Privacy Policy - Eleven

Last modified: July 29, 2020

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 members.

We are a cloud-based customer engagement platform for the global private investment industry. Eleven allows fund managers to build highly engaged, secure, loyal communities of clients. It enables fund investors to access, analyze, research and monitor more information about private investments for making smarter, more tailored investment choices. It offers wealth managers, RIAs, third party marketers, prime brokers and fund administrators custom branded marketplaces to amplify growth.

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 (the "Site") 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 Site and Services represents your consent to this Privacy Policy and the Terms of Use. Please do not access or use the Site or register as a Member of the Site 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 for updates.

Collection of personal information

We employ 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 Site’s application and other forms or postings on the Site; 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 Site’s contact features).

In addition, when you visit our Site, 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 Site 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. We make no representation or warranty with respect to any duty to permanently store any personal information you may provide.

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


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 site. 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 Site.

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 Site. 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 Site.

Internal use of Web Beacons. Eleven 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 Site.

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 Site.

How we use personal information

We collect and maintain personal information for the purposes of identifying you; approving your membership application and maintaining your membership status; processing your payment for membership; contacting you with regard to your application, membership status or account; responding to inquiries from you or your representative; improving and customizing the content you see on the Site; 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 site) for improving our marketing and promotional efforts; statistically analyzing site 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 Members when you upload content or send messages through the Site. Notwithstanding the foregoing, you specifically represent and warrant that you will also respect the privacy of information in the Site and not make public any information in the Site. You expressly acknowledge and understand that the information in the Site is private and solely and strictly intended for the members of the Site and that the security of all information in the Site is crucial for the overall functioning of the Site.

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 Site 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 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. Therefore, we cannot promise, and you should therefore not expect, that your personally identifiable information or private communications would always remain private. Nonetheless, we will use reasonable commercial and legal efforts to protect our Members’ 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 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 Site and Services. Any person, party or entity that does not have an authorized user account is strictly forbidden from entering the Site and/or viewing Member-only "private" information. 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, Members agree to not share their username and password with anyone and agree to keep confidential all information and content on the Site.

Encrypted information

There are areas on the website where you may enter and submit information. Some of 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 Site may include links to other websites, which are provided for your convenience, and other sites may also reference or link to our Site. We do not review, control or monitor the privacy practices operated by others and we are not responsible for any aspect of these sites 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.

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

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

California Consumer Privacy Act

On January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) took effect, and sets new requirements and rights relating to personal information of California consumers. Click here for more details on Eleven and the California Consumer Privacy Act.

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

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.