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This Privacy Policy (this “Privacy Policy”) describes how PRV Asset Management LLC; other company names used by us and our affiliates (together referred to as “PRV”, “we”, “us”, or “our”) handles and secures information we collect through our Websites at www.prvasset.com, (“Website”) relating to our products and services (“Services”). For the purpose of this Privacy Policy, “you” or “User” means the individual user of our Services and / or a visitor to our Website. In addition, please review the terms of the user agreement governing any Services you receive from us, which governs your use thereof. By using our Services, you consent to our Privacy Policy and our Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below. If you have entered into a user agreement for our Services (your “User Agreement”), it will supplement and amend the Terms of Use. Because the Terms of Use and your User Agreement include subjects that may not be covered in this Privacy Policy, and may narrow or modify the scope of our use of information under this Privacy Policy, please review them each carefully. If you do not agree to the terms of this Privacy Policy, please do not provide us with any personal information and do not use our Website or Services.
When you use our Website or Services, you can (depending on the Services you use) submit information by way of the following:
Our Website also gathers information whenever you visit, log in or otherwise interact with us. As with other Websites and interactive services, whenever you interact with our Website, your computer, mobile phone or tablet and its software (a “Device”) transmits a “request” to us. That request includes information received from your Device necessary for us to identify and appropriately route the information your Device is requesting. These “requests” and “replies” are present on all Websites and Internet services. Therefore, whenever you:
Our Website also gathers information whenever you visit, log in or otherwise interact with us. In addition to managing the appropriate routing of information, we use so-called “cookies,” “web beacons,” “server logs” and other Engagement Tools (“Engagement Tools”) to enhance the quality of the service and content you receive. For example, we use Engagement Tools to:
Therefore, even if you do not register with us or submit any personal information on our Website, our Engagement Tools automatically receive information about your Device and the software running on it. We call such information Engagement Data (“Engagement Data”).
Engagement Data often includes elements such as the date and time a “request” is made, the model of the Device making the “request,” the type and version of operating system running on a Device, the browser making the request, routing information, IP address, geolocation, search terms a User enters, what URL a Device most recently visited Website, and, if a mobile application is used, an anonymous unique number. Engagement Data can also include Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement. Engagement Data can be combined with personal information. If so, we treat such combined information the same way we treat personal information.
You have the ability to control how certain Engagement Tools operate by modifying the settings on your Device or its software. Most browsers, for example, allow you to refuse accepting cookies, and many mobile Devices allow you to disable the sending of location information. In some cases, doing these things could diminish the performance of our Website and Services or render them inoperable. To learn more about Engagement Tools and how we use Engagement Data please see the section below entitled “How Information is Used.”
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party Websites or online services (e.g., browser “do not track” signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
Third-party analytics and other service providers, such as Google Analytics, may set and access their own tracking technologies on your Device and they may otherwise collect or have access to information about you and track you over time and across third party Websites. These service providers use tracking technologies to help us analyze how visitors use our Website and Services. We are not responsible for those third party technologies or activities arising out of them. However, some third parties may offer you certain choices regarding their practices.
For example, to learn about opting out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options. If you choose to opt out of the use of Google Analytics, Google will no longer collect and analyze information via cookies associated with your browser for these services. When you opt out, Google will place opt-out cookies on your browser. If you delete your cookies, change browsers, or change devices, you will need to repeat this opt-out process. Also, please note that this opt-out process will work only if your browser is set to accept all cookies. We may still use Google Analytics services to create promotions and apps within social networks after you opt out. These services do not rely on collecting and analyzing information via cookies. To learn more about your choices for these services, review the options your social network provides.
You can obtain information about which third parties have currently enabled cookies and how to opt-out of some of those cookies by visiting the Network Advertising Initiative’s Website at http://optout.networkadvertising.org; or the Digital Advertising Alliance’s Website at http://optout.aboutads.info. For more information on mobile-specific opt-out choices, please visit https://www.networkadvertising.org/mobile-choices.
We work with certain third parties who deploy their own Engagement Tools on our Website (“Third Party Tools”). In some instances they do so exclusively on our behalf. In other instances, they may retain and use the data they collect pursuant to publicly available privacy policies. These Third Party Tools are frequently deployed by companies providing online advertising services or analytics, but they may be deployed in other contexts as well, such as social media plug-ins. We treat personal and non-personal information that we receive from these Third Party Tools the same way we treat personal and non-personal information that we directly collect from our Website. We, however, do not control how these third parties manage the information they gather.
From time to time, we may request your consent or authorization (your “consent”) in connection with the use or sharing of your information. In some instances, this will be because your User Agreement, this Privacy Policy or applicable law or regulations requires us to obtain such consent. In other instances, such consent will be for informational purposes. In the latter case, the request to obtain your consent should not be interpreted as narrowing the scope or applicability of your User Agreement or this Privacy Policy – by entering into your User Agreement or using the applicable Services, you have accepted and agreed to our information handling practices in the manner described in your User Agreement and this Privacy Policy.
In cases where you consent or “opt-in” to the use or sharing of your personal information in a manner that is not otherwise provided for in your User Agreement or this Privacy Policy, unless otherwise explicitly stated in such consent, you will have the ability to rescind your consent and “opt-out” of our use or sharing of such information in the future. In that event, we will refrain from our use or sharing of such information, but we may not be able to require the removal of such information from the databases of the recipients with whom such information has been shared.
From time to time, we may request your consent or authorization (your “consent”) in connection with the use or sharing of your information. In some instances, this will be because your User Agreement, this Privacy Policy or applicable law or regulations requires us to obtain such consent. In other instances, such consent will be for informational purposes. In the latter case, the request to obtain your consent should not be interpreted as narrowing the scope or applicability of your User Agreement or this Privacy Policy – by entering into your User Agreement or using the applicable Services, you have accepted and agreed to our information handling practices in the manner described in your User Agreement and this Privacy Policy.
In cases where you consent or “opt-in” to the use or sharing of your personal information in a manner that is not otherwise provided for in your User Agreement or this Privacy Policy, unless otherwise explicitly stated in such consent, you will have the ability to rescind your consent and “opt-out” of our use or sharing of such information in the future. In that event, we will refrain from our use or sharing of such information, but we may not be able to require the removal of such information from the databases of the recipients with whom such information has been shared.
Our Website and/or Services allow Users to communicate with others through our in-product instant messaging services, Service-branded emails, SMS and other electronic communication channels. Communications that are sent by or on behalf of a User are indicated as being “From” that User. Communications that are sent by us are indicated as being from us or one of our account or support specialists assigned to assist you. Either type of communications may be “real time” communications or communications triggered automatically upon the occurrence of certain events or dates – such as a repeated sign-in failure, an appointment reminder and the like.
Electronic messages received from Users and our administrative announcements are often transactional or relationship messages, such as appointment requests, reminders and cancellations and other Service notifications. You may not be able to opt out of receiving certain messages, although our Website and/or Services may provide a means to modify the frequency of receiving them. In cases in which we believe User emails are not primarily transactional or relationship messages, it will include the capability to opt-out of receiving further e-mails. If you sign-up to receive marketing announcements from us, such emails will include capability to opt-out of receiving such e-mails in the future.
On occasion, we will communicate marketing information, operational updates and other information to Users via electronic mail. Users agree that such transmissions are important means of communication between us and Users and shall not be considered junk faxes or unsolicited advertisements as defined by the Telephone Consumer Protection Act of 1991 or other applicable state or federal laws or regulation.
From time to time we ask Users to complete surveys or otherwise provide input to improve our operations or to assist other Users in making informed choices. The content of such surveys, therefore, should be presumed public. When we make such survey, we let Users know how their responses will be used. As with communities and public forums, we strongly advise Users to exercise care in selecting what information they share in a survey or similar communication, and strongly recommend against sharing any personal financial or other sensitive information that could directly or indirectly be traced to any individual, including yourself.
Our Website may deploy Engagement Tools (such as “cookies,” “web beacons” and “server logs”) on outbound emails to Users and others to collect Engagement Data, and we may use vendors to assist us in sending outbound emails to Users who may deploy Third Party Tools.
Emails and other communications from individuals who are not users of our
Website or Services, or that are being sent in connection with business, agreements or subject matter other than your User Agreement or your use of our Services, are not covered by this Privacy Policy. If, for example, you respond to a posted job opening, that communication to us is not covered by this Privacy Policy as we utilize a third party service provider to manage the application process for the job openings that may have been posted on our Website. Likewise, if you submit to us any ideas, suggestions or proposals (collectively, “Suggestions”) relating to our Website or Services or other products or services by any means – such as through email or other communication channels, one of our communities or user forums, or to our customer support or other personnel – such Suggestions are not governed by this Privacy Policy.
We will not share personal information you submit except under the following circumstances:
To limit sharing of personal information where possible, you may submit such requests by contacting us at www.prvasset.com. We do not sell personally identifiable information, and we will not sell personally identifiable information except as described in this Policy or with your consent. If we ever decide to sell personally identifiable information, we will provide you with notice and a right to opt-out of such sale.
Our Website and many of our Services are protected by technical measures intended to safeguard the confidentiality, integrity and accessibility of sensitive information our Users store and share on our Website. Further, certain regulations require us to investigate potential or suspected threats on our Services or the confidentiality, integrity or availability of the information they safeguard. Accordingly, we may preserve, use and disclose information – including personal and non-personal information – when we have a good faith belief it is necessary or advisable to:
We may also preserve, use and disclose such information in response to a search warrant, court order, subpoena, judicial proceeding or other legal process if we have a good faith belief that the law requires us to do so. Such legal process may prohibit us from notifying the Users or other individuals or entities identified by such information or take such other actions as would otherwise be a violation of your User Agreement or this Privacy Policy. When we preserve information pursuant to this section, it may be for extended periods of time, as we in good faith believe are necessary or appropriate under the circumstances, and may include the preservation of information from accounts that have been disabled.
We endeavor to make security of our Website and Services and the information they collect, store, process and transmit a top priority. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the information we collect, we deploy a wide range of technical, physical and administrative safeguards, including: Secure Socket Layer (SSL) encryption, firewalls, system alerts and other information system security technologies; housing data in secure facilities that restrict physical and network access; and regular evaluation and enhancement of our information technology systems, facilities, and information collection, storage and processing practices. It is important to remember, however, that no system can guarantee 100% security at all times. Accordingly, we cannot guarantee the security of information stored on or transmitted to or from our Website and Services.
If we learn of a security vulnerability or risk, we may attempt to notify you and provide information on protective measures you may take. There are, however, some precautions that you can proactively take to improve your system security and reduce the likelihood of unintended disclosure of personal information:
Our Website and Services are not intended for or designed to attract children under the age of 13, and we do not knowingly collect personal information from such children. If we learn that we have inadvertently obtained personal information from a child under the age of 13, we will delete that information as soon as practicable. If you become aware that your child has provided us with personal information without your consent, please contact us immediately at the contact information below. Should this Privacy Policy change, we would comply with the Children’s Online Privacy Protection Act, which requires us to notify and obtain consent from a parent or guardian before we collect, use and disclose the personal information of children who are under 13 years of age.
Without limiting the generality of the foregoing, our Website and Services do allow Users above the age of 18 years old – such as parents and guardians – to submit personal information about others, including minors. Such Users assume full responsibility over their submission, use and transmission of such information.
Access to our Website and Services is administered in the United States (“US”) and are intended for Users in the US. You may not use our Website or Services in any jurisdiction where offering, accessing or using our Website or Services would be illegal or unlawful. If you are located outside of the US, please note that the information you submit to us will be transferred to the US. By using our Website and/or Services, you consent to this transfer. You also consent to the transfer to and processing of any personal information by us or any of the other parties described in the section “Sharing of Information” above, whether located in the US or any other countries, for the purposes described in this Privacy Policy, or for any other specific purposes to which you consent. If you are located in a country other than the US, you should note that, at present, the laws of the US and certain other countries have not been approved by the European Commission or privacy authorities in certain other countries as providing “adequate protection” for personal information within the meaning of the European Union General Data Protection Regulation or applicable laws of other countries.
This Privacy Policy applies only to our Website and Services. It does not apply to services offered by third parties, including Websites and other online services that our Website or Services may display links to or advertisements for. When you click on such links or advertisements, you will be visiting Websites or interactive services operated by third parties, who have their own information collection practices and may also collect information through the use of tracking tools, such as cookies, web beacons, server logs and the like. When you click on or interact with an ad appearing in our Website or Services, the advertiser or sponsor may infer that you meet targeting criteria that they may have used in connection with the sponsoring such ad. This may lead to similar ads being targeted to you on our Website or Services or elsewhere. We do not have control over how any third party gathers or uses information, so you should review their privacy policies to learn of their information gathering and handling practices.
We continue to improve and enhance our Website and Services. Some of these improvements and enhancements may result in changes to this Privacy Policy. We will post such changes along on this page, and if the changes are significant, we will provide a more prominent notice. Because our Privacy Policy can change at any time, we encourage you to reread it periodically to see if there have been any changes that affect you. We will post the dated that the Privacy Policy was “Last Updated” for your reference. Any changes to the Privacy Policy will go into effect as soon as they are posted to the Website. If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, you will need to deactivate your account before the new Privacy Policy becomes effective. Your use of our Website or Services following any such change constitutes your agreement that all information collected from or about you through our Website or Services after the revised Privacy Policy is posted will be subject to the terms of the revised Privacy Policy.
Our Website and Services aim to provide you with access to the personal information you submit and the means to update it. This can be accomplished by logging into our Website or Services or contacting us using the contact information below. Under certain circumstances, we may ask you to verify your identity before your request is processed. This will be done free of charge except where it would require a disproportionate effort. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
If you desire to deactivate your account please contact us using the contact information below. Upon your request, your account will be deactivated and your personal information will be securely archived. We retain archived information for a period of five years (or longer as permitted by law) as necessary to comply with legal obligations, resolve disputes and enforce our agreements and other authorized uses under this Privacy Policy.
You should also be aware that we store indefinitely non-personal information, including Engagement Data and de-identified personal information, as well as all information that you have shared on any of our public forums, blogs, communities, surveys and the like.
Should you have any questions or complaints about the practices described in this Privacy Policy, you may contact us at:
PRV Asset Management LLC
13911 Ridgedale Drive, Suite 332
Minnetonka, MN 55305
Telephone (855) 767-7100