Effective Date/Last Updated: August 26, 2020
COLLECTION OF INFORMATION
Information You Provide to Us
We collect information you provide directly to us. For example, you may share information directly with us when you subscribe to an investment product, complete subscription materials, email us, fill out a web form, communicate with us via third-party platforms, subscribe to our newsletter, or otherwise interact with us. The types of personal information we collect may include your name, email address, postal address, phone number, date of birth, citizenship, tax identification number, government issued identification, banking information, financial information, employment information, signature, beneficiaries, and other information you may choose to provide.
Information We Collect Through Technology
When you access or use our Site or Services, we may collect information about your activities through technology. We and our service providers may use tracking technologies, such as cookies, to collect information about your use of our Site and Services, including your browser type, operating system, Internet Protocol (IP) address, access times, pages viewed, and links clicked. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular, and count visits. For more information about cookies and how to disable them, see Cookies and Your Choices section below.
Information We Collect from Other Sources
We may also obtain information about you from other sources. For example, we may collect information about you from data analytics providers, marketing automation platforms, email providers, and other third-party sources. Additionally, if you create or log into your online investor account through a third-party platform, we will have access to certain information from that site, such as your name, email, and usage, in accordance with the authorization procedures determined by such third-party platform.
Information We Derive
We may derive information or draw inferences about you based on the information that we or our service providers collect. For example, we may make inferences about your country of residence based on your IP address or infer that you may be interested in certain Services based on your browsing behavior.
USE OF INFORMATION
We use the information we collect to communicate with you, fulfill regulatory requirements, enter into agreements, perform investment due diligence, and complete investment transactions. We also use the information we collect to:
Provide, maintain, and improve our products and services;
Process bank transfers and send you related information, including contribution and distribution notifications, confirmations, and tax and financial reports;
Send you support and administrative messages, respond to your comments, questions, and provide you client service;
Communicate with you about and/or market products, services, and events offered by Manna Tree and others, and provide news and information we think will interest you (see Your Choices below for information about how to opt out of these communications at any time);
Collect and follow up on investment opportunities or inquiries from interested parties;
Monitor, analyze, and track data, usage, and activities in connection with use of our Site;
Tailor your experience on or with respect to our Services;
Provide interest-based advertisement;
Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of Manna Tree and others;
Debug to identify and repair errors in our Services;
Comply with our legal and financial obligations; and
Carry out any other purpose described to you at the time the information was collected.
SHARING OF INFORMATION
We share personal information as follows or as otherwise described in this policy:
With service providers, vendors, and consultants that perform services for us, including but not limited to, web hosting, file sharing and storage, data security, shipping and delivery, fund administration, customer relationship management, email delivery, customer service, and marketing;
Publicly on our Site or Services if you submit or post comments or content on our Site or Services;
If we believe disclosure is in accordance with, or required by, any applicable law or legal process, including tax reporting requirements, agency requirements in certain countries, auditing, lawful requests by public authorities including law enforcement and courts, and national security requirements;
If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Manna Tree, our investors, the public, or other third parties;
With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;
In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
Between and among Manna Tree and our current or future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
With your consent or at your direction.
INTERNATIONAL TRANSFER OF INFORMATION
Manna Tree is headquartered in the United States and have operations and service providers in other countries, including Switzerland and Canada. We and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your jurisdiction of residence. By providing us with your data, you consent to its transfer to and processing within the United States, Switzerland, Canada, and in any other country where we or our service providers may process your information.
COOKIES AND YOUR CHOICES
To recognize you when you return to our Site;
To help us see which features are most popular;
To improve and customize our Site and user experience;
To assess the effectiveness of advertising, marketing, and content; and
To deliver marketing communications that may be of interest to you.
Most web browsers are set to accept cookies by default but allow you to control the use of most cookies through their settings. If you prefer, you can choose to set your browser to remove or reject browser cookies.
Our Site uses Google Analytics to track your activity. You may install the Google Analytics Opt-out Browser Add-on found here to prevent your data from being used by Google Analytics.
If you wish to change, delete, or update your contact information or other information we have about you, please email us at firstname.lastname@example.org. But note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you.
You may opt out of receiving promotional emails from Manna Tree by following the instructions in those communications or by managing your communication preferences in your account settings menu. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Do Not Track Signals
Manna Tree does not respond to “Do Not Track” browser signals or similar mechanisms.
ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA
If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.
Legal Basis for Processing
When we process your personal data, we will do so in reliance on one or more of the following lawful bases:
To perform our responsibilities under our contract with you (e.g., complete investment transactions).
When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
When we find such processing is necessary to comply with a legal obligation to which we are subject (e.g., for tax filings, to track those who have opted-out of marketing communications).
When we have your consent to do so (e.g., when you agree to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.
We store personal data for as long as is necessary for the purpose(s) for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Data Subject Requests
You have the right to request access to the personal data we hold about you and to ask that your personal data be corrected, erased, or transferred in a portable format. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please contact us at email@example.com.
Questions or Complaints
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. Contact details of your Data Protection Authority can be found using the links below:
For individuals in the EEA: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html