Privacy Policy
This policy covers aretetec.com and the Armstrong investor portal at armstrong.aretetec.com, operated by Arete Technologies Management, LLC (“Arete”, “we”). It says what we collect, why, and who processes it for us.
What we collect
- Browsing aretetec.com. We do not ask for anything and set no cookies. Our hosting provider receives the standard details of each request (such as IP address and browser type) to serve and protect the site. Pages load fonts from a third-party font service, which also receives your IP address.
- Register interest (invest.aretetec.com). Your name, email, organization, country of residence, an indicative and non-binding ticket range, your note, which share classes and updates you want to hear about, your answers on accredited status, investor type and timing, and how you heard about us.
- Google sign-in on the investor portal. The name, email address and profile image that Google shares when you sign in. Your session is kept in your browser (local storage and a session cookie).
- Accredited investor attestation. Your name, whether you invest as an individual or an entity (and the entity name), the accreditation criteria you select and your certification, with the time, your IP address, approximate country and browser type.
- Access records. When you open performance data or protected documents on the portal we record your email, the time, your IP address, approximate location (country and city, from our hosting provider), browser type and referring page.
Why we use it
To respond to you, to decide whether we may share fund information with you (including confirming accredited investor status, which Rule 506(c) of Regulation D requires), to keep the portal secure, and to meet legal and record-keeping obligations. We do not sell personal information, and we do not use advertising or analytics trackers.
Who processes it
We use service providers for website hosting, secure sign-in and data storage. They process personal information only on our instructions, under contracts that limit its use to providing their services to us. We may also disclose information when the law requires it, or to our legal, tax and fund-administration advisers. On request, we will tell you which providers hold your information.
Your choices
You can ask us to show, correct or delete what we hold about you by contacting us. Some records, such as investor attestations, we may be required to keep. We keep information only as long as we need it for the purposes above.
Contact
This policy is under review by counsel.