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Delphia Privacy Policy

Privacy Policy

Delphia is an ethical user of personal data. The security of your personal data is important to us.

We've tried to make this Privacy Policy as easy to read as possible. If anything below is unclear, please contact us at privacy@delphia.com, and we'll be happy to clear it up.

What this notice covers

As an organization that uses personal data, Delphia is responsible for collecting and using your data in a responsible, safe, and ethical way. That starts with clearly telling you how we collect, use, and protect your personal data.

This Privacy Policy sets out:

As an organization that uses personal data, Delphia is responsible for collecting and using your data in a responsible, safe, and ethical way. That starts with clearly telling you how we collect, use, and protect your personal data.

Demographic information such as your age, gender, and general economic information;

Your account login details, which will be your email;

Device and browser "metadata" (this is basically an audit trail of your device and browser use) including:

  1. IP address

  2. The make, model, and operating system of the device you have used

  3. Browser type

  4. We track location for the purpose of performance analytics.

Why does Delphia collect your personal data?

We use personal data to:

Register, authenticate, and administer your account;

Develop and improve our services;

Respond to you if you make a user access request;

Detect and prevent fraudulent activity.

Execute your payment for Platform services;

Pay you directly for services provided by you through the Platform

We will never use one of these data categories for another purpose without asking for your consent first. For more information on how we use Cookies, please refer to our Cookie Policy.

Our service providers

We work with trusted service providers that carry our certain functions on our behalf so we can provide our services to you.

These organizations process data on our behalf. They only have access to the personal data that they absolutely need to provide a specific service to us, and in all cases we have contractual safeguards in place to ensure that they do not disclose or use it for any other purposes. In some cases, these organizations (for example, our payment processors) may need to process your personal data for their own specific purposes, for example to ensure that they are compliant with regulations or laws governing their own sectors.

When you visit our website(s), we use the following third party services which may either collect personal data or be a vendor that we share data with:

the Google Cloud Platform

MixPanel

Google Analytics

Facebook Pixel

Twitter Universal Website tag

Sendgrid

Snap Pixel

Apex Clearing Corp

Alpaca Securities LLC

Intercom

Branch

Crazy Egg

Sentry

Fivetran

Our service providers fall within the following categories (and process your data in the following locations):

Data collection technology providers (EEA, USA)

Cloud data storage (EEA, CAN)

Data center storage (EEA, CAN)

Communications platforms and technologies (EEA, USA)

These circumstances are unusual, but we may share personal data with other organizations if:

We have to share your information to comply with legal or regulatory requirements (or we reasonably believe that we need to disclose your information for such purposes);

We need to share personal data in order to establish, exercise or defend our legal rights, including with our legal and other professional advisers;

We restructure our business or if we buy or sell any business or assets we may share your data with the prospective buyer or seller on a strictly confidential basis;

All or substantially all of our company assets are acquired by another party, your data will be one of the transferred assets.

If you don’t want us to make use of your personal data in any of the ways described above, sharing your data with Delphia and using our services is not for you – you can ask us to remove your data.

Depending on the service(s), if any, you use, we may have to retain some of your personal information for legal or regulatory compliance reasons. Please speak to us directly at privacy@delphia.com for details on our document retention policy.

Legal grounds for processing your personal data

Delphia is committed to the lawful, fair, and transparent use of personal data. For every use of your personal data we have described so far, we process your personal data on the grounds that our processing is necessary for legitimate interests we pursue as a business.

If you have any questions about the grounds under which we process your personal data, or would like to find out more about the approach we take to determine that these grounds apply, please contact privacy@delphia.com.

How we store and protect your personal data

We know how important it is to protect your personal data while we have it. This section describes some of the measures we take to ensure that it is kept secure.

We do everything we can to protect your personal data from loss or misuse, and from unauthorized access, disclosure, alteration and destruction. This section describes some of the measures we take to ensure that your personal data is secure:

We use data centers that have a high level of physical security measures to host and protect your data and our systems.

We conduct independent penetration tests and are continuously scanning our systems and applications for vulnerabilities. If you ever think that you have found a security issue or vulnerability in one of our systems please let us know at security@delphia.com. If you would like to encrypt your email with GPG, please use this key.

We use encryption to secure your personal data both in transit on the network and at rest in storage.

We allow access to attributable data (by which we mean data that directly identifies you) only to those Delphia employees who need it to carry out their job responsibilities. For example, our support team need to access some attributable data so they can respond to you when you contact us.

We make security the responsibility of all our employees and we train our staff to identify security risks and protect your data.

Our website may from time to time contain links to and from other websites. If you follow a link to any of those websites, please note that those websites ought to have their own privacy notices and that we do not accept any responsibility or liability for those websites. Please check those privacy notices before you submit your information to those websites.

Data Connections

When you agree to connect your data personal data to the Platform (a "Data Connection"), you become a "Contributor" and are agreeing to allow us to access, store and use the information we collect from the Data Connection (your "Contributed Data").

Delphia uses your Contributed Data to develop research about trends and help Delphia (USA) Inc. make better investment decisions.

Delphia will never share your Contributed Data including data that contains personal information, such as your email address, IP address, name, photo, phone numbers, postal addresses (for example, if it is included in your shipping information) with any users, Contributors or investment products. Contributed Data is collected by us for the purpose of creating anonymized research and our users, Contributors, and investment products are restricted to using Contributed Data for that sole purpose. Once anonymized, any users, Contributors or investment products that use these reports are prohibited from attempting to re-identify you or use the information we share for any purpose other than creating aggregate reports and understanding market trends.

Connect Email

  1. If you agree to connect your email account(s) to the Platform, we will identify e-commerce trends (based on anonymized and aggregated data from email receipts) which Delphia Technologies Inc. will use to help Delphia (USA) Inc. make better investment decisions.

  2. We will never share your emails, personally identifiable information, contacts or messages with third parties, unless required by law.

  3. For more details on how Delphia and Nylas connect to your email account(s), please refer to Terms + Conditions for Email Connections.

Connect Bank Accounts

  1. If you agree to connect your bank account(s) to the Platform, we will identify e-commerce trends (based on anonymized and aggregated data from your and other Contributors' banking transactions) which Delphia Technologies Inc. will use to help Delphia (USA) Inc. make better investment decisions.

  2. Your banking activity gives Delphia insights into purchase intent and buying behaviour.

  3. Your banking activity data is subject to strict controls. Delphia is limited to viewing transactions and never has access to your bank accounts.

  4. Your banking transaction data is always encrypted and is never shared with third parties.

  5. For more details on how Delphia and Plaid connect to your bank accounts, please refer to Terms + Conditions for Banking Data.

Connect Twitter

  1. If you agree to connect your Twitter account to the Platform, we will identify social media trends which Delphia Technologies Inc. will use to help Delphia (USA) Inc. make better investment decisions.

  2. Delphia Technologies Inc. learns about the kinds of things you post publicly on Twitter, and will use that info to ask you more valuable questions in the future.

  3. We will not: (a) post anything to your Twitter account; (b) make your information public, or do anything in respect of your Twitter account without your permission.

How to contact us

If you have questions about this notice, or about how we collect, store and use personal data, you can contact our Data Protection Officer.

Email: privacy@delphia.com

Mail: The Data Protection Officer Delphia Technologies Inc. Suite 300, 501 Queen St W, Toronto, Ontario, Canada, M5V 2B4

Updates to this notice

This notice was last updated on the date that appears at the end of the notice.

We reserve the right to change this notice at any time.

Effective: August 6, 2020

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Delphia (USA) Inc. is registered as an investment adviser under the Investment Advisers Act of 1940 and uses Goldman Sachs & Co. LLC as its broker-dealer and custodian for the private funds. Goldman Sachs & Co. LLC is registered with the Securities Exchange Commission (SEC) as a broker-dealer and an investment advisor and is a member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). Delphia (USA) Inc. serves as the investment manager with discretionary trading authority to United States and Cayman-domiciled private pooled investment vehicles, the securities of which are offered to Fund Investors on a private placement basis. Investment in Delphia Cayman Master Fund (the Fund) is not suitable for all investors. For more details, see our Firm Brochure. Other charges and fees may apply. Registration of an investment adviser does not imply any specific level of skill or training and does not constitute an endorsement of the entity by the Securities Exchange Commission. The opinions and predictions expressed on this website represent the current, good faith views of Delphia (USA) Inc. along with its affiliates (collectively, “Delphia”) at the time of publication and are provided for limited purposes, and are not definitive investment advice. Predictions, opinions, and other information on this website are subject to change continually and without notice of any kind and may no longer be true after the date indicated. By using this website, you accept our Terms of Use and Privacy Policy. Delphia is carrying on the business of, or registered and authorized to, provide investment advice only in the jurisdictions where they are lawfully authorized. Delphia is neither a law firm nor an accounting firm, and no portion of the website should be interpreted as legal, accounting, or tax advice.

Past performance is not indicative of future results. Diversification does not ensure a profit or guarantee against loss. No material available through the website shall be used or considered as an offer to sell or a solicitation of any offer to buy the securities or services of any of our affiliated entities. Offers can only be made where lawful under, and in compliance with, applicable law. Please remember that different types of investments involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment or investment strategy (including those undertaken or recommended by Delphia), will be profitable or equal any historical performance levels. Investments discussed on the website, if any, may not be suitable for all investors. Investors should make their own investment decisions based upon their own financial objectives and financial resources, and should obtain independent investment and tax advice before deciding to invest. Graphs, charts, tools, and graphics are used for illustrative purposes only, and may not reflect actual future performance. The contents on this website are provided for limited purposes, and should not be considered as a definitive investment advice. Delphia does not guarantee any minimum level of investment performance or the success of any investment strategy. As with any investment there is a potential for profit as well as the possibility of loss. This website contains certain “forward-looking statements,” which may be identified by the use of such words as “believe,” “expect,” “anticipate,” “will,” “should,” “planned,” “estimated,” “potential” and other similar terms. Examples of forward-looking statements include, but are not limited to, estimates with respect to financial condition, results of operations, and success or lack of success of Delphia (USA) Inc.’s investment strategy. All are subject to various factors, including, but not limited to general and local economic conditions, changing levels of competition within certain industries and markets, changes in interest rates, changes in legislation or regulation, and other economic, competitive, governmental, regulatory and technological factors affecting Delphia’s operations that could cause actual results to differ materially from projected results. Any links provided to other websites are offered as a matter of convenience and are not intended to imply that Delphia or its authors endorse, sponsor, promote, and/or are affiliated with the owners of or participants in those sites, unless stated otherwise. Please see our Terms of Service governing the use of this website.