Privacy Policy | Cashmere Fund

Last Revised: September 16, 2024

This Privacy Policy describes how Cashmere Fund (collectively, “Cashmere Fund,” “we,” “us,” or “our”) collects, uses, shares, and safeguards personal information we collect though our online properties, including cashmerefund.com, and our mobile applications(collectively, the “Sites”).

Types Of Personal Information We Collect

We collect the following types of personal information aboutyou directly from you; from our service providers, third parties, business partners, our affiliates, or publicly available sources; and automatically through cookies and tracking technologies:

‍Contact Information, including your name, email address, phone number, and postal address.
Demographic Information, including age, date of birth and gender.
Financial and Investment Information, including bank account number, credit or debit card number, Social Security Number, date of birth, and investment history.
Transaction Information, including details about the payment method (e.g., credit card expiration data and zip code), date and amount of transaction, and billing and shipping addresses.
Affiliations, such as information about the organization you represent and your history with that organization.
Career and Professional Information, including education history, employment history, references, awards, qualifications, certificates, licenses, and any other information you choose to provide in your resumes and/or applications.
Information We Generate, including your member number and reports about your investments.
Communications with Us, including information you provide to us in email or through online forms.
Internet or Other Electronic Network Activity Information, including IP address, online identifier, browsing history, search history, information on a consumer's interaction with our Sites, application logs, device data and registration, social media account information or advertisement, your usage preferences, referring links from websites or advertisements that refer you to our Sites, and information collected from cookies and other tracking technologies.

Use And Processing Of Information

We may use and process the personal information described above for the following purposes:

Account Registration. including creating an account, providing account functionalities, and managing your account information.
Communications, including contacting you regarding products, services, billing, transactions, marketing, and other business purposes; receiving and responding to your feedback or issues; and understanding how you interact with our communications to you.
Transactions, including providing you with our products and services, processing returns, and carrying out related business activities.
Surveys, including understanding your opinions and collecting information.
Sweepstakes, Contests, and Promotions, including registering you, providing prizes and rewards, and operating and fulfilling terms.
Recruitment, including managing the application process and communicate with you regarding your application.
Site Interaction, including identifying you when you visit our Sites; to monitor and analyze Site trends, usage, and activities of Site visitors so that we can understand Site usage patterns to help us improve the Sites; and to ensure the Sites operate efficiently.
Marketing and Advertising, including sending marketingand promotional materials relating to our products, services, sales, orpromotions and providing behavior-basedand targeting advertising.
Business Purposes, including as necessary for internal administrative purposes and to manage our relationships.
Security, including preventing, investigating, identifying, or taking any other action with regard to suspected or actual fraudulent or illegal activity, or any activity that violates or may violate applicable laws, regulations, or legal process and our policies.
Legal Obligations, including complying with applicable laws, regulations, or legal processes as well as industry standards and our company policies.
Corporate Restructuring, including evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

‍Sharing Of Information

We may disclose your personal information to the following parties:

Service Providers. We may share your personal information with service providers, including vendors and contractors, that may help us to administer our Sites, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders. We may share your personal information with providers of cookies and other tracking technologies, as described below in the cookies and Tracking Technologies section.
Affiliates and Acquisitions. We may share your personal information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, all or part of our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
Professional Advisors, Affected Parties, Law Enforcement Agencies, Courts, Regulatory Agencies, and Other Government Entities. We may disclose your personal information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
Public. Some of our Sites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.
Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them. Their use of your personal information is not governed by this privacy policy.
Other Disclosures with Your Consent. We may share your personal information with other unaffiliated third parties who are not described elsewhere in this policy.

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Cookies and Tracking Technologies

In addition to any personal information that you submit through our Sites, we and our service providers may use a variety of tracking technologies, including cookies, web beacons, tracking pixels, and other tracking technologies (collectively, “Cookies”) that passively collect certain information whenever you interact with our Sites. Some Cookies, for example, are small files that are stored on your computer when you visit our Sites. Some Cookies may also be employed on mobile apps. Information we get from Cookies helps us to understand how you use our Sites, and we use that information to improve our Sites and your experience.

First-Party and Third-Party Cookies‍

First-party Cookies are set by us on our Sites and are commonly required for the Sites to function and to be protected and secure. Third-party Cookies are set by our service providers, including those who provide analytics, personalization, marketing, advertising, or interactive content on our Sites. Third-partyCookies are governed by each third party’s specific privacy policy, not this one.

Cookie Types and Uses

‍Cookies may be session or persistent Cookies. Session Cookies are deleted from your device when you close your browser. Persistent Cookies remain stored on your device until deleted or until they reach their expiration date.

Functional and Performance Cookies provide functionality to the Sites, help us deliver our products and services, and monitor Sites’ performance, including by routing traffic between servers, retaining user preferences, and facilitating account log ins.
Security Cookies enable security features and allow us to detect activity that might violate our rules and Terms and Conditions, such as unauthorized access or activity.
Location Cookies permit us to use your approximate location, including using your IP address to derive your location, for purposes such as verifying your region and delivering or restricting content based on your location.
Analytics Cookies allow us to understand, improve, and research features and content on theSites, including how visitors navigate the Sites and our popular content and features.
Advertising Cookies allow us to deliver advertisements, customize advertisements for users, and track advertising campaign efficiency, including through the use of third parties that provide targeted advertising for us and who may use information from Cookies to help build visitor profiles and deliver relevant advertising on other websites and apps.

How We Use, Process, and Share Personal Information Collected through Cookies‍

We, and our service providers and vendors, may use Cookies to automatically collect your personal information when you interact with the Sites, including your internet or other electronic network activity information, as described above. We may combine automatically collected information with other personal information we obtain about you, which may include data we obtain from others. Cookies on our Sites may be used to collect personal information about your online activities over time and across different online services.

We use, process, and share your automatically collected information for the following purposes:

Improve User Experience. We use automatically collected information to improve your user experience. For example, the information provided through Cookies may be used to recognize you as a previous user of one of our Sites so you do not have to enter your personal information every time you visit or select the same setting repeatedly. Using Cookies, we can offer personalized content to you based on your location or interests.
Third-Party Analytics. We may engage third-party web analytics services, such as Google, Hotjar, Meta, and Webflow, to help us understand and analyze how visitors interact with our Sites. We use such data to help us administer and improve the quality of our Sites.
Advertising and Marketing. We may use third-party advertising partners, such as Microsoft, Meta, TikTok, and Twitter, that show you personalized ads and to measure the effectiveness of these ad using their own Cookies and our Cookie data. We may provide these third-party advertisers with information about your use of our Sites as well as aggregate or non-personal information about users of our Sites. They may use this information to build or enhance their understanding of you and your interests to provide you with more relevant ads.

Your Choices

You can make the following choices regarding your personal information:

Access To Your Personal Information. You may access to your personal information by navigating to the account settings section of our account. If you have questions or concerns about accessing your information, you may request additional information in writing to the address below.
Deletion Of Your Personal Information. You may request that we delete your personal information by contacting support in the Cashmere Fund app. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with "NO SNAIL MAIL" in the subject line along with your name, address, and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove you from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your being removed.
Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.” Please see our SMS Terms of Use for more details.‍

‍Exercising Your Choices‍

Please address written requests and questions about your rights to cashmere@sweaterfunds.com or call us at 1-888-577-7987.

Note that, as required by law, we may require you to prove your identity by phone call or email. Depending on your request, we may ask for information such as your name, the last item you purchased from us, or the date of your last purchase from or transaction with us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to fulfill your request.

Your Choices About Cookies

‍You may be able to choose how Cookies are used to collect information about you through your browser settings (and extensions), device settings, and generally available opt-out mechanisms. Please be aware that disabling Cookies or limiting targeted advertising will not stop you from seeing advertisements online or in apps. The advertisements you see will, however, likely be less relevant to you.

Browser Settings. Most browsers allow you to review and delete Cookies stored on your device and to disable or prevent Cookies on the websites you visit. Cookies are generally easy to disable or delete, but the method varies depending on your browser. If you typically use more than one browser, you will need to disable or delete Cookies separately on each browser you use. If you disable Cookies, you may not be able to use certain features on our Sites and disabling Cookies may invalidate your other opt outs that rely onCookies to function.
Online Tracking. Your browser may have settingsthat allow you to transmit a “Do Not Track” signal when you visit a website oruse online services. Like many websites, we do not currently recognizeautomated browser signals regarding tracking mechanisms, which may include"Do Not Track" instructions.
Device Settings. Your device settings may allow youto manage Cookies, including by adjusting or resetting the advertisingidentifiers on your mobile device. iOS and Android devices allow you to useyour privacy settings to control whether partners can use information aboutyour app activity for advertising purposes.
Advertising Networks. Some vendors we work with mayparticipate in the Digital Advertising Alliance (“DAA”) and itsAdChoices opt-out program. For more information about the DAA and its opt out tool, you can visit youradchoices.com/ for web browsers or aboutads.info/appchoices for mobile apps. Other advertising networks and exchanges may participate in the Network Advertising Initiative ("NAI"). To learn more about opting out of targeted advertising or to use the NAI opt-out tool, visit networkadvertising.org/choices/ for web browsers or networkadvertising.org/mobilechoice/ for mobile apps.
Vendor Opt-Out Mechanisms. Some of the vendor we work with offer tools that you can use to limit or opt out of their Cookies, such as:

We are not responsible for the effectiveness of, or compliance with, opt-out options or tools offered by others or the accuracy of their statements regarding their programs.

‍Authorized Agent

You may use an authorized agent to submit a request to access your information, delete your information, or opt out of the sale of your information. To designate an agent for these purposes:

You must provide us with a copy of a written and signed Authorized Agent Designation Form given to your authorized agent; and
If you are a business, proof that you are registered with the Secretary of State to conduct business in California.

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How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, as permitted or required by law.

Our Sites permit you to create an account. When you do, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Miscellaneous

The following additional information relates to our privacy practices:

Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
Changes To This Privacy Policy. We may change our privacy policy and practices over time as indicated by the “last revised”date at the beginning of this Policy. Your continued use of the Sites afterany update to this Policy will constitute your acceptance of the changes.
Accessibility. This Policy may be accessed through audio readers.
Children. The Sites are not directed at children under the age of 16 and we do not knowingly collect information from children under the age of 16 through the Sites. If we become aware that we have receivedPersonal Information from a person under the age of 16, we will delete it in accordance with applicable law.
Information for California Residents – California Shine the Light. California law permits customers in California to request certain details about how their Personal information is shared with third parties, and in some cases affiliates, if personal information is shared for those third parties’ or affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us using the information below. Letters should be addressed to Attn: Legal Department regarding Shine the Light. Any such request must include your name and “California Shine the Light Privacy Rights Request” in the first line of the description and, if sent by mail, must include your street address, city, state, and zip code.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

cashmere@sweaterfunds.com

1-888-577-7987

166 Geary St., Ste. 1500 #1577, San Francisco, CA 94108

Effective Date: October 21, 2021

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