This is the Data Privacy Notice (“Privacy Notice”) of Driftwood Advisors, LLC, Driftwood Capital LLC and each of their affiliates and subsidiary entities (collectively, “Driftwood,” the “Company,” or “we” or “us”). We maintain a website to provide services to you (the “Website”). This website may ask for and collect your Personal Information (defined below) to provide our services, enhance your experience, and provide you with other relevant information about our offerings. Driftwood values the privacy of the visitors to its Website and the users of the services provided thereon. This Privacy Notice applies to activities Driftwood engages in on its Website and activities that are offline or unrelated to its Website. We are providing this notice to explain our information practices and the choices you can make about the way your information is collected and used.
This Privacy Notice governs our collection and treatment of Personal Information. The term “Personal Information” refers to non-public information that personally relates to or identifies you (such as your name, password, age, gender, email address, postal mailing address, zip code, home/mobile telephone number, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income, website pages viewed and other similar information). We expect all of our employees and those with whom we share Personal Information to adhere to this Privacy Notice.
Driftwood is committed to protecting the information that our investors, business partners, employees, suppliers, and others have entrusted to us.
This Privacy Notice applies to all Personal Information collected by Driftwood, relating to all investors, business partners, suppliers, and others who do business with us.
We only collect Personal Information that you provide to us or that we are authorized to obtain by you or by law. The types of Personal Information we collect will depend on how you are interacting with us through our website or in person. For example, we may collect different information from you through recruiting than if we are exploring a new business relationship or venture with you. In addition, we are required by law and certain regulatory bodies to collect certain information from you in order to provide our services to you. Depending on our interactions, we may collect the following categories of Personal Information:
We do not sell any Personal Information from individuals to third parties.
Your privacy is important to us. We collect and use information we are required to collect by law or regulatory authority, and that we need to do our business, including providing you with the services and experiences you expect from us. When we collect and use your information, we take your privacy and security seriously and undertake commercially reasonable efforts to maintain the confidentiality and security of your Personal Information.
We will use the information provided by you, or on your behalf, to provide our services or evaluate potential business relationships. Specifically, we have used your Personal Information for the following purposes within the twelve (12) months preceding the date of this Notice:
A “cookie” is a small text file that websites send to your computer, device, or other Internet-connected device to identify your browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and the cookies and may be used to transmit information collected through cookies back to a web server.
Behavioral Tracking/Third Party Cookies
We use third-party analytics services on our website, including Google Analytics. To learn more about Google Analytics, visit: https://policies.google.com/technologies/partner-sites.
Your Internet browser may let you restrict or disable certain types of cookies. Without cookies, you may not be able to use all of the options on our website.
Some web browsers allow you to turn on Do Not Track (“DNT”), which sends signals to websites you visit, telling those sites that you do not want your online activities to be tracked.
Our website currently is not designed to respond to DNT signals received from web browsers.
Sometimes we use technology to collect the information that your browser uses to auto-fill. You can stop this technology by turning it off in your browser, and you will still be able to use all of the options on our website.
We may share information about you to third parties as indicated below:
Affiliates, Subsidiaries, and Special Purpose Entities: We may share your Personal Information with our different affiliates, subsidiaries, and special purpose entities. If we share your information, we will share only the information that is necessary and we will take commercially reasonable steps to make sure that third parties take prudent steps to protect your information.
Investment Subject Matter Experts: We may share your Personal Information with different subject matter experts in the course of a financial transaction or investment, including attorneys, brokers, investment bankers, accounting firms, insurance specialists, market or technology consultants, and HR consultants, among others. These people will only use your information to the extent necessary to undertake diligence and consummate the transaction.
Service Providers, Suppliers, Agents, and Business Partners: Other companies sometimes provide certain services to us or on our behalf (e.g., maintenance, IT support, analysis, development, security, background checks, technical solutions for transactions). Unless we tell you differently or as described elsewhere in this Privacy Notice, our service providers are not permitted to use your information except to assist us.
Compliance with Legal Obligations: We may need to disclose certain information to auditors, government authorities, law enforcement, regulatory agencies, our legal counsel, third party litigants and their counsel, or other authorized individuals in order to comply with laws that apply to us, or other legal obligations such as contractual requirements.
Changes in Business Structure/Ownership: We may disclose or transfer your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of the Company’s business, assets, or ownership interest (including any bankruptcy or similar proceedings).
We have not sold any categories of Personal Information within the past 12 months, including children’s Personal Information.
Information We Disclose for a Business Purpose
In addition to the purposes described in this notice, we may use Personal Information listed below for business purposes.
We strive to take appropriate security measures to help safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are allowed to access Personal Information, and they may only access it for permitted business functions. We also use technology to protect your information, including firewalls and encrypting sensitive Personal Information that is transferred to or from our systems.
While we cannot guarantee that loss, misuse, or alteration will never occur, we use reasonable efforts to prevent it. Please keep in mind that no method of storage or transmission over the Internet is completely secure, so your use of our services and provision of information to us is at your own risk.
Our website may contain links to other third-party sites on the Internet. The information practices of those websites are not covered by this Privacy Notice. We are not responsible for the privacy policies of other websites.
Your Rights and Choices
For all Personal Information that we collect about you, you may have the following rights or choices that we will accommodate where your requests meet legal and regulatory requirements and do not risk making our other data less secure or changing our other data. You may also designate an authorized agent to make a request on your behalf.
Access: You may have the right to know what information is being collected about you, to access your Personal Information, to receive a copy of your information, and to know whether your Personal Information is disclosed and to whom. If you have questions about your information, please contact us using the methods in the Contact Us section below.
Erase: You also may request that we erase your information. If you want to ask us to erase your information, please contact us using the methods in the Contact Us section below.
Data Portability: You may have the right to ask for a copy of the Personal Information we have about you. If you would like to request that we provide a copy of your information to you, please contact us using the methods in the Contact Us section below.
Non-Discrimination: You have the right not to receive discriminatory treatment by the Company because you exercise your privacy rights. If you have any questions, please contact us using the methods in the Contact Us section below.
How to Make a Request: If you would like to make a request, please use the Contact Us section at the bottom of this page. Please provide your full name, phone number, and email address.
Responding to Requests: Your request will be evaluated to determine whether the requested change meets legal regulatory requirements and does not risk making our other data less secure or changing our other data. After we evaluate your request, we will respond to update you on the status of your request.
Verifying Your Identity: To protect you and your information, we may ask you to confirm certain information before we honor your request. For example, if you make a request, we will ask you to confirm your name, email address, and/or phone number verify your identity, so that we can help protect your information. If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.
International Data Transfers
Driftwood primarily stores the Personal Information we collect in the United States. To facilitate Driftwood’s global operations, staff who work for Driftwood and/or our service providers may transfer and access such Personal Information from locations around the world. This will involve transferring your Personal Information outside the European Economic Area (EEA).
We will take commercially reasonable steps necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Notice.
Whenever we transfer your Personal Information out of the EEA, we will ensure one of the following safeguards is implemented:
E.U. Privacy Rights
Under certain circumstances, individuals within the European Economic Area have rights under data protection laws in relation to your Personal Information as set out below:
Legal Bases For Processing
We have set out below a description of some of the legal bases we rely on to process your Personal Information. Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your Personal Information. Please email: [email protected] or write to Driftwood, Attn: Jorge Gomez-Moller at 255 Alhambra Circle, Suite 760, Coral Gables, Florida 33134 if you need details about the specific legal grounds we are relying on to process your Personal Information where more than one ground has been set out below.
Generally, we do not rely on consent as a legal basis for processing your Personal Information.
We will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Currently, we keep most information for the entire lifecycle of an investment fund in order to satisfy legal, accounting, and reporting requirements.
In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.