Last Updated July 23, 2019
We collect personally identifiable and non-personal information from you when you visit the Site. The majority of information is collected during the registration and/or investment process and, while some items are optional, most are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Site, but keep in mind that some of this information will be required if you wish to partake in the Service. In general, the type of information we collect includes, but is not limited to:
● Personal data required to verify your identity;
● Personal and financial data necessary to assess your eligibility to utilize the Services on the Site; and
● Non-identifiable and aggregated personal data pertaining to your Site visits that help us maintain the appropriate features, functionality and User experience.
Investor registration applications will require you to provide basic personal data. Such information may include but not be limited to:
● Your name, address, phone number, email address, birth date, and other personal information.
● Financial information, including your social security number, income, and net worth.
● Copies of your tax returns, brokerage statements, W-2 forms, and other financial documents.
● Your user name and password.
● Information to confirm your identity, such as a completed electronic check transaction or a credit report.
● Your W-9 form.
● Information to confirm your place of residence.
● Information about your use of the Site.
● Information about your computer configuration.
● Information to confirm your relationship with other parties associated with the Site.
● Information about your bank accounts or other sources of payment.
● Your IP address.
We use this data to: (i) enable you to log in to the Site; (ii) establish your ability to view offering materials and to make investments through the Site; (iii) verify that you are at least 18 years of age; (iv) guard against potential fraud; (v) contact you if there is a problem with your Account; and (vi) maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities and other Company updates.
We will also gather the names and email addresses of Users who contact us through the Site with questions about our Company or Site. We collect this information for the sole purpose of responding to such inquiries.
When you subscribe to make an investment in one of our offerings on the platform, you will again be asked for your personal data. You will also be required to provide financial data, such as your bank routing number or swift code, and bank account number, to help to facilitate the subscription process.
We, or our service providers, may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; the dates and times that you visit the Site; and general geographical location. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any Users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. We may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We also may use it to help optimize the Site based on the needs of our Users.
If you would prefer not to see advertising based on your personal preferences, you can change your personal settings in Google (look for “Ad Settings”) or visit the website of the Network Advertising Initiative located at: http://www.networkadvertising.org/choices/#completed
We do not sell or rent personal information about our Users for marketing purposes. We do, however, share your personal information with our trusted partners who perform vital functions with respect to the investment opportunities on our Site.
In addition, your investment profile information may, in a generic way, be made publicly available for use on the “Statistics” page of the Site or in other summaries of aggregate investment data.
If you use our communications forums on the Site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other Users of this forum and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit through this forum.
Generally, we use your personal information to:
● Verify that you are permitted to use and invest through the Site.
● Keep track of your investments.
● Guard against fraud.
● Comply with applicable law.
● Answer your questions.
● Protect our rights.
● Send to third parties at your request.
● Process your transactions at the Site.
● Determine whether your computer information is compatible with the Site.
● Keep track of your use of the Site.
● Send you information about your investments.
● Notify you of other possible investments in which you might have an interest.
● Analyze use of the Site.
● Improve the Site.
● Send you information about the Site.
● Send you materials about us.
● Other purposes we disclose to you.
We also work with providers of hosting services for the Site, electronic signature providers, and electronic payment service providers. We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing, reporting, tax documentation, custody or escrow services. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform, as well as other specific services, like collections. Our partners are legally required to keep your information private and secure.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, legal process, government request, or to comply with any applicable law or regulation, foreign or domestic. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or the Service, or to protect the rights, property or personal safety of the Company, its Users, issuers, or others.
By utilizing the Site, you hereby give us the right to produce any and all messages or user content of any kind produced by you to county, state, and federal courts and/or government officials in response to a subpoena or other court order in the U.S., or in response to similar requests in other jurisdictions.
We will send you email notifications from time to time. For example, we may send you emails:
● To confirm your registration.
● To provide you with legal notices.
● To notify you of new investment opportunities.
● When the online profile you created is changed.
● To ask you to participate in surveys, or otherwise provide feedback.
● To confirm your investment in a project.
● To ask you for information.
● You may also receive emails from third-party providers.
Some notifications are required elements of your transactions on our platform, such as confirmations of particular actions you have taken. These mandatory notices are sent typically to notify you of a change in status. For example, when you register an Account, you will receive emails confirming specific actions you requested. These will include emails to which you must respond to complete your registration and notifications confirming your registration.
We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your Account without your knowledge. In other cases, these notifications involve changes to various legal agreements or Site policies. Generally, you may not opt out of such service-related emails.
We urge you to review your information regularly to ensure that it is correct and complete. To modify or delete your personal information, please log in and update your profile. We may retain certain information as required by law or for necessary business purposes.
We have put in place systems designed to protect your personal information, including:
● We employ a secure channel, using Secure Sockets Layer (SSL) encryption, the standard for secure Internet network connections, to protect information exchanged over the Internet between your web browser and our servers.
● We use automated tools to monitor network traffic to identify unauthorized attempts to upload information, change information, or otherwise seek to gain unauthorized entry into our systems.
● We take additional steps to protect especially sensitive information.
Nevertheless, no security system is perfect. We cannot guarantee that your personal information will remain private.
We limit access to the personal information we have about you to those employees and other persons who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. The Site is built upon a secure infrastructure with multiple layers of protection, and we use industry-standard encryption technologies to safeguard your information.
Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Site. Generally, identification and authentication take place through the use of your username and a password and/or while logging in with one of our support staff.
If we learn of a security systems breach, then we will attempt to notify you electronically or in writing so that you can take appropriate protective steps. We may also post a notice on or through the Site in the event of a security breach.
You can take several precautions to protect the security of your computer and personal information. For instance, you can use a well-chosen password and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious Users. When you are finished with a session on the Site, be sure that you log out and close the browser window.
You should also be aware of fraudulent attempts to gain access to your account information through "phishing," whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake site, scammers will ask for login information to gain access to people's Accounts and withdraw their money.
We will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain. In the case of the Company, you should always ensure the URL begins with https://www.waterworksfund.com.
Transmissions over the Internet are never 100% secure or error-free. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal information to WaterWorks or through WaterWorks Service via the Internet.
California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (the “California Act”) and the California Business and Professions Code. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. The California Act requires us to inform you, at your request, (1) the categories of personal information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. The California Act further requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send a request by email or standard mail. When contacting us, please indicate your name, address, email address, and what personal information you do not want us to share with marketing partners. The request should be sent to the attention of our legal department and labeled “California Customer Choice Notice.” To make a request, please send an email to info[at]waterworksfund.com. Please allow 30 days for a response. There is no charge.
Please send your privacy-related complaints and suggestions to info[at]waterworksfund.com. You can also send complaints to regulators. Please contact your state’s consumer protection authority.