This privacy policy (“Policy”) of Assure Services, Inc. and its affiliates (collectively “Assure”) applies to Assure’s services, platforms, and applications (the “Services”) and Glassboardtech.com and other Assure websites (collectively the “Site”). Assure has developed this Policy to inform you how Assure collects, uses, shares, or otherwise processes any information that is unique to you and may be used to identify you or your usage data, or that can reasonably be used to identify you (“Personal Information”). It also describes the choices available to you regarding our use of your Personal Information and how you can update this information.

Assure respects your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. If you choose to exercise these privacy rights, you have the will not to be treated in a discriminatory way. Assure does not sell your Personal Information. Assure uses various security measures to protect your Personal Information. You can help keep your data safe by taking measures to protect your data against unauthorized disclosure or misuse.

Why Assure Collects Information

To Provide Services: Assure performs various services for you and for third-parties that provide us with your information. In many cases Assure needs your Personal Information to perform these services. For example, if you invest in a special purpose vehicle, your Personal Information is needed to properly administer the special purpose vehicle and provide you with important information and services, like tax information.

To Personalize your Experience: Assure is always looking for ways to improve your experience with our Services and the Site. Assure may use your Personal Information and usage data to make your experience more personal and relevant. This may include sending you reminders and updates about the Services you have requested or may have an interest in.

Information Assure Collects

Assure collects only the personal data Assure needs or is required to collect. This includes:

  • Personal Data: name, username, password, date of birth, gender, marital status, title, social security number or tax identification number, home address, work address, billing address, email address, telephone numbers, professional history, picture, and copies of identification cards or other forms of identification.
  • Financial Data: bank account information, money transfer instructions, funds transfer accounts, financial objectives, transaction history, salary, credit reports, investment documents, and financial statements.

You are not required to provide personal data that Assure requests. However, if you choose not to do so, in many cases, you will not be permitted to invest. Also Assure may not be able to provide you with Services or respond to your requests.

How Assure Collects Information

Assure generally collects information by asking you to enter data into forms on the Site, by observing your activity on the Site and use of the Services, from third-parties that have been engaged by us to provide services that require Assure’s collection of your Personal Information, or from documents uploaded directly by you or by a third-party from whom you have requested services, from third party information providers that provide background checks, verify your identity, creditworthiness, and your eligibility and suitability to participate in certain transactions or services.

Cookies and Tracking Technologies

Assure uses cookies, web beacons and log files to automatically gather, analyze, and store technical information about the Site’s visitors. This information includes the visitor’s IP address, browser type, ISP, referring page, operating system, date/time, and clickstream data (meaning data about the pages you visit on the Site). This information is used to improve the Services and enhance the experience of the Site’s visitors. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it will limit your use of certain features or functions on the Site or of the Services. This may negatively affect your Site experience.

Sharing Your Information

  • Assure may use third party sources to confirm or supplement the information that it obtains from you.
  • Assure may share your Personal Information with third parties, including:
  • Service providers that provide software and services to store Assure’s customer and other information.
  • The affiliates of Assure so that Assure may better provide the Services.
  • Lawyers, accountants, auditors, insurers, or other similar service providers.
  • Credit card and payment providers that help process payments for Assure (Assure does not store any credit card information you provide).

Assure may share your information with law enforcement agencies, public authorities, or other organizations if legally required to do so, including to meet national security or law enforcement requirements, or if Assure has a good faith belief that such use is reasonably necessary to:

  • Comply with a legal obligation, process, or request.
  • Enforce the Site’s Terms of Use and other agreements, including investigation of any potential violation of those agreements.
  • Detect, prevent, or otherwise address security, fraud, or technical issues.
  • Protect the rights, property, or safety of Assure, Site users, a third party, or the public, as required or permitted by law.

Assure may also rely on your consent as a legal basis for using your Personal Information where Assure has sought your consent for a specific purpose. If so, you have the right to revoke your consent at any time, but this will not affect any processing that has already taken place.

In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Assure may transfer your Personal Information as part of the transferred assets without your consent or notice to you. Assure may use and disclose aggregate information for any purpose so long as the information does not identify or otherwise relate to an individual for any purpose.

Where Assure Stores Your Data

Assure is based in the United States and our Site is hosted in the United States. Therefore, if you are located outside the United States, the information that you submit to Assure through our Site will be transferred to the United States. Likewise, your data and your Personal Information will be transferred to and accessible from the United States.

Individual Rights over Personal Information

Assure respects your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data maintained by Assure regardless of where you live. Generally, you can review, cure inaccuracies, and update Personal Information through your account, if you have one, or by contacting privacy@assure.co.

In certain circumstances individuals have the following rights. Assure will endeavor to allow you to exercise these rights whether you have the right under the laws of the jurisdiction in which you reside or not.

Access and Portability

You have the right to know whether Assure processes Personal Information about you, and if so, to access data Assure holds about you and certain information about how Assure uses it and with whom Assure shares it.

Correction, erasure, and restriction of processing. You have the right to require Assure to correct any of your Personal Information that is inaccurate, to have incomplete data completed, and to request that Assure delete your data: (i) where you believe it is no longer necessary for Assure to hold the Personal Information, (ii) where Assure is processing your data on the basis of its legitimate interest and you object to such processing, or (iii) if you believe the Personal Information Assure holds about you is being unlawfully processed by Assure. You can request that Assure restrict the processing of your data (other than for storage purposes) that Assure holds: (i) if you believe the Personal Information is not accurate (while Assure verifies accuracy), (ii) where Assure wants to erase the Personal Information because the processing Assure is doing is unlawful, but you want Assure to continue storing the data, or (iii) where Assure no longer needs the Personal Information, but you require Assure to retain the data for the establishment, exercise, or defense of legal claims or where you have objected to Assure processing Personal Information and Assure is considering your objection.

Objection: You have the right to object to Assure’s processing of data about you and Assure will consider your request. You should provide detail as to your reasoning so that Assure can assess whether there is a compelling overriding interest to continue to process your data or Assure needs to process it for legal purposes or in relation to legal claims.

Complaints: In the event that you wish to make a complaint about how Assure processes your Personal Information, please contact Assure. Assure will endeavor to deal with your request. This is without prejudice to your rights, if any, to file a claim with the applicable regulatory body in the state, or with the data protection supervisory authority in the EU country, in which you live or work.

You can exercise these rights by sending an email to privacy@assure.co or by mailing Assure at the address listed at the end of this Policy. You may have an authorized person make a request on your behalf. Before Assure responds to your request, you may need to verify your identity or that the person you authorized is so authorized.

These rights in their entirety may only be granted as a matter of law to residents in certain states or countries. Where the exercise of your right is not required by law, your request will be handled on a case-by-case basis.

You may make a complaint without prejudice to your rights, if any, to file a claim with the applicable regulatory body (for instance, a data protection supervisory authority) in the state or country in which you live or work. If your complaint or dispute is not satisfactorily resolved or you don’t receive a timely response from Assure, you may escalate the matter to the applicable regulatory body. Assure commits to cooperate with the relevant authority and will comply with the advice given by it with regard to your appliable information.

There may be situations where Assure cannot grant a request you make. For example, if you ask Assure to delete your transaction data and Assure is legally obligated to keep a record of the transaction to comply with law. Assure may decline to grant a request if granting the request would (i) undermine Assure’s legitimate use of data for anti-fraud and security purposes, (ii) jeopardize the privacy of others, or (iii) be extremely impractical or not required by applicable law.

Third Party Websites and Do Not Track

The Site includes links to third party websites whose privacy practices may differ from those of Assure. If you submit Personal Information to any of those websites, your information is governed by those websites’ privacy policies. You should read the privacy policies of those third-party websites before you submit any information to them. Assure does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

Changes to This Privacy Policy

Each time you visit the Site or use the Services, the current version of this Policy will apply. Please check the date of this Policy if you wish to view if changes have been made. You should check the Site regularly to be aware of changes. Assure encourages you to periodically review this page for the latest information on Assure’s privacy practices. Revisions this Policy are effective immediately after being posted.

The privacy laws of various states and countries and the interpretation of those laws may change. Assure endeavors to comply with all applicable laws and nothing in this policy (whether stated or not stated) is intended to contravene your rights, or not grant you rights, that you have under applicable law.

Contact

Please contact Assure with any questions or concerns about this Policy or Assure’s data collection practices at privacy@assure.co or 6510 S. Millrock Drive, Suite 400, Salt Lake City, UT 84121