Last Updated: September 2023
We may collect and maintain personal information in a number of ways, including when you visit our office and when you contact us by email or telephone.
• Identifiers. We collect contact information, such as name, email, address, phone number and title, if you or your representative provide us with this information in connection with prospective services or if they work with us as a service provider or vendor to our business. We also collect contact information from those who register for or attend our sponsored events. We use this information to communicate with such persons and conduct our business relationships.
• Commercial Information. We may collect information needed for our operations, such as bank account information to process invoices and payments, transaction history and signatures. We also collect personal information to diligence prospective investments or as otherwise appropriate to pursue our investment strategies.
• Professional and Education Information. We may collect information needed for our operations, such as background or educational information, references, emergency contact information, information to identify conflicts of interest and similar information as needed to comply with our policies and procedures.
• Other Electronic Network Activity Information. We maintain various security measures to protect our technology infrastructure and may monitor those who connect to our internet network or otherwise interact with our technology infrastructure, such as by collecting browsing history or information about the device connected to our network.
• Audio and Visual Information. We maintain various security measures to protect our premises, including video cameras, and to facilitate our operations we may also collect audio recordings from those who contact us.
• Physical Security Information. We maintain various physical, technical and administrative security measures to protect our premises and operations, which capture personal information. These may include badges to enter the building and access certain parts of the premises and sign‐in processes for guests.
If you have provided us with non-personally identifiable information, including anonymous information and aggregate data collected automatically through cookies, we may use such non-personally identifiable information to understand better how visitors use the Site and to improve the Site. You can manage or disable cookies at any time by adjusting your browser settings. Please refer to the settings menu of your browser for instructions on how to change your cookie preferences.
We also collect identifying information, sensitive personal information (such as social security, driver’s license and passport numbers and bank account information) and additional commercial information as needed to effect investment transactions and provide investment services, as described in our Privacy Notice provided to those who engage with us for investment services.
Much of the information referenced above will have been provided by you, but some may come from other sources, such as your representatives, your business contact at Universa, automated sources (as described above) or a mutual referral contact.
• To evaluate and effect investment transactions and contracts, manage the investment services we provide you and help maintain the administration, safety, security and integrity of our business and assets;
• To comply with any applicable compliance, legal and regulatory obligations, lawful requests and legal processes (such as to respond to subpoenas and requests during government investigations) as we believe appropriate, and to comply with the compliance obligations required by our service providers;
• To communicate with you about investments, our other services and products, and updates regarding our firm;
• To improve the services provided to you, as well as understand your interests and personalize your experiences with us;
• For marketing and promotional communications (as permitted by law and to the extent you do not opt out of receiving such promotional communications); and
• On occasion, we may ask for your consent to use your personal information for purpose(s) we explain at that time.
If you do not provide requested information in connection with our operations, we may be unable in some circumstances to comply with our obligations or pursue a relationship with you, and we will tell you about the implications of that decision.
• Service providers that act on our behalf and help us with our operations (for example, administrators or companies that assist us with hosting, database management services, processing transactions, generating financial reports, data processing, tax filings, technology services and maintaining books and records), provided, that these third parties may use your personal information only as authorized by their contracts with us;
• Our professional advisors, such as lawyers, bankers, accountants, brokers and insurers in the course of the professional services that they render to us;
• Another company, in the case of a proposed or actual merger, or acquisition or sale of all or part of our business;
• Any third party to which you direct us to disclose your personal information or which you consent to the disclosure of your personal information.
We do not sell personal information and we do not share personal information for cross-context behavioral advertising.
Our services are not directed to, and we do not knowingly collect or share personal information from anyone under the age of 16.
Our Site is not designed to respond to “do not track” signals received from browsers.
Our Site does not send any tracking technologies or cookies and, therefore, does not use Global Privacy Control.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means. We specify retention periods for our records, including your personal information, in our policies and procedures.
If you are a California resident, you may have certain rights if your personal information is protected by applicable California law, including the following rights (subject to certain exceptions and limitations):
• Right to Know. You have the right to request (a) the categories and specific pieces of personal information we collect and disclose; (b) the categories of sources from which we have collected your personal information; (c) the categories of third parties to whom your personal information was shared or disclosed for a business purpose; and (d) the business purposes for such collection and disclosure of your personal information.
• Right to Request. You have the right to request a list of the personal information (if any) disclosed to third parties for direct marketing purposes in the prior 12 months.
• Right to Delete. You have the right to access and then delete your personal information that we have collected from you or maintained about you (except to the extent we are required by law to retain any record).
• Right to Correct Inaccurate Information. If we maintain inaccurate information about you, you have the right to request correction of that inaccurate personal information, taking into account the nature of the personal information and the purposes of the personal information processing. We will use commercially reasonable efforts to correct this information.
• Right to Limit. We do not use or disclose sensitive personal information for purposes other than those permitted by CCPA regulations section 7027(m).
• Right to Opt-Out. You have the right to opt-out of the sale or sharing of personal information for cross-context behavioral advertising. However, we do not sell or share any personal information for cross-context behavioral advertising.
California residents also have the right to not be discriminated against for exercising any of the rights described above.
If you are a California resident and wish to exercise these rights, please contact us at 786-483-3140 or email at Contact@universa.net. There are circumstances where we are not required to comply with consumer requests and we will let you know if one of those situations is applicable.
We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please contact Compliance@universa.net.
To help protect your privacy and maintain security, we will verify your identity before granting access to your personal information or complying with your request. If you request to access or delete your personal information, we will verify your identity by comparing information we have on file against information you may provide us. If you designate an authorized agent to make a request to access or delete your personal information on your behalf, we may require you to (1) provide the authorized agent written permission to do so, and (2) verify your own identity directly with us (as described above).
We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.