Privacy Policy

Effective on April 4, 2024

Institutional LPs is committed to operating at the highest level of competency, integrity, respect and honesty. To that end, this policy provides detailed information about your data and privacy.

1. Introduction

1.1 Platform

Read this Privacy Policy ("Policy") carefully before using the Platform (described herein). This Policy applies to Institutional LPs platform ("Platform"), which includes Institutional LPs website located at www.institutionallps.com and all other Institutional LPs-related products, services, and features that state that they are offered under this Policy, including the offsite collection of data for the Platform.

When you visit, access, or otherwise use the Platform, you agree to this Privacy Policy (even if you are using the Platform on behalf of an organization). If you do not agree to this Policy, you are not authorized to visit, access, or otherwise use the Platform and you should not do so.

1.2 Members

You agree that by clicking "Continue", "Submit", or (when logged into the Platform) a button with an arrow on it, you are a Platform member ("Member") once we decide to grant you admission, even if you are using the Platform on behalf of an organization. If you do not agree to this Policy, do not click "Continue", "Submit", or (when logged into the Platform) a button with an arrow on it, and do not access, visit, or otherwise use the Platform.

1.3 Visitors

If you are not a Member, you agree that by visiting, accessing, or otherwise using the Platform, you are a Platform visitor ("Visitor"), even if you are using the Platform on behalf of an organization. If you do not agree to this Policy, do not access, visit, or otherwise use the Platform. If at any time in the future you become a Member, you immediately cease to be a Visitor.

1.4 Data Controller

You are agreeing to this Policy with Institutional LPs (also referred to as "we", "us", or "Institutional LPs"). Institutional LPs will be the controller of your data provided to, or collected by or for, or processed in connection with the Platform.

1.5 Changes

We may modify this Policy and the Cookie Policy periodically. If we make material changes, we will provide you notice through the Platform, or by other means, to provide you the opportunity to review the changes before they become effective. We agree that changes cannot be retroactive.

If you object to any changes, you may terminate your Platform access by requesting account closure via our online contact form here. Your continued use of the Platform after we publish or send a notice about these changes means that you are consenting to the updates and that the collection, use and sharing of your data is subject to the updated Privacy Policy.

2. Data That We Collect

2.1 Data That You Share with Institutional LPs

You provide us with data any time you share content or information with us. If you contact us via email or phone, you will share information with us. To contact us with questions, feedback, or inquiries, the Platform includes an online submission form here. To submit the form, you need to provide data as indicated on the contact form (eg. your name, organization, email address). If you make a purchase on the Platform, you will need to provide payment (eg. credit card) and billing information.

2.2 Service Use

We may log usage data when you visit, access, or otherwise use the Platform, such as when you view or click on content on the Platform. We may use logins, cookies, device information, and internet protocol ("IP") addresses to identify you and log your use of the Platform. If you are a Member, we may also use your email address to identify you and log your use.

2.3 Cookies, Web Beacons and Other Similar Technologies

We may use cookies and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on the Platform. We may also allow some third-parties to use cookies. You can control cookies through your browser settings and other tools. For more detailed information regarding cookies and similar technologies, please read the Cookie Policy.

2.4 Your Device and Location

We receive data from your devices and networks, including location data. When you visit, access, or otherwise use the Platform, we may get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or Internet Service Provider (ISP) or your mobile carrier. If you use the Platform from a mobile device, that device may send us data about your location based on your phone settings. We will ask you to opt-in before we use Global Positioning System (GPS) or other tools to identify your precise location.

2.5 Data Residency and Cross-Border Transfers

We may store and use your data outside of your country depending on several factors (eg. your location). Data on the Platform that is unrelated to communications (eg. data included in a request) resides in the U.S. when at rest (i.e. not being accessed). Data on the Platform that is unrelated to communications and not at rest (i.e. being accessed) may not reside within the U.S. as its data residency depends on the location of the person accessing it.

Data on the Platform that is related to communications will be stored on Institutional LPs servers that reside in the U.S. However, any information in the communication may also be stored on computer systems of the person(s) receiving the communication. Those computer systems are not controlled by us and may reside inside, or outside, of the U.S.

We rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process or store data may have laws which are different, and potentially not as protective, as the laws of your own country.

2.6 Other Information

The Platform is dynamic and we may introduce new features, which may require the collection of new information. If we collect materially different data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

2.7 Are Children Allowed to Use Institutional LPs?

No. Children are not permitted to visit, access, or otherwise use the Platform.

3. How We Use Your Data

3.1 Communications

We may contact you through email, phone, mail, and/or notices posted on the Platform. We may send you messages about the Platform availability, security, or other Platform-related issues. We may also contact you regarding how to use the Platform, network updates, scheduled maintenance, reminders, and promotional messages. You may opt-out of many of these communications at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

3.2 Marketing

We may promote the Platform to you and others. We may use data and content about Members for invitations and communications promoting Member growth, engagement, and the Platform.

3.3 Platform Development

We may use data, including the feedback of Members and Visitors, to conduct research and development for the further development of the Platform in order to provide you and others with a better, more intuitive and personalized experience, drive Member growth and engagement on the Platform, and better serve Members.

3.4 Support

We use data collected on the Platform to help Members and Visitors, and to fix problems on the Platform. We use the data (which can include your feedback and other communications) to investigate, respond to, and resolve complaints and Platform issues.

3.5 Security and Investigations

We use the data collected on the Platform (including your communications) for security, fraud prevention and investigations. We use the data if we think it’s necessary for security purposes or to investigate possible fraud or other violations of the Terms of Use, this Policy, the Cookie Policy, and/or attempts to harm Members or Visitors.

4. How We Share Information

4.1 Service Providers

We may use third-party service providers to help us provide the Platform (e.g. audit, legal, computer servers, website hosting, maintenance, analysis, payments, fraud detection, marketing and development). These service providers will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

In such cases, Institutional LPs remains controller of the data, the third-parties only process the data in accordance with our instructions and we are responsible for ensuring such third-parties are compliant with all applicable data protection regulations in relation to their processing activities.

For example, we may use computer servers (and computer software and other hardware infrastructure) from a third-party service provider to host the Platform and to store your data. The privacy policies of any such third-party computer servers will generally include EU-US Privacy Shield, General Data Protection Regulation (GDPR), Statement on Standards for Attestation Engagements No. 16 (SSAE-16), and Payment Card Industry Data Security Standards (PCI DSS) certifications and policies, as well as additional security measures. By using the Platform, you understand and agree that your data may be stored on servers of our third-party service providers.

4.2 Legal Disclosures

We may need to share your data when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary for any of these reasons:

•Investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies.
•Enforce the Terms of Use or any other of our agreements with you.
•Investigate and defend Institutional LPs and the Platform against any third-party claims or allegations.
•Protect the security or integrity of the Platform.
•Exercise or protect the rights and safety of Institutional LPs, our Members, our Visitors, personnel, or others.

We will attempt to notify you about legal demands for your data when appropriate in our judgment unless, i) prohibited by law or court order, ii) we do not have a direct means to contact you (eg. email, phone number), iii) the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overly broad, vague, or lack proper authority, but we do not promise to challenge every demand.

We reserve the right, at our sole discretion, to report to law enforcement agencies, government authorities, and/or government regulators any activities that we in good faith believe to be unlawful. This includes, but is not limited to, identifying the Member(s) and/or Visitor(s) involved in such activities.

4.3 Change in Control or Sale

We may share your data with third-parties as part of a sale, merger, or change in control, or in preparation for any of these events. Any other entity which buys us, or part of our business, will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4.4 Your References and/or Invitations

We may share information about you with any references that you provide to us. This may include, but is not limited to, your name, organization and email. We may also share information about you with anyone that you invite to the Platform by providing us with their contact information, such as their name and email. This may include, but is not limited to, your name, organization and email.

5. Your Choices and Obligations

5.1 Data Retention

We may keep most of your data for as long as you have access to the Platform. This includes data you or others provided to us and data generated or inferred from your use of the Platform. Even if you only use the Platform for communicating with others, we may retain your information and keep your data until you decide to terminate all of your access to the Platform. In some cases, we may choose to retain certain information in a depersonalized or aggregated form after termination.

5.2 Rights to Access and Control Your Data

You have the following rights regarding your data:

•Delete Data: You may ask us to delete some, or all, of your data (eg. if it is no longer necessary to provide the Platform to you).
•Change Data: You may also ask us to change or correct your data in certain cases, particularly if it's inaccurate. However, there are situations where it is not possible for us to change or correct data. We cannot guarantee that any changes or corrections are possible.
•Object to, or Limit or Restrict, Use of Data: You may ask us to stop using all, or some, of your data (eg. if we have no legal right to keep using it) or to limit our use of it (eg. if your data is inaccurate or unlawfully held).
•Right to Access and/or Take Your Data: You may ask us for a copy of your data and can ask for a copy of data you provided in machine readable form.

To make such a request, please see Section 6.4 below for instructions on how to contact us. We will consider your request in accordance with applicable laws. Residents in the countries governed by General Data Protection Regulation (GDPR), or similar laws, may have additional rights.

6. Other Important Information

6.1 Security

Server infrastructure and software security is infallible and cyberattacks present a constant risk to information integrity, security, and confidentiality. Although we implement significant security measures for server infrastructure and software on the Platform, we cannot guarantee the integrity, security, or confidentiality of any information that you share on the Platform.

It is important for you to protect against unauthorized use of your login access information, such as your password or Personal Identification Number (PIN). Be sure to sign off when finished using a shared computer.

6.2 Lawful Bases for Processing

We will only collect and process data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, such as to deliver the Platform you have requested) and "legitimate interests".

Where we rely on your consent to process data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your data, please contact us by following the instructions in Section 6.4.

6.3 Direct Marketing and Do Not Track Signals

We currently do not share data with third-parties for their direct marketing purposes without your permission. Our policy on "do not track" signals is explained in the Cookie Policy.

6.4 Contact Information

If you want to contact us with questions related to privacy, please complete and submit our online submission form by clicking here. Please note that providing detailed and accurate information at the outset will facilitate efficient processing of your submission.