LEGAL NOTICE
Privacy Policy
Investment Advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule regarding the privacy of consumer financial information (“Regulation S-P”). We have developed this privacy policy to provide you with information about the types of information we may collect from you when you visit our Site or otherwise contact us. We take precaution to maintain the privacy of personal information concerning our current clients and prospective investors. These precautions include the adoption of certain procedures designed to maintain and secure such client’s nonpublic personal information from inappropriate disclosure to third parties.
Please note that if you are an investor in our funds, you should review the privacy notice(s) provided with your investment documents for additional information on our data collection and use.
If you are a California resident and your personal information is subject to the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations, and as amended by the California Privacy Rights Act, and as further amended from time to time, “CCPA”),please review the Additional Information for California Residents section below for additional disclosures, our Notice at Collection, a description of your rights under the CCPA.
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INFORMATION WE COLLECT
X Capital Advisors, LLC (X Capital) must collect certain personally identifiable financial information about its customers to provide financial services and products. The personally identifiable financial information that we gather during the normal course of doing business with you may include:
• information we receive from you on applications or other forms;
• information about your transactions with us, our affiliates, or others;
• information we receive from a consumer reporting agency.
X Capital website collects personal information when you fill out an online form that is submitted to X Capital via a X Capital Web site, including, but not limited to, those forms requesting information about X Capital or any of our services, or requests for someone at X Capital to contact you. The submission forms require you to provide contact information (such as name and e-mail address),and in some cases ask for other optional information (such as your phone number, home address and contact preferences).
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COLLECTION, USE, AND DISCLOSURE OF NON-PERSONAL INFORMATION
"Non-Personal Information" contains nothing that could identify you personally. X Capital may collect such Non-Personal Information, such as demographic and profile data, through the XCapital Web sites. X Capital may aggregate Non-Personal Information and share it with our affiliated companies and other third parties.
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INFORMATION WE DISCLOSE
We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted or required by law, or as necessary to provide services to you. In accordance with Section 248.13 of Regulation S-P, we may disclose all of the information we collect, as described above, to certain non-affiliated third-parties such as our attorneys, accountants, auditors, to certain affiliated third-parties in order to provide services or products to you, and to persons or entities that are assessing our compliance with industry standards. We enter into contractual agreements with all non-affiliated third-parties that prohibit such third-parties from disclosing or using the information other than to carry out the purposes for which we disclose the information.
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CONFIDENTIALITY AND SECURITY
We restrict access to nonpublic personal information about you to those Employees who need to know that information to provide financial products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. ACCURACYX Capital strives to maintain accurate personal information in our client files at all times. However, as personal situations, facts and data change over time; we encourage our clients to provide feedback and updated information to help us meet our goals.
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OPT-OUT
In order to opt-out of receiving future mailings or e-mails on a given topic, please send an email toinfo@xcapadvisors.us, or write to X Capital Advisors, LLC, PO Box New York, NY . Please include your full name, your current address and previous address if you have been at your current address fewer than six months and your email address. X Capital will process your opt-out request, but it may take up to two weeks for the request to be processed through our systems and you may receive communications from X Capital during that period. To re-subscribe, you may return to the relevant Web site and resubmit the request form.
Where We Process Your Information
We are based in the U.S. When you provide personal information to us from outside of the U.S., please be aware that we will receive and process it in the U.S. and that U.S. data protection laws may be different from those of your country of residence.
Children’s Information
This Site is not intended for use by those under 13. We do not knowingly solicit or collect personal information on the website from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personal information to us, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required bylaw).
Links to External Websites
Our Site may contain links to third party websites. Any access to and use of such third-party websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third-party websites.
Your Rights
You may have certain rights with regard to your personal information, including: access your personal information; rectify the information we hold about you; erase your personal information (in certain circumstances); restrict our use of your personal information (in certain circumstances);object to our use of your personal information; receive your personal information in a usable electronic format and transmit it to a third-party (also known as the right of data portability);withdraw any consent you have given to uses of your personal information and lodge a complaint with your local data protection authority. If you wish to exercise any of these rights, please contact us using the information below in Contact for More Information. Please use the subject line “Data Rights Request” if emailing.
Additional Information for California Residents & Notice at Collection
As a business, California’s privacy law, the CCPA, requires us to provide additional disclosures with regard to our collection, use, disclosure, and sharing of personal information and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Notice at Collection and Use of Personal Information
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Information We Collect
Depending on how you interact with us, we may collect the categories of personal information listed above in the section Information We Collect and How We Collect It.
Purpose for Collection and Use of Information
We may collect and use personal information from you for the purposes described above in the section Purpose for Collecting and Using Personal Information.
Sale or Sharing of Personal Information
We do not sell or share your personal information (as such terms are defined under the CCPA).
How Long We Keep Information
How long we keep your personal information will vary depending on the type of personal information and our reasons for collecting it. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal information). In general, we will retain your personal information for as long as we require it to perform our contractual rights and obligations or for periods required by our legal and regulatory obligations.
For more information about our privacy practices, please review our entire Privacy Policy, which is available starting at the top of this webpage.
Our Collection, Use, and Disclosure, of Personal Information and Sensitive Personal Information
What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information from all or some of the categories of sources listed above in the section, Information We Collect and How We Collect It. We may collect all or a few of these categories of personal information for the business or commercial purposes identified in the section, Purpose for Collecting and Using Personal Information.
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Disclosure of Personal Information
We do not sell or share your personal information as defined under the CCPA (as those terms are defined under the CCPA). We do not knowingly sell or share the personal information of California residents under 16 years old.
CONTACTING US
If you have any questions about this Privacy Policy, the practices of any of the X Capital Web sites or the information you have submitted to the X Capital Web sites, you can contact X Capital at info@xcapadvisors.us.