General

Concentric Advisors, Inc. and its affiliates (hereinafter, “Concentric”, “we”, “us” or “our”) are committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms of Use) governs our collection, processing and use of your Personal Information. We define “Personal Information” as information which identifies you personally, e.g. your name, e-mail address, etc. The purpose of this Privacy Policy is to inform you of:

• the kinds of Personal Information which we may collect about you and how it may be used;
• our use of information regarding IP Addresses and our use of cookies;
• any disclosure of Personal Information to third parties;
• the transfer of Personal Information outside of the United States;
• your ability to correct, update and delete your Personal Information; and
• the security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control.

BY VISITING THIS SITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY

Gathering and Use of Personal Information

We may collect your Personal Information if you use the Site. The types of Personal Information which we collect may include:

• your name
• your phone number
• your e-mail address

We may use your Personal Information for the following purposes:

• if you contact us, to reply to your queries
• to analyze use of our Site
• as required for regulatory purposes
• to provide you with information about products and promotions that may be of interest to you, from ourselves and third parties
• for market research e.g. surveying our Site visitors’ needs and opinions on issues, such as our performance etc.

SMS Terms of Service for Recruiting

• When you opt into the service, we may send you SMS messages to notify you of any updates to your application status and to engage in discussion throughout your application process.
• You can cancel the SMS service at any time. Just text “STOP” to unsubscribe. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to opt-in again, just reply START to the phone number you unsubscribed to and we will start sending SMS messages to you again.
• If you are experiencing issues with the messaging program you can reply with the keyword “HELP” for more assistance, or you can get help directly at recruiting@concentric.io
• Please note that carriers are not liable for delayed or undelivered messages
• As always, message and data rates may apply for any messages sent to you from us and to us from you. Message frequency may vary. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

We will process your Personal Information only for the purpose(s) for which it has been provided to us.

IP Addresses

We may collect information about your computer, including where available your IP address, operating system and browser type and for system administration. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

Cookies

We use a browser feature known as a “cookie”, which assigns a unique identification to your device. Cookies are typically stored on your device’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends, and administer our platform. The information collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge, we can improve the quality of your experience on our platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Site. We use third party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s) will place cookies on the hard drive of your device and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using our platform. Our service provider(s) is/are contractually restricted from using information they receive from our Site other than to assist us.

Disclosure of Personal Information

We use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law. We may make available the Personal Information that you provide to us to our affiliates, agents, representatives, trusted service providers and contractors for these limited purposes. We may also share your Personal Information with financial institutions, insurance companies or other companies. We may also share your Personal Information with law enforcement or regulatory agencies, as may be required by law. Any third party which receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for Concentric, unless otherwise required or permitted by law. We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.

Correction/Updating/Deletion of Personal Information

You have the right to access your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us at: info@concentric.io. You may also request the deletion or destruction of both your account and Personal Information by sending an email to us at: info@concentric.io. Concentric will take action on your request only where it is not inconsistent with our legal and regulatory obligations. Upon your written request, we will inform you of the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. We will also give you a copy of the Personal Information we have retained.

Security

We have implemented security measures to protect the confidentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction. Only authorized personnel of Concentric have access to your Personal Information, and these personnel are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

Retention of Personal Information

We will hold your Personal Information only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements. In accordance with our record keeping obligations we will retain Accounts and Personal Information for, at least a period of five years after they are closed.

Links

There may be links from our Site to other sites and resources provided by third parties. This Privacy Policy applies only to our Site. Accessing those third-party sites or sources requires you to leave our Site. We do not control those third party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.

Changes

Our Site policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of Concentric. If we change this Privacy Policy, will take steps to notify all users by a notice on our Site and will post the amended Privacy Policy on the Site.

Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy and/or practices as it or they relate to our Site and platform, please contact us at the following e-mail address: info@concentric.io

Last updated: June 2023