Privacy Policy

Last modified: July 1, 2024

Our commitment to privacy

Eleven ("Eleven", “we”, “our”, or “us”) recognizes, respects and appreciates your privacy. We are committed to protecting the privacy of our customers and safeguarding against unauthorized disclosure of or access to personal information of our Users.

We are a cloud-based customer engagement platform for the global private investment industry. We have created this Privacy Policy to explain how we use and protect the information that you submit to us. It is important that you carefully read this Privacy Policy prior to accessing and/or using platformeleven.io. (the "Website") or registering for and/or using the Services (as defined in the Terms of Use Agreement (the "Terms of Use")), as your use and continued use of the Website and Services acknowledges your consent to this Privacy Policy and the Terms of Use. Please do not access or use the Website or register as a User of the Website or Services if you do not agree to abide by this Privacy Policy. As we update our Website over time, this Privacy Policy may change, so please check periodically for updates.

Collection of personal information

We employ reasonable and appropriate technical and organizational security controls that align with industry standards and best practices to safeguard your information. Personal information about you may be collected from you through various sources, including information i) that is entered manually and voluntarily by you on the Website’s application and other forms or postings on the Website; ii) that you provide regarding your preferences (for example, based on your activity on our Website); iii) from other sources with your consent (for example, from other institutions such as auditors or administrators); iv) from sources in the public domain; and v) from other interactions you may have with us (for example, discussions or emails with our staff, including through the use of the Website’s contact features).

In addition, when you visit our Website, we may gather anonymous technical and navigational information, such as computer browser type, Internet protocol address, cookie information, pages visited, and average time spent on our Website. This information does not personally identify you and may be used, for example, to alert you to software compatibility issues, to customize any advertising or content you see, fulfil your requests for products and services, contact you, conduct research or analyze and improve our Website design and functionality.

Such information collected by us may be stored and processed in the United States. By using the Service, you consent to the foregoing collection and use of information and any such transfer of information outside of your country.

The information you may provide us can be classified into two general types (user-provided information and website usage information). Both are discussed in greater detail below.

Personal information you choose to provide

In order to provide the best experience when you visit our Website, we may ask you for Personal Information. Personal Information includes, for example, your name and email address, both of which you may be asked to provide when registering with Eleven. A description of some of the ways that you may provide personal information to us, as well as further details on how we may use such personal information, is given below.

1. Contact us / feedback

If you email us using a “Contact” link on our Website, we may ask you for information such as your name and email address so we can respond to your questions and comments. If you choose to correspond with us via email, we may retain the content of your email messages, your email address and our response to you.

2. Surveys

We may occasionally ask website visitors to complete online surveys and opinion polls about their activities, attitudes and interests. These surveys help us improve our products and services. When asking for participation in these surveys, we may ask you to provide us with your name and email address.

3. Website Forms

Our Website may offer visitors contact forms to request additional details and to download collateral. If you fill out one of our web forms, we may ask you for information such as your name and email address so we can respond to your questions and comments. If you choose to correspond with us via web forms, we may retain the form data which can include name, email address and other contact related details.

Website usage information

Cookies

Websites commonly use “cookies” to enhance identification of its users. Cookies are pieces of information that are passed to your browser and stored on your computer's hard drive. We may set and access cookies to recognize repeat visitors, to automatically enter your login ID and/or to provide additional features to make your experience faster and more efficient. We do not link the information we store in cookies to any personally identifiable information you submit while on our Website. We may allow other companies that are advertising on some of our pages to set and access cookies on your computer. The use of these cookies by other third parties is subject to their own privacy policies. Advertisers or other third parties do not have access to our cookies. Your browser must be configured to accept cookies in order to login to the Website.

Web beacons

Web Beacons, also known as pixel tags and clear GIFs, ("Web Beacons"), are electronic images that allow a website to access cookies and help track marketing campaigns and general usage patterns of visitors to those websites. Web Beacons can recognize certain types of information, such as cookie numbers, time and date of a page view, and a description of the page where the Web Beacons is placed. No personally identifiable information about you is shared with third parties through the use of Web Beacons on the Website. However, through Web Beacons, we may collect general information that will not personally identify you, such as: Internet browser, operating system, IP address, date of visit, time of visit and path taken through the Website.

Internal use of Web Beacons. Elevenven may use Web Beacons internally to count visitors and recognize visitors through cookies. Access to cookies helps Eleven personalize your experience when you visit the Website.

Email. Eleven may include Web Beacons in HTML-formatted email messages that Eleven sends to you. Web Beacons in email messages helps Eleven determine your interest in and the effectiveness of such emails.

External use of Web Beacons. Eleven may also use Web Beacons externally. For example, Eleven may report aggregate information about visitors, such as demographic and usage information, to its affiliates and other third parties. Eleven may also include other Eleven's Web Beacons within the Website.

How we use personal information

We collect and maintain personal information for the purposes of identifying you; approving your account and maintaining your status as a User; processing your payment for account; contacting you with regard to your account,status as a User or account; responding to inquiries from you or your representative; improving and customizing the content you see on the Website; analyzing Website usage; fulfilling legal and regulatory requirements; and as otherwise set forth in this Privacy Policy.

We may also use your non-personal information (such as demographic and usage information, or other information that you submit such as your reasoning for joining the Website) for improving our marketing and promotional efforts; statistically analyzing Website usage; market research; project planning; investigating and troubleshooting problems; detecting and protecting against error, fraud or other criminal activity; enforcing the Terms of Use or any applicable Rules; developing, upgrading, modifying, offering and/or delivering better, new and/or innovative products and services to you; and other internal purposes or as otherwise described to you at the time of collection.

Your username and some personally identifiable information that you voluntarily disclose may be displayed to other Users when you upload content or send messages through the Website. Notwithstanding the foregoing, you specifically represent and warrant that you will also respect the privacy of information in the Website and not make public any information in the Website. You expressly acknowledge and understand that the information in the Website is private, offered solely and strictly intended for the Users of the Website and that the security of all information in the Website is crucial for the overall functioning of the Website.

Your opt in/opt out choices

Unless you specifically opt out, we may also use your personal information to contact you and deliver information to you that, in some cases, is targeted to your interests, such as administrative notices, newsletters, notices, product offerings and communications relevant to your use of the Website or the Services. By accepting the Terms of Use and this Privacy Policy, you expressly agree to receive this information, unless you specifically opt out. We will obtain your consent for any use of your personal information beyond those set forth in this Privacy Policy and the original uses for which you provided your consent.

Disclosure and sharing of personal information

Except as expressly provided herein, absent your prior consent, we do not sell, rent, trade, share or exchange your personal information with any unrelated third parties. Notwithstanding the foregoing, we reserve the right, and you authorize us, to share or disclose your personal information, including, without limitation, any content, records or electronic communications of any kind, when we determine, in our sole discretion, that the disclosure of your personally identifiable information is necessary to identify, contact, or bring legal action against you if: you are or may be violating the Terms of Use, this Privacy Policy or any applicable Rules; you are interfering with a third party's or our rights or property; you are violating any applicable law, rule or regulation; necessary or required by any applicable law, rule or regulation; and/or requested by governmental authorities in the event of any investigation, act of terrorism or instance of local, regional or national emergency.

While we use industry standard practices to implement reasonable and appropriate technical and organizational measures to protect your privacy, we cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. For example, and without limiting the foregoing, we may be forced to disclose personal information to the government or third parties under certain circumstances or third parties may unlawfully intercept or access your transmissions or communications. Nonetheless, we will use reasonable commercial and legal efforts to protect our Users’ private information.

In the event that we go through a business transition or corporate event such as a merger, acquisition, sale of all or a portion of our assets, or change of control, your personal information collected by us about you would be considered a business asset and would be transferred to the applicable new entity. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

We may use third-party partners to help us operate and maintain our Website and deliver our products and services. We may also share your information with our service providers and other third parties (“Affiliated Parties”) that provide products or services for or through this Website or for our business (such as website or Infrastructure hosting companies, communications providers, email providers, analytics companies, credit card processing companies and other similar service providers that use such information on our behalf).

Third-party service providers are contractually restricted from using or disclosing the information, except as necessary to perform services on our behalf or to comply with legal requirements.

Your ability to access, limit use and disclosure

You may request access to your personal data to update, correct or delete, or to limit the use or disclosure of your personal data.

Individuals wishing to view, update, delete, or supplement their personal data may do so by contacting the business that provided Eleven your personal data directly to make your requests, or alternatively you can submit your request through our Data Subject Access Request (DSAR) Portal. If the Eleven DSAR portal is unavailable, requests can be sent to privacy@platformeleven.io. Individuals outside the EU may also use our Data Subject Access Rights portal to submit complaints about your privacy and our collection or use of your personal information.

Security measures

Access to nonpublic personal information about you is restricted to those individuals or parties who need to know that information to provide products or services to you. For your privacy and security, personal information that you submit to us is password protected. Please note that in the unlikely event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party's ability to view, use or disseminate such information. While we have in place up-to-date technology and Internet procedures to protect your payment information from intruders, it is impossible to guarantee that these technologies and/or procedures will eliminate all of the risks of theft, loss or misuse. We are not liable for any damages that might result from unauthorized use, publication, disclosure or any other misuse of payment information, including but not limited to credit card information.

For the information given on the Internet, we also use a variety of protections to maintain the security of your online session, which include the use of firewall barriers and authentication procedures. While we do our utmost to protect your information, we cannot ensure or guarantee the security of any information you transmit to us as no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. It is important to note that any information you transmit to us is done solely at your own risk.

We also seek to provide a safe and secure environment by controlling who has access to the Website and Services. Any person, party or entity that does not have an authorized user account is strictly forbidden from entering the Website and/or viewing User Content. Any violation is considered extremely damaging to us, and we shall pursue our rights to the fullest extent of the law. Should we discover that a wrongfully authorized user has gained access (through us or through other channels), we will seek to rectify the situation immediately, including immediately suspending or terminating such user’s account. Notwithstanding the foregoing, Users agree to not share their login credentials with anyone and agree to keep confidential all information and content on the Website.

Aggregate/De-Identified Data. We may aggregate and/or de-identify information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others. By using the Services, you consent to such use.

Online Analytics and Advertising

Analytics.

We use third-party web analytics services, including Google Analytics, on our Services to collect and analyze the information discussed above, and to engage in auditing, research and reporting. The information (including your IP address) collected by various analytics technologies described in the "Cookies and Similar Technologies" section will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive, analyzing usage trends across our products and mobile devices, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Encrypted information

There are areas on the website where you may enter and submit information. These areas are encrypted using SSL encryption (TLS 1.2) between your Web browser and our Web servers. This is designed to reduce the chances of someone stealing your private information as it travels from your web browser to our secure server. When you enter an encrypted page you will see a security notice and an icon on your browser (for example a lock for Microsoft Internet Explorer). Some older browsers have known SSL bugs that can result in the browser crashing on SSL pages or giving error messages. We recommend that you upgrade to the latest version of your preferred browser.

Links to other sites

The Website may include links to other websites, which are provided for your convenience, and other websites may also reference or link to our Website. We do not review, control or monitor the privacy practices operated by others and we are not responsible for any aspect of these websites or for your business dealings with them. Additionally, such links are not an endorsement by us of those websites and/or the products or services offered on those websites.

Your postings, submissions and transmitted information

We reserve the right to review your postings, submissions and transmitted information made by you to determine, in our sole discretion and at any time, your compliance with the Terms of Use and this Privacy Policy. However, such review is totally at our option, we have no duty to any such review.

How long we store your information

We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Terms of use

This Privacy Policy is governed by the Terms of Use, which includes all disclaimers of warranties and limitation of liabilities. All capitalized terms not defined in this Privacy Policy will have the meaning set forth in the Terms of Use.

To review other applicable terms and conditions that apply to this Privacy Policy, including, without limitation, intellectual property rights, representations and warranties, disclaimer of warranties, limitation of liability and resolving disputes, please review the Terms of Use.

Children's privacy (COPPA)

This Website is not designed, structured, directed or intended for children under the age of 13. For that reason, we do not knowingly collect or maintain personally identifiable information or non-personally-identifiable information on the Website from persons under 13 years of age. If you are under 13 years of age, then please do not use or access the Website at any time or in any manner. If we learn that personally identifiable information of persons under 13 years of age has been collected on the Website without verified parental consent, then we will take the appropriate steps to delete this information.

The Children’s Online Privacy Protection Act (COPPA) puts parents in control for children under the age of 13. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

California Consumer Privacy Act

On January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) took effect, and set new requirements and rights relating to personal information of California consumers. This section for California residents applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

California Civil Code Section 1798.83 permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for such third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, contact us by email at privacy@platformeleven.io.

With regard to the California Consumer Privacy Act (“CCPA”) please be advised that Eleven will not sell your data to any third parties, California Law requires that we allow you to Opt-Out Of the sale of your personal information.

If you are a California Consumer you have certain rights under the CCPA: Consumers have the right to request access to personal information, and can make this request for free, twice per year.

1.Right of Access

On receiving an access request, Eleven will provide the necessary information in a portable and easily accessible format, normally within 45 days of the request. The categories of personal information the business collects about the consumer are:

• The categories of sources of the consumer’s personal information
• The business or commercial purpose for collecting or selling the consumer’s personal information
• The categories of any third parties with whom the business shares the consumer’s personal information
• The specific pieces of personal information collected about the consumer

2. Right to Deletion

Consumers have a right to request the deletion of personal information that the business holds on the consumer. However, this right does not apply where the business needs to retain the personal information in order to do any of the following:

• Provide goods or services to the consumer
• Detect or resolve issues security or functionality-related issues
• Comply with the law
• Conduct research in the public interest
• Safeguard the right to free speech
• Carry out any actions for internal purposes that the consumer might reasonably expect

3. Right to Non-Discrimination

Consumers have the right not to be discriminated against for having exercised their rights under the CCPA. In particular, the business may not:

• Deny the consumer goods or services
• Charge the consumer different prices for goods or services, whether through denying benefits or imposing penalties
• Provide the consumer with a different level or quality of goods or services to the consumer
• Threaten the consumer with any of the above

To exercise the CCPA consumer access, portability or distribution rights described above, please submit a verifiable complaint by either:

• Calling us at number (866) 819-5840 or
• Emailing us at privacy@platformeleven.io.

Only you or a person registered with the California Secretary of State who you authorize to act on your behalf may file a valid complaint. You may also make a verifiable complaint on behalf of your minor child.

Consumers may only request access or data portability twice within a 12 month period. The verifiable complaint must contain:

• Sufficient information to allow us to verify that you are the person under the complaint;
• Describe your request in sufficient detail to allow us to understand, verify and respond to your request.

We will only use the personal information provided with the consumer request to verify the consumer’s identity (compliant).

Important Notice to European Union Individuals: The General Data Protection Regulation

To facilitate our business practices, your Personal Data may be collected, transferred to and stored by Eleven in the United States. As a result, your Personal Data may be processed outside the EEA, and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection in the EEA. In this event, we will ensure an adequate level of protection, for example by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

If you are a visitor from the EU, EEA or UK jurisdictions our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

For European or UK Data Subjects you may have the following right with regard to all Personally Identifiable Information as defined in the EU General Data Protection Law or UL Privacy Act:

1. The right to be informed about our collection and use of your personal data;
2. The right of access to the personal data we hold about you (please contact us using the details set forth below);
3. The right to correct any personal data we hold about you if it is inaccurate or incomplete (please contact us using the details set forth below);
4. The right to be forgotten (i.e., the right to ask us to delete your personal data);
5. The right to restrict (i.e., prevent) the processing of your personal data;
6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organization); and
7. The right to object to our use of your personal data for particular purposes. In certain circumstances we may not be able to stop using your personal data, if that is the case, we’ll let you know why.

If you have any cause for complaint about our use of your personal data, or have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the details set forth below and we will do our best to solve the problem for you.

GDPR Complaints

Eleven commits to resolve complaints about your privacy and our collection or use of your personal information under GDPR. European Union, United Kingdom and Swiss individuals with inquiries or complaints should use our Data Subject Access Rights portal to submit complaints about your privacy and our collection or use of your personal information.

Alternative means of contact:

• If the Eleven DSAR portal is unavailable, requests can be sent to privacy@platformeleven.io.

Link to EU Data Protection Authorities: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

Contact us

If you have any questions or comments about this Privacy Policy, or if you would like to review, delete or update information we have about you or your preferences, requests should be submitted through our Data Subject Access Request (DSAR) Portal. If the Eleven DSAR portal is unavailable, requests can be sent to privacy@platformeleven.io.

Updates to our privacy statement

This Privacy Policy may be updated periodically and without prior notice to reflect changes in our online information practices. We will post a prominent notice on this Website to notify you of any significant changes to our Privacy Statement and indicate at the top of the statement when it was most recently updated.