies.
How is this information used?	Unless indicated herein, we do not disclose information obtained in the course of our practice except as required or permitted under law solely to provide our services and to conduct customary business operations. Information collected from Cookies and Web Beacons is used to improve Prisere LLC’s Platform and/or provision of Services. In addition to the above, when requested, we provide information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas.

Users

When you register for or log into an account on our Platform, we consider you a User. This section describes our privacy practices for Users.

What do we collect?	Information from Third Parties
What does this include?	We may collect information from third parties, including information from a consumer-reporting agency and information about you, the User. Examples of these information sources include credit reports or background checks from vendors that you authorize us to receive information from (such as Equifax or Experian), and information obtained through third party services that provide a mechanism to share information you have provided to the applicable third party through the use of an application program interface (API), such as the Twitter, Linkedin, or Instagram API. This collected information may include: information about your transactions with nonaffiliated third parties and other information about you.
Can you limit collection?	No. If you are unwilling to provide your information, then Prisere LLC is unable to provide you with the Services.
How is this information used?	Unless indicated herein, we do not disclose information obtained in the course of our practice except as required or permitted under law solely to provide our services and to conduct customary business operations. Information collected from Third Parties is used to create insights and improve Prisere LLC’s Platform and/or provision of Services. In addition to the above, when requested, we provide information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas.

What do we collect?	Information Provided by User
What does this include?	We gather information directly from you when you provide us with the information when signing up for the Services. You will be asked to fill out this information prior to utilizing Prisere LLC’s Services. This collected information may include: your name, contact information, age, marital status, number of dependents, occupation, employer, education, investment experience, annual income, net worth, liquid net worth, description of existing assets, investment objectives, risk tolerance, and investment restrictions.
Can you limit collection?	No. If you are unwilling to provide your information, then Prisere LLC is unable to provide you with the Services.
How is this information used?	Information collected directly from the User is used to provide services to our clients and for our general business purposes. We limit the collection and use of this information within our firm to only those individuals associated or employed with us that must have information to provide services to you. Such services are limited to climate scoring of investment portfolio and referring you to other third-party investment advisers who have agreed in writing to participate in our third-party investment adviser program. By signing up to use the Services and agreeing to this Privacy Policy, you are opting-in to our sharing of your information with third-party investment advisers. We provide information to our third-party service providers that assist us with business, operational and compliance support only when necessary. In such situations, we stress the confidential nature of information being shared. If you are unwilling to have your personal and/or financial information provided to the third-party investment advisers in our program, then Prisere LLC is unable to assist you with a recommendation of a third-party investment adviser. In addition to the above, when requested, we provide information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas.

Advisers

When you agree to act as a third-party investment adviser for Prisere LLC’s Services, we consider you an Adviser. This section describes our privacy practices for Advisers.

What do we collect?	Information from Third Parties
What does this include?	We may collect information from third parties, including information from a consumer-reporting agency and information about you. Examples of these information sources include credit reports or background checks from vendors that you authorize us to receive information from (such as Equifax or Experian), and information obtained through third party services that provide a mechanism to share information you have provided to the applicable third party through the use of an application program interface (API), such as the Twitter, Linkedin, or Instagram AP. This collected information may include: information about your transactions with nonaffiliated third parties, and other information about you, the consumer.
Can you limit collection?	No, if you are an Adviser, we will collect this information.
How is this information used?	Unless otherwise indicated herein, we do not disclose information obtained in the course of our practice except as required or permitted under law solely to provide our services and to conduct customary business operations. Information collected from Third Parties is used to create insights and improve Prisere LLC’s Platform and/or provision of Services. However, when requested, we provide information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas.

How we Protect Your Information

Our employees and affiliated persons are required to protect the confidentiality of information and to comply with our stated policies and procedures, instituted to ensure the confidentiality of the information. They will access information only when there is an acceptable reason to do so. Employees who violate our Privacy Policy are subject to disciplinary action, up to and including termination from employment with us. We also maintain physical, electronic and procedural safeguards to protect information, which comply with applicable state and federal laws and rules thereunder.

The collection and use of your information by third parties is subject to each third party’s specific privacy policy and terms of use. Prisere LLC has no control over the means by which third parties further use or disclose your information.

Additional Privacy Information

Former Customers

Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you, and we will continue to treat your information with strict confidentiality.

Retention of Information

We retain your information for as long as it is relevant for our operations, to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce the Terms of Use, or take other actions permitted by law. The information we retain about you will be handled in accordance with this Privacy Policy.

Future Changes

We reserve the right to make changes to this Privacy Policy at any time. We will notify you about material changes in the way we treat your information, including by placing a prominent notice on the Platform or by sending you an email so that you can choose whether to continue using the Prisere LLC Platform or Services. Material modifications are effective 30 calendar days after our initial notification or upon your acceptance of the modified Terms.

Please revisit this page periodically to stay aware of any changes to this Privacy Policy. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose.

Accessing, Changing and Managing Your Information (for Non-California Residents)

You may change and update the information you provide through the Platform, or change your preferences concerning how we use your information, as follows:

You may make changes to the user information you have provided in connection with your Prisere LLC account by logging in to your account and changing the applicable information or by contacting us at support@Prisere.com. Following receipt of a request from you, we will take reasonable steps to update or correct your information.

You can make changes regarding receiving email communications from us within your Prisere LLC account. You can also choose not to receive email communications from us by following the “unsubscribe” instructions in any email communication you receive from us.

Jurisdictional Issues

The Platform and Services are operated from the United States. Prisere LLC may transfer, process or store your information with trusted affiliates, subsidiaries or contractors outside the U.S. in order to provide you with responsive, secure and accurate services. Your agreement to the terms of this Privacy Policy or your submission of information in connection with the Platform and Services represents your agreement to this practice. If you do not want your information transferred to or processed or stored accordingly, you should not use the Platform or Services. If you elect to use the Platform or Services outside of the United States, please be advised that you are doing so at your own risk and that you will be transferring information outside of your respective region to the U.S. for storage and processing.

Third Parties

The Service may contain links to websites that are not owned or operated by Prisere LLC. Please be aware that we are not responsible for the privacy practices of these websites. If you visit these websites or provide any information directly to parties other than Prisere LLC (even if those websites display the Prisere LLC brand), different policies may apply to the collection and use of your information. We encourage you to investigate and ask questions before accessing third-party websites or disclosing information to third parties.

No Use by Children

The Platform and Services are not intended for use by children under the age of 18. We will never knowingly collect information directly from children under the age of 18. If you are under the age of 18, you may not use the Platform or Services and please do not provide us with information of any kind whatsoever. If we become aware that a user is under the age of 18 and has submitted information to the Platform or Services, we will remove his or her information from our files and deactivate his or her account. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received personal information from a child under the age of 18, please contact us immediately at support@Prisere.com.

US State Residents Privacy Policies

California Residents

For a full description of your rights as a California resident under the California Consumer Privacy Act (“CCPA”), please see our California Privacy Policy in Appendix A.

Nevada Residents

For a full description of your rights as a Nevada resident under the Nevada Security and Privacy of Personal Information law, please see our Nevada Privacy Policy in Appendix B.

Virginia Residents

For a full description of your rights as a Virginia resident under the Virginia Consumer Data Protection Act (“VCDPA”), please see our Virginia Privacy Policy in Appendix C.

Appendix A

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” (as defined by the CCPA, California Civil Code § 1798.140(v)) that is subject to the CCPA.

Eligible Requests.

We take reasonable steps to help ensure that the Personal Information we collect from you is accurate, complete and current. In addition to accessing your Personal Information through the app or website, you may also request access to your Personal Information, request that erroneous or inaccurate Personal Information be updated, or (in certain circumstances) request deletion of your Personal Information, by contacting us via email at support@Prisere LLC.com or by writing us at the mailing address listed below. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

In the event that you request deletion of your data, we will retain the deletion request and may retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our service or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties (excluding processors) as described in this Privacy Policy, retention of that information may be subject to those third parties’ policies.

In some instances, but still in accordance with this Privacy Policy, we may share some personal information with third parties for direct marketing or other purposes, as described above herein. You can opt-out of this type of data-sharing by sending us an email at support@Prisere LLC.com or writing us at the mailing address listed below.

Procedures for Request.

We will respond promptly to your requests in accordance with applicable law and will try to respond to all legitimate requests within forty-five (45) days. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated of the status of your request(s). For your protection, we may only implement requests with respect to the personal information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We may decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain personal information for a longer period for recordkeeping purposes, such as retaining records relating to your purchases for warranty or accounting purposes.

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Platform because such information may be required in order for you to register as a user or use products or services.

You have the right to be free from discrimination for exercising your rights under the California Consumer Privacy Act. Prisere LLC does not discriminate against California residents for exercising their rights under the CCPA by:

Denying you goods or services
Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
Providing you a different level or quality of goods or services
Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services

Submitting Verifiable Consumer Requests.

When exercising the data rights described above, we will request that you submit a “verifiable consumer request.” The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

To verify a consumer request, consumers will be asked to provide their:

Name;

Phone Number;

Email Address;

Mailing Address; and

Matching pieces of personal information maintained by the Company in a signed declaration.

In response to the requests, consumers will be asked to confirm more than one data point of personal information maintained by the Company to verify their identity. We cannot provide personal information to consumers if we cannot verify your identity or authorization to make the request.

Authorized Agents.

You may be permitted by applicable law to designate an authorized agent to exercise certain rights on your behalf. With the exception of authorized agents with power of attorney pursuant to Probate Code sections 4000 to 4465, consumers will be required to verify their own identity directly with the Company and provide written permission for an agent to act on their behalf.

Legal Exceptions Under the CCPA.

The CCPA includes certain exceptions, which if they apply, exempt your personal information from the CCPA. This is not an exhaustive list, but the following types of data are exempt from the CCPA and may apply to personal information we have about you: (i) personal information or PHI covered by HIPAA; or (ii) personal information covered by the Gramm-Leach-Bliley Act. If you make a CCPA Request that is subject to an exception, we will notify you of the basis for the exception in response to your request.

Requests Regarding Direct Marketing Partners.

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing us at support@Prisere LLC.com or writing us at Prisere LLC Inc, 365 W 125 St. #68, New York, NY 10027, attention: Privacy Policy.

Appendix B

This section contains notices required under Chapter 603A of the Nevada Revised Statutes and only applies to “Covered Information” as defined in NRS 603A.320.

Under NRS 603A.340, Prisere LLC makes available through this notice above herein: the categories of information that Prisere LLC collects through its Platform and the third parties with whom Prisere LLC may share such information; how the consumer who visits the Platform can review or request to change their information collected; and how changes to the policy are made and noticed.

Under NRS 603A.345-346, Prisere LLC provides the following: A consumer may at any time submit a verified request to direct Prisere LLC not to make any sale of any covered information collected or purchased about the consumer.

When exercising this data right, we will request that you submit a “verifiable consumer request.” The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

To verify a consumer request, consumers will be asked to provide their:

Name;

Phone Number;

Email Address;

Mailing Address; and

Matching pieces of personal information maintained by Prisere LLC in a signed declaration.

In response to the requests, consumers will be asked to confirm more than one data point of personal information maintained by Prisere LLC to verify the consumer’s identity. We cannot provide personal information to consumers if we cannot verify your identity or authorization to make the request.

Appendix C

This section contains information required under Chapter 53 of the Code of Virginia and only applies to data defined in Code of Virginia § 59.1-575.

Under the Code of Virginia § 59.1-577(A), you may invoke your consumer rights at any time by submitting a request to Prisere LLC specifying the consumer rights you wish to invoke.

The consumer rights you are authorized to invoke under the Code of Virginia § 59.1-577 include the right:

To confirm whether or not Prisere LLC is processing your personal data and to access such personal data;
To correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data;
To delete personal data provided by or obtained about you;
To obtain a copy of your personal data that you previously provided to Prisere LLC in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and
To opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

To verify a consumer request, consumers will be asked to provide their:

Name;

Phone Number;

Email Address;

Mailing Address; and

Matching pieces of personal information maintained by Prisere LLC in a signed declaration.

Pursuant to Code of Virginia § 59.1-577(B), we will comply with your request by responding within 45 days of receipt of the request. We will respond promptly to your requests in accordance with applicable law and will try to respond to all legitimate requests within forty-five (45) days. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated of the status of your request(s). If we require 45 additional days, we will inform you of the extension within the initial 45-day response period.

You have the right to make requests under the Virginia law, free of charge, twice annually. If your requests are manifestly unfounded, excessive, or repetitive, Prisere LLC may decline the request or charge you, as permitted under law, a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.

If we decline to take action regarding your request, we will inform you without undue delay, within 45 days of the request, including a justification for declining the request. For your protection, we may only implement requests with respect to the personal information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We may decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may deny your requests based on our need to retain certain personal information for a period for recordkeeping purposes, such as retaining records for accounting purposes.

You have the right to appeal our decision not to complete your request, within a reasonable period of time after your receipt of the decision. The appeals process requires that you submit a “verifiable consumer request,” as outlined above. Within 60 days of receipt of an appeal, Prisere LLC shall inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, Prisere LLC will provide you with information through which you may contact the Attorney General to submit a complaint.

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