LEGAL / PRIVACY
Effective Date: [EFFECTIVE DATE]
01 / INFORMATION WE COLLECT
Information you provide directly: Contact and account information, including name, firm name, title, email, and phone number; firm and transaction information submitted by RIAs in connection with facilitating a derivative or lending transaction, including but not limited to a collar advance, which may include portfolio holdings, position details, and other financial information; identity verification and know-your-customer (KYC) documentation submitted to support transaction setup; and messages and communications sent through the platform, including correspondence with lenders. Information collected automatically: Usage data, including pages visited, features used, browser type, device identifiers, IP address, and referring URLs; and cookies and similar tracking technologies (see Section 6). Information from third parties: Information provided by RIAs, lenders, and identity verification or compliance service providers we work with to facilitate transactions.
02 / HOW WE USE INFORMATION
We use information to operate the platform and coordinate derivative and lending transactions, including but not limited to collar advances, between RIAs and lenders; verify identity and support KYC and anti-money laundering compliance; communicate with users about accounts, transactions, and platform updates; maintain, secure, and improve the platform; detect and prevent fraud, abuse, and technical issues; and comply with applicable law, regulation, and legal process.
03 / HOW WE SHARE INFORMATION
We share information with RIAs and lenders as necessary to facilitate a derivative or lending transaction, including but not limited to a collar advance, at the direction of the party submitting the transaction; with service providers that support our operations, such as hosting, identity verification, and data storage, who are bound by confidentiality and data protection obligations; with our professional advisors, including legal, compliance, and audit advisors, as needed; to comply with law, regulation, subpoena, or other legal process; and in connection with a merger, acquisition, financing, or sale of assets. We do not sell personal information.
04 / DATA SECURITY
We use administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
05 / FINANCIAL INFORMATION
Because Koladen facilitates transactions involving nonpublic personal financial information, certain data handled through the platform may be subject to the Gramm-Leach-Bliley Act (GLBA) and its Privacy and Safeguards Rules. We maintain safeguards designed to protect this information consistent with applicable requirements.
06 / COOKIES AND TRACKING TECHNOLOGIES
We and our service providers use cookies and similar technologies to operate the website, remember preferences, and understand usage. You can control cookies through your browser settings; disabling cookies may affect site functionality.
07 / DATA RETENTION
We retain information for as long as necessary to fulfill the purposes described in this policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements.
08 / YOUR RIGHTS AND CHOICES
Depending on your location, you may have the right to access, correct, delete, or restrict our use of your personal information. To exercise these rights, contact us at privacy@koladen.com. California residents: You have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, request deletion, and opt out of the sale or sharing of personal information. We do not sell personal information.
09 / CHILDREN’S PRIVACY
Our website and platform are not directed to individuals under 18, and we do not knowingly collect personal information from children.
10 / THIRD-PARTY LINKS
Our website may contain links to third-party sites. We are not responsible for the privacy practices of those sites and encourage you to review their policies.
11 / CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. Material changes will be reflected by updating the effective date above.
12 / CONTACT US
Questions about this policy or our data practices can be directed to legal@koladen.com.