Information Collection Overview
We explain here what categories of personal information we have collected in the past 12-month period, or are likely to collect in the future, the source of that information, what we do with it, and with whom we have or would share it:
- Category of Personal Information Collected – Contact Information: Including name, address, and phone number.
- Source: Investors and prospective investors provide us with this information when they visit the Site, call us, email us, or otherwise interact with us.
- Purpose for Collection: To communicate with and to help us improve our services to you; to provide you with the products and services you have requested; to inform you about additional products or services that may be of interest to you; for marketing purposes; and for other internal and legal obligation purposes.
- Categories of Recipients: We may share this information with third party companies to help us deliver services, including but not limited to, technical support, analytics, and advertising services. We may also occasionally hire companies to provide limited services on our behalf including: packaging; mailing and delivering purchases; answering customer questions about products or services; sending mail; and processing event registration. We provide these companies with only the information they need to deliver their service and they are prohibited from using that information for any other purpose.
- Category of Personal Information Collected – Professional/Employment Information: Such as company name and category of employment.
- Source: Users may provide company name or to indicate broad employment categories as part of client information.
- Purpose for Collection: To verify users’ identities and qualifications to invest in Lockstep funds, if applicable.
- Categories of Recipients: We may share this information with third party companies to help us deliver services, including but not limited to, data storage, technical support, and analytics.
- Category of Personal Information Collected – Browsing Information: Such as your IP address, MAC address or other device identifier, the kind of browser or computer you use, pages and content that you visit on the Site, what you click on, the state and country from which you access the Site, date and time of your visit, and web pages you linked to our Site from.
- Purpose for Collection: To evaluate usage of the Site and improve performance and user services; to protect the security and integrity of the Site and our business, such as preventing fraud, hacking, and other criminal activity or to meet legal obligations.
- Categories of Recipients: Our service providers who help us with fraud protection and website analytics.
In some jurisdictions, individuals may have the right to opt-in or withdraw consent for certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed below, “Access, Correction and Deletion.”
In Connection with Business Transfers: In the event that a division, a product or all of Lockstep is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.
To Comply with Laws: Lockstep may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our clients, employees or others, in accordance with or as authorized by law.
You can opt-out of receiving communications from us by following the instructions contained in the messages you receive. Even if you opt-out of receiving these messages, we reserve the right to send you certain communications relating to the services we provide, and we may send you service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those communications. For more information about interest-based advertising, including how you can manage advertising, please see below “Interest-Based Advertising.”
Information We Collect Automatically
When you visit the Site, we may collect certain information from you, including your Internet Protocol (IP) address, MAC address, browser type, operating system, device-identifying information, the specific web pages visited during your connection, and the domain name from which you accessed the Site. In addition, we may collect information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Site and other clickstream data. We may also use non-personal or aggregated information for statistical analysis, research, and other purposes.
We may also use web beacons on the Site, in our emails, and in our advertisements on other websites, however we do not allow third party advertisements on the Site. Web beacons are tiny graphic images that are used to collect information about your visit to the Site, such as the pages you view and the features you use, as well as information about whether you open and/or act upon one of our emails or advertisements. We may also collect the URL of the website you visited immediately before coming to the Site. Web beacons help us analyze our Site visitors' behavior and measure the effectiveness of the Site and our advertising. We may work with service providers that help us track, collect and analyze this information.
Lockstep may use Google Analytics to evaluate use of the Site for our internal purposes such as evaluating usages of the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.
We may combine the information we collect through cookies and web beacons with other information we have collected from you or information from other sources.
We may use third-party advertising companies that use tracking technologies to serve our advertisements across the Internet. These companies may collect information about your visits to the Site and other websites and your interaction with our advertising and other communications. These advertising companies serve ads on behalf of us and others on non-affiliated sites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to the Site and elsewhere over time. Other companies may also use such technology to advertise on the Site.
You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in. If you would like more information about this practice and to know your choices concerning interest-based ads, visit:
- In Canada, please visit: http://youradchoices.ca/choices/
- In the EU, please visit: http://www.youronlinechoices.eu/
Access, Correction, & Deletion
We respect your right to access and correct your personal information. You may access your personal information by signing into your account. From there, you can correct or modify your information. You may also exercise your rights, subject to applicable laws, to request that we delete or restrict access to your personal data. We may need to retain it for legally permitted purposes and this will be explained to you if necessary.
If you need assistance correcting or updating your personal information, or would like to request that we delete your personal information, please contact us using the contact information detailed in the “How to Contact Us” section below.
Retention of Personal Information
Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided in agreements between you and Lockstep or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made de-identified.
Lockstep has implemented a number of security features throughout the Site to prevent the unauthorized release of or access to personal information. For example, database information is kept separate from live servers and is firewall protected. Please be advised, however, that although Lockstep has endeavored to create a secure and reliable site for you, the confidentiality of any communication or material transmitted to or from Lockstep via the Site or e-mail cannot be guaranteed. When disclosing any personal information, you should remain mindful of the fact that it is potentially accessible to the public and consequently, may be collected and used by others without your consent. Lockstep has no responsibility or liability for the security of information transmitted via the Internet.
The Site is not directed to children, nor do we knowingly collect any personal information from children under the age of 13 without verifiable parental consent. If you believe that a child has provided personal information to us, please contact us promptly as described below, and we will endeavor to investigate and delete such information from our systems.
Third Party Websites
Your California Privacy Rights
If you are a California resident, California law may provide you with the following rights with respect to your personal information:
- The right to know the categories of information or the specific information we have collected, used, disclosed and sold about you. To submit a request to know, you may email us at [INCLUDE EMAIL CONTACT]. You also may designate an authorized agent to make a request for access on your behalf.
- The right to request that we delete any personal information we have collected about you. To submit a request for deletion, you may email us at [INCLUDE EMAIL CONTACT]. You also may designate an authorized agent to make a request for deletion on your behalf.
When you exercise these rights and submit a request to us, we may verify your identity by asking you for information such as your email address, telephone number, and/or information about your account with Lockstep. We also may use a third-party verification provider to verify your identity. Lockstep will endeavor to honor users’ requests unless such a request conflicts with certain lawful exemptions under the California Consumer Privacy Act of 2018. Please note that Lockstep is only required to honor such requests twice in a 12-month period.
Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.
Visitors from Outside the United States – Cross-Border Transfer
Right to Lodge Complaints
We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.
How to Contact Us