VOLORIDGE INVESTMENT MANAGEMENT, LLC

ONLINE PRIVACY STATEMENT

Voloridge Investment Management, LLC (“Voloridge”, “we”, “our”) is committed to protecting your privacy when you use the Voloridge website (the “Site”). This Online Privacy Statement (the “Statement”) explains how we collect, use, share, and safeguard your information when you use the Site.

For California Residents, we have also prepared a Supplemental Privacy Statement for California Consumers under CCPA (“California Statement”) in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Please review our California Statement below for more information.

What Information We Collect

When you use the Site, Voloridge may collect certain categories of personal information about you either directly from your inputs to the Site, passively through your use of the Site, or from third party and public sources that relate to you. This information is used in the manners described below.

Personal Identifiers: We may collect your name, address, email address, phone numbers and login information used to register on the Site, and other personal information that you may provide – for example, through submission of forms, job applications, or other documents.

Employment Information: When you apply for employment with Voloridge we may collect information including work status, legal status, employment history, salary history or other employment information volunteered on the application forms or through the submission process. Voloridge may also collect this information through third parties related to your employment such as recruiters and/or recruiting platforms, industry associations, and online social media platforms.

Internet or Other Network Activity: Voloridge and Voloridge’s Service Providers may collect non-personal information about your activities in network logs or in cookies to track and collect information about your interactions with the Site. 

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. We use cookies to help identify and track visitors, their usage of the Site, and their website access preferences. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration, customer support and to collect aggregate information for internal reporting purposes.

Visitors who do not wish to have cookies placed on their computers should disable cookies using the information provided below prior to using the Site, with the understanding that certain features may not function properly without the aid of cookies.

If you would like to disable these cookies, you will need to do so using your browser. Different browsers make different controls available to you. Generally, your browser will offer you the choice to accept, refuse, or delete cookies at all times, or those from providers that website owners use i.e., third-party cookies, or those from specific websites.  Each browser’s website should contain instructions on how you can do this.

For further information please refer to: https://www.aboutcookies.org/how-to-delete-cookies/ 

How We Use Your Information

The provision of personal information by you may be necessary for the performance of any contractual relationship with you, where we have a legitimate interest or for business and commercial purposes. For each category of personal information above, we use your personal information to carry out the following purposes:

Regulatory and Legal: Personal information may be disclosed to comply with applicable legal or regulatory obligations including the support of audits, responding to court orders or subpoenas or in response to a government agency or investigating body’s request. We may also use your personal information when we are investigating fraud or other areas of concern where disclosure is legally required or otherwise necessary.

Communications: Personal information will be used by Voloridge to communicate with you about your relationship with us. This includes processing applications, answering requests and questions you make to us or in our recruitment process.

Site Analysis: Personal information may also be used to improve the Site’s performance. 

Other Permitted Use: Voloridge may use your information as otherwise permitted by law, for any other purpose described in this Statement, or as we may notify you.

How We Share Your Information

Service Providers: We may share your information with our affiliates and third parties that serve us for the purpose of operating our business.

Comply with the Law: We may disclose your personal information to comply with any applicable law, regulation or government request or to protect our rights or the rights of our customers, users, partners or others.  In some cases, personal information may be transferred to jurisdictions outside of the United States. Such transfers may be to our Service providers, other affiliated entities, to governmental, regulatory or judicial authorities, auditors, legal advisors or agents as well as to sub-contractors engaged by us.  In these situations, we will seek to put appropriate safeguards in place to maintain the security of your information.

Business Successors or Transfers: If we sell all, or substantially all, of our assets to a third party, your personal information held by us will be transferred as part of the sale. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your personal information as set forth in this Statement.

Information You Elect to Share: You may access other third-party services (Third-Party Services) through the Site by clicking on links to those Third-Party Services from within the Site. Such Services may contain terms and conditions, privacy provisions, confidentiality provisions, or other provisions that differ from the terms and conditions applicable to the Site.  Links to Third-Party Services and websites are provided solely for your convenience.  A link to any Third-Party Services or site is not an endorsement of any kind of the service or site, its content, or its sponsoring organization.  We are not responsible for the privacy policies or practices of these Third-Party Services. 

Children’s Online Privacy Protection Act

The privacy of children online is an important issue to Us.  Voloridge does not seek or knowingly collect personal information from children under the age of 13.  Voloridge requests that children under the age of 13 not disclose or provide any personal information through the Site.  If we learn that we have received information directly from a child who is under the age of 13, we will take appropriate action in accordance with applicable law.  To learn more about the Children’s Online Privacy Protect Act (COPPA) please visit the Federal Trade Commission’s website at https://www.ftc.gov/.

Security of Internet Communications

The Internet is not a secure medium.  We employ reasonable administrative, technical and physical safeguards designed to protect personal information.  When you enter sensitive information (such as a social security number) on the Site, we encrypt that information using secure socket layer technology (SSL) or similar technology during its transmission to the Site.  Unfortunately, no method of transmitting or storing data can be guaranteed to be secure, and we do not assume any responsibility for any harm, loss or damage you may experience from transmission of information by or to Voloridge over the Internet.  If you believe that the security of any account you might have with us has been compromised, please contact us using one of the methods described below.

Changes to This Online Privacy Statement

If we make updates to our U.S. online privacy practices, we will update this Statement with the changes and update the “last updated” date posted at the bottom of the Statement. Any updates to the Statement become effective when we post the updates on this Site.  Your use of the Site following any update to the Statement means that you accept the updated Statement and consent to the use and sharing provisions identified in the Statement.

Contact Us

Questions or concerns related to this policy may be directed to compliance@voloridge.com.

Last Updated:  September 2020

 

CALIFORNIA-STATEMENT

 

Rights for Individuals in California 

 

California enacted the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time, “CCPA”), in 2018, and it is effective as of January 1, 2020.  The CCPA grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.”  If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA.  The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.

 

California Residents’ Rights under the CCPA

 

If your personal information is subject to the CCPA, you may have certain rights concerning your personal information, subject to applicable exemptions and limitations, including the right to: 

1. be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; 
2. not be discriminated against because you exercise any of your rights under the CCPA; 
3. request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“request to delete”); and 
4. request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“request to know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting or selling the personal information; (d) the categories of third parties with which we share personal information; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose.

 

How to Submit a Request under the CCPA

 

You may submit requests to know through the following telephone number 561.231.5770, or through the Site at the following link www.voloridge.com. You may submit requests to delete through the following methods: via email to compliance@voloridge.com or mail to Voloridge Investment Management, LLC, 110 Front Street, Suite 400, Jupiter, Florida 33477.

 

We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent.  Any information gathered as part of the verification process will be used for verification purposes only.  If we cannot verify your identity in accordance with California Law, we may deny your request in whole or in part.

 

Contact for More Information 

 

If you have any questions or concerns about this California-Specific Privacy Policy, please contact compliance@voloridge.com.