LQS PRIVACY POLICY
Last Updated: January 18, 2024
This Privacy Policy describes how LAB Quantitative Strategies, LLC (“LQS”), and our subsidiaries and affiliated companies (collectively, “LQS,” “we,” or “us”) collect, use, and disclose information about you. This Privacy Policy applies to information we collect when you access or use our websites and other online products and services at www.lab-qs.com (collectively, our “Services”), or when you otherwise interact with us, such as through our support channels or on social media pages. We may provide different or additional notices of our privacy practices with respect to certain products or services, in which case this Privacy Policy may not apply.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with additional notice (such as by adding a statement to the Services or sending you a notification), such as in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
It is our policy not to disclose any non-public personal information about those of you who are individuals, except to our affiliates servicing your account (including those who are involved in the operation, administration or management of, or the sale of interests in, the Partnership) and non-affiliated service providers as allowed by applicable law or regulation or in response to inquiries from governmental authorities. In the normal course of serving you, the information we collect may be shared with companies that perform various services such as investment advisers, accountants, attorneys, administrators, custodians, broker-dealers and marketing service firms. Specifically, we may disclose to these service providers non-public personal information including:
If you are a California resident, please see the additional “California Privacy Information” section.
CONTENTS
Notice of Collection of Information
Transfer of Information to the United States and Other Countries
California Privacy Information
NOTICE OF COLLECTION OF INFORMATION
The information we collect from you varies depending on the way you interact with us and our website. When you engage or simply browse on our public website as a consumer to learn more about us (“Consumer”), the information we collect and use is different from the information we collect if you are a LQS investor or commercial business client (“Investor”) and interact with us in a commercial capacity to purchase one of our products or services. Below, we describe the different ways we might collect information from you.
Consumer
LQS provides commercial products and services to other businesses, and so, we do not engage with Consumers in their personal capacity. Consumers, however, can browse our website, and so we may collect internet or other electronic network activity information from you when on our website, but any forms or information we collect are limited to those interacting with us in their professional capacity through their company or business, and Consumers do not provide their personal information to us.
Investors
If you are an Investor, we collect certain personal information from you and/or your authorized users in order to facilitate our business relationship with you and provide you our commercial products and services (collectively, “Investor Information”). The Investor Information we may collect from you and/or your authorized users includes:
| Categories of Personal Information | Examples of Personal Information Collected |
|---|---|
| Identifiers and California Customer Records | Name, business name, job title, email address associated with your business, postal and billing address, phone number, IP address |
| Commercial information | Records of products or services purchased, obtained or considered, or other purchasing or consuming tendencies |
| Internet or other similar network activity | Browsing history, search history, information on a consumer's interaction with a website, application, email, or advertisement, including access times, pages viewed, links clicked, and the page you visited before navigating to our Services; IP address, device identifiers, browser type; information collected by tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services |
| Professional or employment-related information | Company name, job title |
| Inferences | Information we derive about your preferences from collected personal information, including services you may be interested in |
| Sensitive Personal Information | Precise Geolocation |
Information We Collect from Other Sources
We obtain information from other sources. For example, we may collect information from identity verification services, referral sources, and any other third party sources of information. This information includes name, email address, and job title.
USE OF INFORMATION
We use the information we collect to provide you with the appropriate services and products. We also use the information we collect to:
- Provide, maintain, improve, and develop new products and services, including to process subscription and withdrawals from funds and provide you with required disclosures and statements;
- Debug and repair errors in our Services;
- Personalize your experience with us;
- Provide you with waivers and other relevant agreements;
- Send you technical notices, security alerts, support messages, and other transactional or relationship messages;
- Communicate with you about products, services, and events offered by LQS and others and provide news and information that we think will interest you;
- Monitor and analyze trends, usage, and activities in connection with our products and services;
- Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of LQS and others;
- Comply with our legal and financial obligations;
- Create de-identified, anonymized, or aggregated information; and
- Carry out any other purpose described to you at the time the information was collected.
DISCLOSURE OF INFORMATION
We disclose personal information in the following circumstances or as otherwise described in this policy:
- We disclose personal information to vendors that access personal information to perform work for us, such as companies that assist us with fund administration, fund auditing, web hosting, fraud prevention, customer service, and marketing and advertising.
- We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of LQS, our users, the public, or others.
- We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal information is disclosed between and among LQS and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
- We disclose personal information with your consent or at your direction.
We also disclose aggregated or de-identified information that cannot reasonably be used to identify you.
ANALYTICS
We engage others to provide analytics services. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by LQS and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.
TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES
LQS is headquartered in the United States and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law.
YOUR CHOICES
You may update and correct certain information about you or ask us to delete certain information by sending an email to [email protected], but note that we may retain certain information as required by law or for our legitimate business purposes.
COOKIES
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
CALIFORNIA PRIVACY INFORMATION
The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.
California Consumer Privacy Act
Disclosure of Personal Information
In the preceding 12 months, we have disclosed the following categories of personal information for business purposes described above in the Disclosure of Information section to the following categories of recipients:
| Category of Personal Information | Categories of Recipients |
|---|---|
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California Sales and Sharing of Personal Information
California law requires that we provide transparency about personal information we “sell” or “share.” “Sale,” for the purposes of the CCPA, broadly means scenarios in which we have disclosed personal information with partners in exchange for valuable consideration, while “sharing” means we have disclosed information to a third party for cross-context behavioral advertising. In addition, the CCPA has been interpreted to deem this “sharing” to also be a form of “sale.” In the preceding twelve (12) months, LQS has not “sold” or “shared” your personal information to or with third parties for cross-context behavioral advertising, such as targeting of advertising to you based on your personal information obtained from your activity across businesses, websites, apps, and services other than our Services.
We do not knowingly sell personal information about consumers under the age of 16.
Privacy Rights
Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request correction of your personal information, (3) request deletion of your personal information, and (4) not be discriminated against for exercising these rights. You may make these requests by calling (720) 826-0771 or sending an email to [email protected].
If we receive your request from an authorized agent and they do not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may also require you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request. If you are an authorized agent seeking to make a request, please contact us at [email protected].
CONTACT US
If you have any questions about this Privacy Policy, please contact us at [email protected].