Effective June 1, 2021
This Policy applies to our “Services” which include our website at classvipartners.com, including any subdomains
or mobile versions (our “Site”), our proprietary software and platform known as CoPilot (including its website
www.copilotanalytics.com), and other services we may provide to you (e.g. investment banking, wealth management,
business consulting, or other services). Please note that some of our Services are subject to additional privacy notices
that may be required by law, and our clients who have entered into an engagement agreement with us (“Clients”) may
receive those additional privacy notices in connection with those Services. In addition to allowing individuals to browse
our Site (“Users”), our Services allow our Clients to use the Services, and in some cases to designate others who are
authorized to access the Services (“Authorized Users”).
COLLECTION AND USE OF PERSONAL DATA
Personal Data We Collect
Personal Data about you and your identity, such as your name, username, profile data, and other Personal Data you may provide when you register for our Services or as part of a user or account profile.
Personal Data used to contact an individual, e.g. email address or phone number. Biographical Data: Personal Data relating to employment/employer, professional qualifications or affiliations, experience, etc.
Personal Data relating to your use of the Service, including your engagements or other transactions with us.
Personal Data relating to your device, browser, or application e.g. IP address, MAC address, application ID/AdID/IDFA, identifiers from cookies, session history and similar browsing metadata, and other data generated through applications and browsers, including via cookies and similar technologies.
Personal Data related to your financial accounts or potentially your income or assets, depending on the specific Services you have requested that we provide to you.
Personal Data included in content provided by users of the Service in a free-form or unstructured format, such as in a “contact us” box, free text field, in answers provided within CoPilot, in a file, document, or in messages.
How We Collect Personal Data
We collect Personal Data from you directly, for example, when you input information into an online form, register for our Services, or provide Personal Data to our employees so that they can provide certain Services to you.
We may collect certain Personal Data automatically from your devices. For example, we collect Device/Network Data automatically using cookies and similar technologies when you use our Services, access our Sites, or when you open our marketing communications.
We receive Personal Data from third parties with whom we have a relationship, such as third parties who perform background checks for us, or others who may collect information on our behalf.
Data we create or infer:
We may create and infer Personal Data based on our observations or analysis of other Personal Data we process, and we may correlate this data with other data we process about you.
How We Process Personal Data
Client Services and Registration
Using the Services
Billing and Payment
Cookies and Similar Tracking Technologies
We, and certain third parties, automatically collect and process Identity Data, Contact Data, and Device/Network Data
when you interact with cookies and similar technologies on our Services. We may receive this data from third parties to
the extent allowed by the applicable partner. Please note that the privacy policies of third parties may also apply to these
technologies and the Personal Data collected through them.
(ii)for “analytics” and “personalization” purposes, consistent with our business interest in how the Services are used or perform, how users engage with and navigate through our Services, what sites users visit before visiting our Site, and other similar information, and understand characteristics of Users in various technical and geographic contexts; and
(iii)for “retargeting” or similar advertising purposes, so that you can see advertisements from us on other websites. These technologies and the data they collect may be used by advertisers to deliver ads that are more relevant to you based on content you have viewed, including content on our Sites. These tracking technologies may also help prevent you from seeing the same advertisements too many times and help us understand whether you have interacted with or viewed ads we’ve delivered to you. This data collection may take place both on our Sites, as well as on third-party websites that participate in the ad network (e.g. including as part of advertisements delivered by that ad network on a third-party website).
Note: Some of these technologies can be used to identify you across platforms, devices, sites, and services. Our Site currently does not respond to browser-based do not track requests.
Business Purposes of Processing
To Provide our Services and Fulfill Obligations
Internal Processes and Service Improvement
Compliance, Health, Safety & Public Interest
Other Processing of Personal Data
YOUR RIGHTS AND CHOICES
Applicable law may grant you certain rights in your Personal Data. These rights vary based on your state/country of residence, and may be limited by or subject to our exemptions from certain laws. California residents may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes (if any) during the preceding calendar year.
You may submit requests to exercise rights you have by contacting us email@example.com. All rights requests must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data.
You may have the following choices regarding the Personal Data we process, to the extent required under applicable law:
Consent: If you consent to processing, you may withdraw your consent at any time. You may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of our Services.
Direct Marketing: You have the choice to opt-out of or withdraw your consent to marketing communications. You may exercise your choice via the links in our communications or by contacting us.
We implement and maintain reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and though we may enter contracts to help ensure security, we do control third parties’ security processes. We do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.
We retain information for so long as it, in our discretion, remains relevant to its authorized processing purpose, and in any event, for so long as required by law.
CHANGES TO OUR POLICY
We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Services following notice of any changes indicates acceptance of any changes.
Feel free to contact us with questions or concerns:
101 University Blvd / Suite 400
Denver, CO 80206