Privacy Policy
Last updated: March 24, 2023
This Privacy Policy describes Markin Asset Management’s policies and procedures on the collection, use and disclosure of Your Visitor information when you visit MarkinFunds.com and informs You about Your Privacy rights and how the law protects You.
Markin Asset Management uses Your Visitor data to provide and improve on the performance of our website and the services we provide. By using the MarkinFunds.com website, you agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined in the following section. These definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You when you become a client, subscribe to our communications, or access our website.
Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Visitors' information and determines the purposes and means of the processing of Visitors' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of Visitors' personal information, that does business in the State of California.
CCPA and/or CPRA refers to California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Markin Asset Management, 411 Theodore Fremd Avenue, Suite 206S, Rye, NY 10580, United States. For the purpose of the GDPR, the Company is the Data Controller.
Visitor, for the purpose of the CCPA/CPRA, means a person who is a resident of the United States. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to the United States
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to Markin Asset Management as the legal person which determines the purposes and means of the processing of Personal Visitor or Customer Data.
Device means any device that can access the Website such as a computer, a cellphone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
GDPR refers to EU General Data Protection Regulation.
Personal Data is any information that relates to an identified or identifiable individual.
For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to Your identity.
For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
Website refers to www.MarkinFunds.com.
Service Provider means the person who processes the data on behalf of Markin Asset Management. It refers to third-party companies or individuals employed by Markin to facilitate or perform services related to the Website or to assist the Company in analyzing how the Website is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
Usage Data refers to data collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).
Website refers to Markin Asset Management, accessible at www.MarkinFunds.com
You means the individual accessing or using the Website, or the company on behalf of which such individual is accessing or using the Website, as applicable.
Under GDPR, You may be referred to as the Data Subject, Visitor or as the User as you are the individual using the Website.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While visiting our Website or accessing Our Services, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Phone number
Visitor Usage Data
Usage Data
Visitor Usage Data is collected automatically when visiting Our Website.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access Our Website by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Website or when You access the Website by or through a mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Website. The technologies We use may include:
Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Website. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Website may use Cookies.
Web Beacons. Certain sections of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies on TermsFeed website article.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
To provide and maintain our Website, including to monitor the usage of our Website.
To manage Your Account: to manage Your registration as a user of the Website. The Personal Data You provide can give You access to different functionalities of the Website or Services that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Website.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
To deliver targeted advertising to You: We may use Your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, services, marketing and your experience.
We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers like Google to monitor and analyze the use of our Website, to advertise on third party websites to You after You visited our Website, to contact You.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Data
Markin Asset Management will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Markin Asset Management will also retain Visitor Usage Data for internal analysis purposes. Visitor Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Website, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Website or email subscription service may give You the ability to delete certain information about You from within the Website. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Disclosure of Your Personal Data
Legal requirements
Markin Asset Management may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Protect the personal safety of Visitors of the Website or the public
Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors (such as Google) collect, store, use, process and transfer information about Your activity on Our Website in accordance with their Privacy Policies. For example:
Analytics
We may use third-party Service providers to monitor and analyze the use of our Website.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
Mailchimp
Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/
Behavioral Remarketing
Markin Asset Management may use remarketing services to advertise to You after You accessed or visited our Website. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Website so that We can improve our Website to reflect Your interests and serve You advertisements that are likely to be of more interest to You.
These third-party vendors collect, store, use, process and transfer information about Your activity on Our Website in accordance with their Privacy Policies and to enable Us to:
Measure and analyze traffic and browsing activity on Our Website
Show advertisements for our products and/or services to You on third-party websites or apps
Measure and analyze the performance of Our advertising campaigns
Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:
The NAI's opt-out platform: http://www.networkadvertising.org/choices/
The EDAA's opt-out platform http://www.youronlinechoices.com/
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.
We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Website with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.
The third-party vendors We use are:
Google Ads (AdWords)
Google Ads (AdWords) and remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Twitter also provides remarketing services. You can opt-out from Twitter's interest-based ads by following their instructions here: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which Markin Asset Management is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Markin Asset Management.
In any case, Markin Asset Management will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
Markin Asset Management undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Website.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
CCPA/CPRA Privacy Notice
For California residents, this portion of the privacy notice supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Visitor or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.
Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Collected: Yes.Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, address, or telephone number. Some personal information included in this category may overlap with other categories.
Collected: Yes.Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), sex (including gender, gender identity, gender expression), veteran or military status, genetic information (including familial genetic information).
Collected: No.Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: No.Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.Category F: Internet or other similar network activity.
Examples: Interaction with our Website or advertisements.
Collected: Yes.Category G: Geolocation data.
Examples: Approximate physical location.
Collected: No.Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No.Category J: Non-public education information per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.Category L: Sensitive personal information.
Examples: Account login and password information, geolocation data.
Collected: Yes.
Under CCPA/CPRA, personal information does not include:
Publicly available information from government records
Deidentified or aggregated Visitor information
Information excluded from the CCPA/CPRA's scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
Directly from You. For example, from the forms You complete on Our Website, preferences You express or provide through our Website or Services.
Indirectly from You. For example, from observing Your activity on our Website.
Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Website.
From Service Providers. For example, third-party vendors like Google to monitor and analyze the use of our Website, third-party vendors to deliver targeted advertising to You, or other third-party vendors that We use to service the Website.
Use of Personal Information
We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:
To operate our Website and provide You with Our Services.
To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Website and the Services we provide.
To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Website or Services, We will use that personal information to respond to Your inquiry.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Other one-time uses.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.
If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.
Disclosure of Personal Information
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Share of Personal Information
We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:
Service Providers
Our business partners
Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You
Sale of Personal Information
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Visitor's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We DO NOT sell personal information as the term sell is commonly understood.
We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a “sale” under CCPA/CPRA. This includes the following categories of personal information:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact “sold”, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
Your Rights under the CCPA/CPRA
The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
The categories of personal information We collected about You
The categories of sources for the personal information We collected about You
Our business or commercial purposes for collecting or selling that personal information
The categories of third parties with whom We share that personal information
The specific pieces of personal information We collected about You
If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
The categories of personal information categories sold
The categories of personal information categories disclosed
The right to Opt-out. You have the right to submit an opt-out request, please see the "Opt-out" section or contact Us.
The right to correct Personal Data. You have the right to correct or rectify any any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.
The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Us.
The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
Denying goods or services to You
Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
Providing a different level or quality of goods or services to You
Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA/CPRA Data Protection Rights
Please see the "Opt-out" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.
Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:
By email: info@markinfunds.com
By phone number: +1 (914) 269-2338
By mail: 411 Theodore Fremd Avenue, Suite 206S, Rye, NY 10580 United States
Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
We cannot respond to Your request or provide You with the required information if We cannot:
Verify Your identity or authority to make the request
And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.
Opt Out
As defined in the CCPA/CPRA, "sell" and "sale" is broadly defined as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Visitor's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We DO NOT sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a “sale” under CCPA/CPRA.
You have the right to opt-out of the collection or sharing of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop collecting or sharing any of Your personal information. To exercise Your right to opt-out, please contact Us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Website that shares personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential “sales” as defined under CCPA/CPRA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.
Website
If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Opt-out" buttons listed on the Website to review your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access Markin’s Website.
Additionally, You can opt out of receiving ads that are personalized as served by our Website Service Providers by following our instructions presented on our Website:
The NAI's opt-out platform: http://www.networkadvertising.org/choices/
The EDAA's opt-out platform: http://www.youronlinechoices.com/
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.
Mobile Devices
Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:
"Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
"Limit Ad Tracking" on iOS devices
You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.
Limit the Use or Disclosure of My Sensitive Personal Information
If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services.
We collect, use and disclose sensitive personal information in ways that are necessary to provide Services and access to Our Website. For more information on how We use Your personal information, please see the "Use of Your Personal Data" section or contact us.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Website does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.
Links to Other Websites
Our Website may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
Markin Asset Management may update this Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Website, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
By email: info@markinfunds.com
By phone number: +1 (914) 269-2338
By mail: 411 Theodore Fremd Avenue, Suite 206S, Rye, NY 10580 United States