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Privacy Policy

Effective: June 12, 2023

 

Accordant Investments (“Accordant”, “we” or “us”) has a firm commitment to privacy. The following discloses our information gathering and dissemination practices for this website: accordantinvestments.com.

This Privacy Policy describes our practices regarding information that could be used to identify you or that is associated with information that identifies you (“Personal Information” or “Personal Data”) when you use the Site or in connection with an actual or potential business relationship with us. This Privacy Policy concerns only the Site and does not concern any website to which the Site may link. We do not have control over the data practices of these third-party sites and those practices are governed by the sites’ own privacy policies. If you choose to visit these third-party sites, you should review their privacy policies to ensure that you understand and are comfortable with their practices concerning your Personal Information. Except as set forth in this Privacy Policy, Accordant will not share, sell, or rent individual Personal Information with anyone without your advance permission or unless ordered by a court of law.

This Privacy Policy does not encompass our privacy practices with respect to any nonpublic Personal Information we may collect from you as an investor in investment vehicles that we sponsor or manage, and that is not collected through this Site. We address these practices in separate notices to investors or potential investors.

 

The Types of Personal Information We Collect About You Through The Site

When you enter and browse the Site, we may collect two different types of information about you: information you provide to us, and information we collect automatically through technology.

Personal Information You Provide to Us

In order to obtain access to certain information or materials provided via the Site, you may have to provide Personal Information, including but not limited to your name, e-mail address, mailing address and phone number. You may also provide this information when you contact us with inquiries (for example, through the contact form on our Site). Additionally, we may collect and retain a record of all communications with you. This site gives users the option to remove their information from our database to stop future communications. You can send requests to info@accordantinvestments.com.

Accordant also works with third-party website operators to provide services such as document sharing and portfolio management (“Portal Sites”). When you input Personal Information to one of Accordant’s Portal Sites, you are providing that information to a third-party. Accordant’s Portal Sites may utilize framing techniques to make it appear that the user is still on the Site when the user is actually on a Portal Site. For example, if you are on a page that has the look and feel of www.accordantinvestments.com, but the URL listed in your browser is a different URL than www.accordantinvestments.com, then any information you provide is being collected by this third-party and not governed by this Privacy Policy.

When you leave the Site and are transferred to a Portal Site, you may be notified that you are no longer on the Site. You should carefully review the privacy policy and terms of use for any Portal Site before using and providing Personal Information through a Portal Site. The operators of such Portal Sites may share the information you enter with Accordant.

Personal Information We Collect Automatically Through Technology

We may collect information about you automatically using technology. For example, we may collect your Internet Protocol or IP address each time you request a page during a visit to the Site. (An IP address is often associated with the portal through which you enter the Internet.) At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site.

We collect information about your use of the Site through cookies (see the “Cookies and How We Use Them” section below).

The technical methods we use on the Site may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send our Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that is personally identifiable.

During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving our websites, and for any other purpose to the extent permitted by applicable law.

Other examples of data we may automatically collect include:

  • The kind of browser or computer you use.
  • State or country from which you accessed the Site.
  • Date and time of your visit.
  • Name of your Internet service provider.
  • Web page you linked to our Site from.
  • Pages you viewed on the Site.

This information is collected to help us administer and operate the Site, better understand how users interact with and access the Site, and understand the types of users access the Site.

Cookies and How We Use Them

This website stores cookies on your computer with the help of HubSpot. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our website visitors. Cookies are small text files that may be placed on your browser when you visit our Site. In particular, the Site uses Google Analytics to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. This includes compiling statistical information concerning, among other things, the frequency of your use of our Site, the pages visited, and the length of each visit, as well as information about your computer, operating system, internet service provider, IP address browser, language, and country. The information generated by Google Analytics about your use of the Site (including your IP address) will be transmitted to and stored by Google, Inc. in the United States. You can prevent your data from being collected by Google Analytics on our Site by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser. For more information on Google Analytics privacy practices, read here and, for information on Google Analytics cookies expiration, read here.

The Site also uses a session cookie to maintain a user session throughout the user’s visit to the Site. The cookie contains no Personal Information, and the associated session automatically expires after you leave the Site. Because this cookie is essential for using and navigating the Site, you cannot refuse it. Moreover, we use a cookie to record your agreement to our use of cookies on our Site.

By choosing to use the Site after having been notified of our use of analytics cookies in the ways described in this Privacy Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgment of your consent, you agree to such use.

Using the settings of your Internet browser, you may be able to choose to have your computer warn you each time a cookie is being sent, or to turn off all cookies. Consult your browser help menu to learn more about your options. If you disable cookies, you may not have access to many features that make your browsing of our Site smoother, and some of our services may not function properly. For more information on cookies and deletion of cookies, please visit: www.allaboutcookies.org.

Other Types of Personal Information We Collect About You

We may collect Personal Information from you in connection with an actual or potential business relationship with us (for example, if you are a supplier). The data we collect includes information that you voluntarily give to us, such as your payment information, business card, or contact details. We will use this information to develop a business relationship and in a manner consistent with the purpose you gave the information for.

How We Use Your Personal Information

Personal Information. We use Personal Information we collect about you when you visit and browse the Site as part of our normal business operations, and to send you communications either about your interactions with us or about features of the Site, including any future changes to this Privacy Policy. We may use your Personal Information for marketing, research and other business purposes (with your consent if required by the applicable law), and we may associate your Personal Information with other information we collect about you, such as details about your usage patterns and interests.

We may also use the information you provide to improve the Site or our services, to customize your experience on Site, to serve you specific content, or for other business purposes.

Non-personally identifiable information. We may use non-personally identifiable information that does not personally identify you, including anonymous information and aggregate data, in order to understand better how our visitors use the Site, research our visitors’ demographics, interests, and behavior, improve the Site, provide visitors with customized services and information, and for other similar purposes. We may share this information with others for information or promotional purposes, and may use non-personally identifiable information in any manner permitted by law. When any non-personally identifiable information is combined with other information that identifies you, it will be treated as Personal Information in accordance with this Privacy Policy.

Sharing With Third Parties

Accordant may share your Personal Information with third-party service providers to facilitate our services or platform functions on our behalf, in particular providers of hosting, cloud services and other information technology services providers; email communication software providers; web analytics services (for more details on the third parties that place cookies through the Site, please see the “Cookies and How We Use Them” section above). These companies and individuals may have access to your Personal Information as needed to perform their functions.

We may also share your Personal Information, as well as certain aggregated demographic information that does not identify you personally, with our business partners or affiliates in order to provide services and offerings to you.

We will share Personal Information:

  • When we believe that such disclosures are required by law, regulation, legal process, subpoena, document request or governmental or legal request;
  • To enforce our Terms of Use, to cooperate with law enforcement, to protect your or our safety or security, including the safety and security of property that belongs to you or Accordant, or to protect the safety and security of our websites, databases or third parties, including the safety and security of tangible or intangible property that belongs to us or to third parties;
  • To protect Accordant against liability; and
  • In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of Accordant or one or more of its businesses to another entity, whether an affiliate or a third party, in which case user information may be shared in the diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction; Personal Information may also be one of the transferred assets.

Protection of Information

Accordant uses reasonable technical, administrative and physical methods to maintain the integrity and security of our databases, including firewalls. Please be aware, however, that there is no absolute guarantee of security on the Internet. You use our Site and send us information at your own risk.

Your California Privacy Rights

California Consumer Privacy Act (CCPA)

Some Personal Information collected by Accordant from California residents outside of this Site may be subject to the provisions of the CCPA. For such data, Accordant will provide such consumers with applicable CCPA notices at the time of collection.

“Shine the Light” Law

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Accordant does not share your Personal Information with third parties for their direct marketing purposes.

How We Respond to “Do Not Track” Signals

Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Children

Accordant does not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to Accordant through the Site, please contact us and we will endeavor to delete that information from our databases.

Information Sharing for Marketing Purposes

Federal law gives you the right to limit information sharing between affiliated entities for marketing purposes. You may limit our affiliates from marketing products or services to you based on your personal information that we collect and share with them. This information includes your date of birth, email and physical addresses, bank account and other account information. To limit information sharing for marketing purposes, please contact us at info@accordantinvestments.com Your choice to limit marketing offers from our affiliates will remain in effect until you tell us to make a change.

Accessibility Statement

Accordant is committed to ensuring digital accessibility for people with disabilities. We are continually improving the user experience for everyone and applying the relevant accessibility standards.

Feedback

We welcome your feedback on the accessibility of Accordant Investments. Please let us know if you encounter accessibility barriers on Accordant Investments: