Privacy Policy

DESTINY HEREBY ADOPTS AND INCORPORATES, BY REFERENCE, THE TERMS OF USE OF ITS SUBADVISOR, MARSTONE, AS SET FORTH BELOW, WITH RESPECT TO DELIVERY OF DESTINY DIGITAL PLATFORM AND SERVICE.

DATE APPROVED: June 26, 2017

We are committed to maintaining the confidentiality, integrity, and security of personal information collected from our advisory clients and users. The privacy practices of this statement apply to services from Marstone Inc. available under the domain destinydigital.marstone.com (the "Website"). “We” or “us” shall, at all times, mean and refer to Destiny and Marstone, Inc. By visiting this Website you agree to be bound by the terms and conditions of this policy (“Privacy Policy”). This Privacy Policy describes the information, as part of the normal operation of our services, we collect from you, and what may happen to that information. By accepting the Privacy Policy and the Client Agreement in registration, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Terms of Use Agreement.

For the purpose of this agreement, a User is an individual who uses our website or mobile application to evaluate our service, or for educational purposes, and a Client is an individual or entity who signs our Advisory Agreement that entitles the Client to have their investment portfolio managed or subadvised by Marstone. This Agreement, as well as the Terms of Use, applies to both Users and Clients.

1. USER GENERATED CONTENT

What information do we collect?

  • Information relevant to your computer or mobile device, such as the type of device you from which are logging in, the server from which you login, the IP address from which you log-in, and other types of anonymous information when you visit the Website and become a Client.
  • Personal and financial information provided or accessed when you register and become a client.

Why do we collect it?

  • We are not only a technology provider, but also a registered investment advisor for our clients. We are required by law to collect and maintain certain information pursuant to U.S. law.
  • We collect your personal information to maintain your Website account, and to provide and enhance our customer service service and experience.
  • To improve your experience, we aggregate your personal information and perform certain analysis and reporting. This analysis could include identifying trends including those of tribal identities and investment for both internal and external purposes. When we aggregate this information, we ensure that the information is not identifiable to any single client.

Definitions

Anonymized- to make anonymous. In other words, no one can figure out who you are with the information provided.

Aggregated- combining several elements to form a whole. Basically, we combine all of the content to form a whole bunch of data that cannot be traced back to any single individual.

Using your data:

  • We use your data to operate and maintain your account in conformance with with US law and regulations;
  • We perform analytics and investigate and understand how the Website is used;
  • We use your data to monitor and protect the security and integrity of the Website;
  • We use the analytics performed on the Website to better serve you and to market products and service;
  • If required by law, such as a court order, subpoenas, or summons, we may disclose personal information;
  • We may use your data if we determine it is necessary to investigate, prevent, or take other action regarding illegal or violative activities, or to prevent suspect fraud, front-running or scalping situations, or other potential threats to the physical safety of any person, account or to prevent violations of our Privacy Policy or Client Agreements;
  • We will use User Information and Content to provide you with information and services, to customize your experience on the Website and to inform you about other products and services; and
  • We also aggregate and use User Information and Content, without any identifying information, to understand how our products and services are used, to deliver our products and services and to help us develop and innovate.

Third Parties

  • We do not sell, rent, or trade your personal information with any third- parties unless required by law;
  • We may share your personal information with identification verification services, e-signature providers and account aggregation services, all to serve you as a customer;
  • We may use third parties service providers to perform analytics and marketing services on your behalf; and
  • If this is the case, we may disclose some personal information, aggregated and anonymized.

All of these above-referenced firms have entered into agreements that require that third parties to keep this personal information anonymized and confidential.

What if we close or are sold?

Information about our users, including personal information, may be disclosed or transferred to entities now or in the future affiliated with us or as part of any merger, acquisition, change of control, debt financing, insolvency, bankruptcy or sale of our assets. Such information may be used in the businesses of any entity so receiving it. We may disclose personal information in specific other cases with your consent.

Analytics Services

We reserve the right to use analytics services, such as Google Analytics, to collect information about the usage of this Website. This analytics service collects information relevant to your computer, such as what type of device you are logging in from, the server from which you login, the IP address from which you log-in, and other types of anonymous information when you visit the Website and become a client. We only use the information we get from these analytics services to improve this Website and the services we provide to you through the Website.

These analytics services only collect the IP address assigned to you on the date you visit this Website, not your name or other identifying information. The Google Analytics Services or other similar services’ ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies. We will never combine the information collected from this service with the content you upload to the Website as a client.

You can prevent analytics from recognizing you on return visits to this Website by disabling cookies on your browser. You can opt out of analytics by installing the Google Analytics Opt-out Browser Add-on or similar opt-out functionality.

2. HOW YOU ACCEPT THIS POLICY

By using the Website, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this Privacy Policy.

3. CHANGES TO YOUR PERSONALLY IDENTIFIABLE INFORMATION

Once you have registered with the Website, you can access your profile, review the information that is stored and revise some of that information. If you have problems, you can always contact service@destiny-digital.com. Due to U.S. regulatory requirements, we do not delete residual copies of outdated information and must preserve all consumer data for a minimum of three (3) years.

If you wish to access or change the personal information that you have submitted to us or to request the correction of any inaccurate information you have submitted to us, you may correct certain information via the Website. Alternatively as a Website account holder, to request any corrections to your personal information, you can send an email that includes your contact information to service@destiny-digital.com

4. DELETING YOUR INFORMATION

We believe that your data belongs to you, and therefore, you may request deletion of your personal information at any time that you choose. To request that your account be deleted, please contact us at service@destiny-digital.com. We will remove your information as soon as reasonably practical, however we may retain and archive such account information as required by applicable laws or regulations. Despite such removal, portions of your data may remain on our production and backup servers indefinitely.

5. AS A VISITOR

We collect various types of anonymous information about visitors to the Website, such as device-related information (browser type, IP address) and server log information (date and time you visited). We collect information that you input into our website and use this information to better understand our visitors and business, all to bolster the Website Service.

6. CHANGES TO OUR PRIVACY POLICY

Please review this Privacy Policy as we regularly re-evaluate our privacy and security policies and update this Privacy Policy periodically as necessary to deal with new challenges. The date last revised appears at the top of the Policy and changes take effect immediately upon posting. You agree to accept electronic communications and/or postings of revised versions of this Privacy Policy on destinydigital.marstone.com and agree that such electronic communications or postings constitute notice to you of the revised version of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you here, by email or by posting a notice on our home page.

7. EMAIL OPT OUT

Our Website complies with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (CAN-SPAM). We may provide users with periodic website related notifications, marketing offers, or other information via email. You may elect to stop receiving such messages at your discretion by updating your account preferences on the website or through your Website account. You may also follow the unsubscribe instructions included in each promotional email. Please note that certain email messages we send users are necessary for the proper functioning and use of services available through our website, and users who participate in such services do not have the ability to opt-out of such email messages.

8. CHILDREN'S ONLINE POLICY

The features, services, and other aspects of the Website requiring the submission of personally identifiable information are not intended for anyone under 18 years of age. We do not knowingly collect personally identifiable information from children under the age of 13 without parental consent. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us please contact us at service@destiny-digital.com

9. SOCIAL MEDIA

This Privacy policy and these terms apply to Website-operated services and applications. This Site may contain links that access other websites and apps that are not operated or controlled by us. The policies described herein do not apply to third party websites or applications.

10. QUESTIONS AND CONCERNS

If you have questions or concerns regarding this Privacy Policy, or if you have any questions, comments or feedback, please contact us at service@destiny-digital.com.

For more general information regarding privacy you can visit the Federal Trade Commission which offers an overview of privacy protection.

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