Importantly, VCM wants you to know that we do not sell or rent the personal information we may have about you to anyone and we do not share your personal information with outside companies for the purpose of selling their products or services to you.
NOTE TO RESIDENTS OF THE EUORPEAN UNION: To comply with the requirements of the European Union’s (“EU”) General Data Protection Regulation (“GDPR”) for our EU clients/investors, this Policy outlines the legal basis on which we process your personal information and provides other disclosures required by the GDPR.
- About Us
- The Information We May Collect About You
- How We May Collect Information About You
- How We May Use Your Information
- Disclosure of Your Information
- Your Communication Preferences
- Data Retention
- Notice to European Residents – EU Specific Terms
- Contact Us
1. About Us
VCM is an investment firm founded in 2020 which focuses on alternative investments. VCM manages $800+ million on behalf of high net worth individuals and institutions and employs a staff of 30+ corporate professionals and 170+ site level employees. Our diverse range of investment strategies encompass real estate, private equity and public market alternatives. We prioritize commonsense investing and preservation of capital across all strategies.
2. The Information We May Collect About You
VCM Collects your Personal Information through the use of this VCM Website and other VCM software platforms including the investor portal. Further, VCM collects information from you directly as a client or prospective client. The types of information VCM collects and the extent to which it is used depends on the context and nature of your interactions with us. We may collect or receive the following types of information (collectively “Personal Information”) from and about you:
a. Identity Information (i.e. full name, government identification number or social security number, date of birth, marital status, residency status and other affiliations);
b. Contact Information (i.e. mailing address, physical address, email address and telephone number);
c. Business Information (i.e. company name, company contact information, title, department and industry type);
d. Financial Information (i.e. assets, net-worth, credit report, income and financial account details);
e. Transaction Information (i.e. payments to and from VCM, investments made with VCM and other details of your interactions with VCM);
f. Technical Information (i.e. internet protocol (IP) address; login/profile data, browser type and information from Google Analytics data collection services, including usage data on how the VCM website and investor portal are used);
g. Marketing and Communication Information (i.e. preferences in receiving marketing information from VCM and communication preferences); and
h. Background Information (i.e. information provided by third-party due diligence screening about you to ensure disclosure, honesty and lawfulness in our interactions.
3. How We Collect Information About You
VCM collects Personal Information from you in the following ways:
a. Direct Interactions: most of the Personal Information we collect about you is obtained directly from you when you apply for or invest with us, whether in person, by mail, phone or electronically;
b. Automated Technologies: When you interact with the VCM website, we collect Technical Information and Transactional Information about you. We do not collect your identity information or contact information until you provide it to us; and
c. Third Party Sources: We may gain or verify Personal Information from consumer or investigative reporting agencies, investigative sources or public sources.
4. How We May Use Your Information
VCM uses your personal information in the following ways:
a. to perform on the contract that you have entered into with us or are about to enter with us;
b. to communicate with you as an investor or potential investor;
c. to make financial decisions based on legitimate business interests;
d. for audit and debt collection;
e. for fraud prevention and to comply with federal and state Anti-Money Laundering Requirements and other laws; and
f. for statistical analysis.
5. Disclosure of Your Information
VCM does not disclose Personal Information about our applicants, investors or former investors to anyone outside of VCM and its affiliated companies, except with your permission or as required by law. Importantly, we want you to know that:
- we do not sell or rent your Personal Information to anyone;
- we do not share your Personal Information with outside companies for the purpose of advertising or selling their products or services to you; and
- we restrict access to your Personal Information to those employees who need to know it to provide services to you.
VCM may share your Personal Information with third-parties as authorized by you or, when it is in the legitimate interest of VCM. Your Personal Information may be disclosed to affiliated and unaffiliated third-parties in the following circumstances:
a. to enable a third-party, hired by or working with VCM, to perform business services or functions on our behalf in order to serve you;
b. to facilitate the processing of a transaction or service requested by you;
c. as required by law enforcement agencies to prevent fraud of illegal activities;
d. as required by government or regulatory agencies to comply with law or regulations; and
e. to allow authorized persons to respond to subpoena, warrant or court order.
It is VCM’s policy to safeguard your Personal Information through written privacy policies and physical, electronic and procedural protections, including confidentiality agreement.
6. Your Communications Preferences
If you wish to opt-out of receiving marketing communications from us, please reach out to us at the contact provided in the Contact Us section below. Although you may opt-out of the use of your Personal Information for marketing purposes, we may still use your Personal Information for non-marketing purposes.
7. Data Retention
VCM retains your Personal Information consistent with our Records Management Policy or to satisfy any legal, accounting or governmental reporting requirements. Due to the nature of our business, we may be required to keep your records of your Personal Information in order to comply with US law and regulations.
9. Notice to European Residents – EU Specific Terms
a. Legal Basis for Processing Your Personal Information: we will only process your Personal Information where we have a legal basis to do so. The legal basis will depend on the reason(s) we collected and need to use your Personal Information. The different legal bases we rely on are:
i. Consent: where you have told us, you consent to us processing your Personal Information for a specific purpose, such as when you invest with us;
ii. Legitimate Interest: where the processing is necessary for us to conduct our business but not where our interests are overridden by your rights or interests. This may include processing your Personal Information to inform you of changes to our services or to provide you with information about other services we offer;
iii. Contractual Necessity: where the processing of your Personal information is necessary based on your legal relationship with us;
iv. Legal Claims: where the processing of your Personal Information is necessary for the establishment, exercise or defense of legal claims; and
v. Legal Obligation: where we are required to process your Personal Information by law.
b. Transfer of Personal Information: This website is published in the United States and is governed by United States law. If you are located within the European Union, you should be aware that your Personal Information will be processed in the United States. We may transfer your Personal Information outside of the European Economic Area (“EEA”):
i. in order to store it;
ii. in order to enable us to provide services to and fulfill our contract with you;
iii. in order to facilitate the operation of our business, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
c. Your Rights: you have the following rights under certain circumstances:
i. to be provided with a copy of your Personal Information held by us;
ii. to request the recertification or erasure of your Personal Information held by us;
iii. to request that we restrict the processing of your Personal Information (while we verify or investigate your concerns);
iv. to object to the further processing of your personal information, including the right to object to marketing;
v. to request that your provided Personal Information be moved to a third party; and
vi. to withdraw consent without detriment at any time if the processing of your Personal Information is based on consent without detriment at any. Such withdrawal will not affect the processing of your personal data prior to the withdrawal.
d. How to Exercise Your Rights: you can exercise your rights listed above at any time by contacting us at firstname.lastname@example.org or email@example.com. The exercise of the above rights might be subject to certain conditions and we may require further information from you before we can respond to your request. If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.
10. Contact Us
Vukota Capital Management LLC
5251 DTC Parkway, Suite 1150
Greenwood Village, Colorado 80111
Attn: Legal Department
Last Updated: May 6, 2020