Legal · Version 1.0 · Not yet in effect
Privacy Policy
This policy explains how Common Ridge LLC ("we", "us") handles personal information in Common Ridge and on this website.
1. Our role
For investor and fund data, the fund manager decides why and how personal information is used. We process it on the fund manager's behalf as a service provider, under the Data Processing Addendum. For visitors to this website, for our own account and billing records, and for security of the service, we decide how information is used and act as the controller.
2. Information we handle
- Account information: name, email address, sign-in credentials such as passkey public keys, device and session details.
- Investor information provided by fund managers or by you: entity details, contact details, addresses, tax identification numbers, dates of birth, identity documents, accreditation information, bank account details, commitments, transactions, documents and signatures.
- Verification information: results from identity and sanctions screening providers.
- Usage and security information: IP address, browser and device type, pages and actions, and audit records of sensitive actions.
- Website information: details you submit in a form, and limited technical information from your visit.
Sensitive fields such as tax identification numbers, bank account numbers, dates of birth and identity document numbers are encrypted individually in our systems.
3. How we use it
To provide and secure the service, authenticate you, deliver documents, process payments you authorize, meet legal obligations, respond to you, and improve the service using aggregated information. We do not sell personal information and we do not use investor information for advertising.
4. Who we share it with
- The fund manager whose funds you hold.
- Subprocessors that help us run the service, listed on our Subprocessors page.
- Professional advisers, and authorities where the law requires.
- A successor, if we are part of a merger or sale, subject to this policy.
We do not share one fund manager's information about you with another.
5. Where it is stored
Customer data is stored in the United States.
6. How long we keep it
We keep information for as long as the fund manager's workspace needs it and as the law requires. Audit records and document access records are kept for seven years. Sign-in event records are kept for two years. Request logs are kept for 90 days. When a workspace ends, data is deleted after 30 days, except financial and audit records that must be kept, where personal information is made unreadable by destroying the encryption key.
7. Your choices and rights
Depending on where you live, you may have rights to access, correct, delete or export personal information, and to object to or restrict some uses. Because the fund manager controls investor data, we may direct a request to the fund manager. Contact us at support@commonridge.com. We will not treat you differently for using your rights. [Counsel to confirm: state-law notices, including California, and any international transfer language.]
8. Security
We protect information with the controls described on our trust page, including encryption in transit and at rest, access controls, tenant isolation and audit logging. No system is perfectly secure.
9. Children
The service is not directed to children and we do not knowingly collect their information.
10. Changes
We will post changes here with a new version and effective date, and tell account holders of material changes.