BuildX collects nonpublic personal information about the Investors from the following sources: subscription forms, investor questionnaires, and other information provided by the Investor in writing, in person, by telephone, electronically, or by any other means (including name, address, nationality, social security number or tax identification number, employment information, and financial and investment qualifications); and transactions (including account balances, investments, and withdrawals and redemptions).
Disclosure of Nonpublic Personal Information
BuildX may share nonpublic personal information about the Investors as permitted by law, including to assist in offering or providing BuildX’s products and services to the Investors. BuildX does not disclose nonpublic personal information about the Investors to nonaffiliated third parties except as permitted by law. For example, BuildX may share nonpublic personal information with nonaffiliated third parties in the following situations:
- To comply with federal, state, or local laws, rules, and other applicable legal requirements
- To comply with a properly authorized civil, criminal, or regulatory investigation or a subpoena or summons by federal, state, or local authorities
- In connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of BuildX’s business
- To protect against or prevent actual or potential fraud, unauthorized transactions (such as money To), claims, or other liabilities
- To BuildX’s service providers (which may include, for example, attorneys, accountants, auditors, administrators, or other professionals) in connection with the administration and operations of BuildX
- To persons acting in a fiduciary or representative capacity on behalf of the Investor (which BuildX has determined it will do only with the Investor’s consent)
Protection of Investor Information
BuildX and its affiliates have adopted written policies and procedures, safeguards, and a security program (collectively, the “Information Security Program”) to protect Investor personal information. The Information Security Program includes physical, electronic, and procedural safeguards that comply with federal standards to protect customer information and includes policies designed to ensure that access to personal and account information concerning Investors is restricted to those employees or agents who need to know that information in the course of their job responsibilities. Pursuant to the Information Security Program, BuildX will destroy, erase, or make unreadable data, computer files, and documents containing nonpublic personal information prior to disposal
The Information Security Program also is designed to identify risks to the confidentiality and security of records containing personal information and includes procedures for assessing the likelihood of and potential damage from such threats. Technical, physical, and administrative safeguards are in place for the protection of personal information and are regularly monitored for effectiveness. In addition, the only third-party service providers permitted to be in possession of Investor personal information are those which WeBuild reasonably believes have appropriate security measures in place to protect that information.