Thank you for visiting the website of twentytwo & brand (together with its affiliates “22”, “we” or “us”). By accessing or using this website (the “Site”), you hereby accept and agree to comply with the practices described in this Privacy Policy, as well as our Terms of Use & Disclaimers, and acknowledge your understanding of same. These legal notices may be updated by us at any time. Your continued use of the Site after any such modifications shall constitute your acceptance of this Privacy Policy as modified.

 

If you do not agree to this Privacy Policy for any reason, please do not use the Site.

 

If you have any questions or comments about this Privacy Policy, please contact us at twentytwo & brand - hello@twentytwoandbrand.com

 

Your Privacy Is Important to twentytwo & brand

In the course of serving you as an individual client or as someone associated with a corporate or Individual client, 22 may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

 

This Privacy Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy.

 

This Privacy Policy concerns only the Site and does not concern any website to which the Site may link. Should you choose to visit these third-party sites, you should review their privacy policies to ensure that you understand and are comfortable with their practices concerning your personally identifiable information (“PII”). This Privacy Policy does not concern your interaction with 22 in any matter other than your use of the Site. Finally, this Privacy Policy does not address our privacy practices with respect to any non-public personal information we may collect from you as an investor in us or in funds that we sponsor or manage. We address these practices in separate notices to investors or potential investors.

 

Information Collection and Use

Personally Identifiable Information: When you use the Site, you may be asked to provide information that we collect and store in a way that allows us to relate it to you personally, including your name, address, e-mail address, and telephone number. Any PII you submit to the Site is used only to service your account and/or to provide you with information on our products and services. If we collect and store any of your PII, we will not sell, share, or rent it to others in contravention of this Privacy Policy.

 

Additionally, if you are accessing parts of this Site that are password-protected, then (i) once you submit your password, the Site will recognize who you are and collect all information that you submit, including all electronic information (including all transaction information), and (ii) any information collected about you from the Site may be associated with other identifying information that we have about you.

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• Aggregate Information: In addition to the information you provide to us, we may collect information about you through technology. The Site may use technical methods to track and analyze the traffic patterns on, to, and from the Site. We may collect the information from the use of these technical methods in a form that is personally identifiable. If we use such data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.

• Cookies: Cookies are small text files that are stored in your computer’s memory and hard drive when you visit certain web pages. Cookies are used primarily for administrative purposes, to improve your experience with the Site.

 

The Site uses cookies to recognize when a user has visited the site and to collect aggregate user viewing data. Cookies may also be used in the investor portals to monitor user IDs and passwords for security.

 

Using the settings of your Internet browser, you can configure your browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. You are always free to decline our cookies if your browser permits, however, if you choose to turn off cookies, you may not have access to many features that optimize your browsing of our Site, and some of our services may not function properly. You may at any time delete any cookies set by using the relevant option of your Internet browser or by deleting the cookies on your hard drive. The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used Internet browsers, or you may consult the vendor documentation for your specific software.

 

By using the Site with your browser settings adjusted to accept cookies, you consent to our use of cookies and other tools to provide the products and services available on the Site.

 

Use of Information.

22 does not disclose any nonpublic PII about its Site users to any non-affiliated third party, except as set forth below.

 

We may use or disclose certain PII we collect about you when you visit and browse the Site as part of our normal business operations, or to send you administrative communications either about your interactions with us or about features of the Site, including any future changes to this Privacy Policy.

 

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within 22 may be given, or given access to, your PII. We may use or disclose this information for marketing, research, and other business purposes, and we may associate your PII with other information we collect about you, such as details about your usage patterns and interests, but we will not sell this information or disclose it to third parties.

 

We may also use service providers to facilitate our services or platform functions on our behalf. Non-affiliated companies and individuals that assist 22 in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your PII only in the course of providing such services and only for the purposes that we dictate.

 

Under limited circumstances, we will use or disclose PII when we believe that such disclosures are required by law, regulation, legal process, subpoena, document request, or governmental request. We may also do so to help enforce our Terms of Use, protect your safety or security, including the safety and security of property that belongs to you, or protects the safety and security of our websites or databases or the tangible or intangible property that belongs to us or to third parties.

 

In the event that 22, or all or some of our business, stock, or assets, are acquired by or merged with or into another entity, we may share all or some of your information with this entity to continue to provide services to you. You will receive a notice if such an event occurs. If the new entity wishes to make additional use of your information, you may decline such use at such time.

 

Security

No data transmission over the Internet can be 100% secure, therefore 22 cannot ensure or warrant the security of any information submitted on the Site. However, we endeavor to protect your PII using technical, administrative, and physical methods to maintain the integrity and security of our databases, including firewalls. We will not be responsible or liable for any damages, losses, or causes of action arising out of or in connection with the disclosure of your PII.

 

Do Not Track

Other than statistical tracking on overall site usage, there is no tracking of any individual nor does the Site request or capture any personal information from viewers.

 

Children’s Privacy

Although this Site is not targeted toward children, we are concerned about the safety and privacy of children who use the Internet. Consistent with the Children’s Online Privacy Protection Act of 1998, if a child under 13 has provided PII to us through the Site without verifiable parental consent, a parent or guardian may inform us at the address for legal notices above, and we will use commercially reasonable efforts to delete it from our files.

 

International Use

This Site is operated and controlled by 22 in the United States, and the Content (as that term is defined in our Terms of Use) provided in or accessible through the Site is, unless otherwise specified, directed at residents of the United States. We make no claims, representations, or warranties that the Content or the Site, or that the transactions, products, or services discussed on or accessible through the Site, are available or appropriate for sale or use outside the United States. Access to the Site from countries or territories where such access is illegal is prohibited. Those who access the Site from outside the United States do so on their own initiative and are responsible for compliance with local laws, rules, and regulations.

 

Our databases are located in the United States. By sending us your data, you consent to its transfer to and storage within the United States.

 

No Representations or Warranties

22 has compiled this Site and the Content hereon in good faith, and while we use reasonable efforts to include accurate and up-to-date information, the Site and Content are provided on an “as-is” and “as available” basis, with no representations or warranties of any kind. We do not make and hereby specifically disclaim any and all express or implied representations or warranties with respect to the Site and the Content, including those with respect to merchantability, fitness for a particular purpose, title, non-infringement, availability, security, accuracy, freedom from viruses, malware or other harmful components, completeness, timeliness, functionality, reliability, sequencing or speed of delivery. Your use of this Site and use or reliance upon any of the Content is solely at your own risk.

 

Limitations of Liability

In no event shall 22, its affiliates or their respective officers, directors, managers, partners, members, shareholders, employees, affiliates and agents be liable to any party for any claims, liabilities, losses, costs, or damages under any theory, including but not limited to any direct, indirect, punitive, special, incidental, or consequential damages arising out of in connection with any access, use (or inability to use) or distribution of the Site, or any Content thereon, including those caused by any failure of performance, error, omission, interruption, defect, delay in operation, computer virus, worm, line failure or other computer malfunction, or unauthorized interception of data or communications. This is true even if we have been advised of the possibility of such damages or losses. You understand and agree that your use of this Site is predicated upon your waiver of any right to sue us directly or to participate in a suit for any losses or damages resulting from your use of this Site.

 

Governing Law/Forum

This Privacy Policy is governed by the laws of the State of Florida. Any dispute regarding this Privacy Policy or your use of the Site shall be resolved solely in the state or federal courts located in Palm Beach, Florida. You agree to waive trial by jury in any such action.