Eleven Systems, LLC
Privacy Policy

Last Updated Date: February 9, 2022

 

This “Privacy Policy” describes the privacy practices of Eleven Systems, LLC (collectively, “Eleven Systems”, “we”, “us”, or “our”) in connection with the www.elevensystems.com website, the application, platform (e.g., 11 Financial, 11 Property, and 11 Messages), and any other website, application or platform that we own or control and which posts or links to this Privacy Policy (collectively, the “Services”), and the rights and choices available to individuals with respect to their information.

Eleven Systems may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

Table of Contents

Personal Information We Collect

Information you provide to us. We collect the following personal information from you (e.g., customers of our Services and investors of investments hosted on our platform) through or in connection with the Services:

  • Contact information, such as your and your authorized users’ first and last name, email addresses, mailing addresses, phone numbers, photo, and social media usernames. We require that you provide an email address and either your first or last name to use the services. Other contact data is optional.
  • Content you choose to upload to the Services, such as documents (e.g., financial statements, investment related documents, property related documents), text, images, audio files, and videos, along with the metadata associated with the files you upload.
  • Profile information, such as your and your authorized users’ username and password that you may set to establish an online account with us and preferences. Please note that your username will be the email address you supplied.
  • Property information, such as property descriptions, files, images, parameters for security cameras, door access logs, notifications and issues created by you and your staff, inventory information, contacts, precise geolocation of your property, budgeting and operations data, and checklists. If you enter a secured door that has an associated security camera, your entry will be recorded as part of the door access log.
  • Financial information, such as financial account information (e.g., account name, account number, transactions, and balances), operational data, financial statements, analytics derived from the operational and account data, and notifications.
  • Investment information, such as data on specific investments, notes that describe specific investments, analytics based on defined investments, names of investors, and notifications.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit to us, any changes you make to the database, activity logs for the applications, and information you provide when you use any interactive features of the Services.
  • Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from authorized family office users. We may receive personal information about you from authorized family office users. For example, an authorized family office user may share your financial information or investment information through or in connection with the Services.

Automatic data collection. If you use our Services or communicate with us, we, our service providers, and ourbusiness partners may automatically log the following types of information about you, your computer or mobile device, and your interactions over time with us:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (such as device identifiers), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area. If you opt to have full geolocation enabled to assist with creating messages or tracking travel (typically only needed for Property services users), then geolocation data is also collected.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

Service delivery. We use your personal information to:

  • Provide and operate the Services;
  • establish and maintain your account or profile;
  • enable security features of the Services, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
  • communicate with you, including by sending you announcements, updates, security alerts, and support and administrative messages; and
  • understand your needs and interests, and personalize your experience with the Services and our communications;
  • provide support and maintenance for the Services, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Services. As part of these activities, we may create aggregated, de-identified or anonymous data from personal information we collect. We may use this aggregated, de-identified or anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our Services.

Marketing. We may send you Eleven Systems-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt out of marketing section below.

Compliance and protection.We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the website or otherwise; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Affiliates. Our corporate parent and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Third parties that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, information technology, email delivery, and marketing).

Business and marketing partners. Third parties with whom we collaborate on joint activities, with whom we have entered into either joint marketing relationships or other joint ventures.

Professional advisors. Professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transfers. Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Eleven Systems or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Your Choices

You have the following choices with respect to your personal information.

Access, Update, or Delete Your Information. If you have established an account with us, you may review, update, or delete certain account information by logging into the account.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies. Please see our Cookie Notice.

Privacy settings. We make available certain privacy settings on the Service, including options to control whether certain information is displayed to other users, such as when investment owners allow investors to view certain information regarding an investment. Users of our mobile application also have the choice whether to allow us to access your precise location data. Your device settings may provide the ability for you to revoke our ability to access location data.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other Sites, Mobile Applications, and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security practices

We employ organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfers

We have offices in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

Our website is not intended for use by children under 16 years of age. If we learn that we have collected personal information through our website or mobile applications from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it. We encourage parents or guardians with concerns to contact us.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our website. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you.

Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the website or mobile applications, or submission of personal information to us after the effective date of any modified Privacy Policy, indicates your acceptance of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to privacy@elevensystems.com. You may also write to us via postal mail at:

Eleven Systems, LLC

Attn: Information Security Manager

221 North Hogan Street, Suite 403

Jacksonville, FL 32202

Your California Privacy Rights

Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at privacy@elevensystems.com or postal mail at 221 North Hogan Street, Suite 4039, Jacksonville, FL 32202. You must put the statement “Your California Privacy Rights” in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete
information.

Notice to European Users

The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom, Switzerland, and the European Economic Area (collectively referred to as “Europe”).

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection laws, regulation, and legislation. Essentially, it boils down to information about an individual, from which that individual is either directly identified or can be identified. It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed). The personal data that we collect from you is identified and described in greater detail in the section Personal Information We Collect.

Controller. Eleven Systems is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation. See the How to Contact Us section above for contact details.

Legal bases for processing. We use your personal information only as permitted by law for the purposes listed below. The European data protection legislation requires us to ensure we have a “legal basis” for each purpose for which we collect personal information. Our legal bases for processing your personal information described in this Privacy Policy are listed below:

  • Where we need to perform a contract that we are about to enter into, or have entered into, with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”)).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”). Generally, we do not rely on your Consent as a legal basis for using your personal information other than in the context of direct marketing communication

We set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information. The purposes identified are explained in greater detail in the section How We Use Your Personal Information.

 

Purpose Category(ies) of Personal Information involved Our Legal Basis for This Use of Personal Information
Service Delivery
  • Contact information
  • Content you choose to upload to the Services
  • Profile information
  • Property information
  • Financial information
  • Investment information
  • Feedback or correspondence
  • Usage information
  • Device data
  • Online activity data
  • Location data
  • Other information
  • Contractual necessity
  • Legitimate Interests

We have a legitimate interest in providing you a good Service, communicate with you, including by sending you updates on our Services, websites and related offers where you have shown interest in similar services from us

Research and Development
  • Contact information
  • Profile information
  • Feedback or correspondence
  • Usage information
  • Other information
  • Device data
  • Online activity data
  • Location data
  • Contractual necessity
  • Legitimate Interests

It is in our legitimate interests that we can monitor and ensure the proper operation of our websites and associated systems and Services

Compliance and Protection
  • Contact information
  • Content you choose to upload to the Services
  • Profile information
  • Property information
  • Financial information
  • Investment information
  • Feedback or correspondence
  • Usage information
  • Device data
  • Online activity data
  • Location data
  • Other information
  • Compliance with Law
  • Legitimate Interests

We have a legitimate interest in ensuring the ongoing security and proper operation of our Services, websites and associated IT services and networks.

Marketing
  • Contact information
  • Content you choose to upload to the Services
  • Communications data
  • Marketing information
  • Other data
  • Device data
  • Online activity data
  • Location data
  • Consent

 

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

Retention. We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. If you request that your personal information be removed/deleted, we will either delete or anonymize it, subject to any laws requiring otherwise, and subject to it being available to delete (see below).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Your rights. European data protection legislation gives you certain rights regarding your personal information. If you are located within Europe, you may ask us to take the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Data portability. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to privacy@elevensystems.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here. If you are based in Europe, you can find your data protection regulator here. If you are based in the UK, you can make a complaint directly to the Information Commissioner’s Office.

Cross-Border Data Transfer. If we transfer your personal information out of Europe or the UK to a country not deemed by the relevant regulatory authority to provide an adequate level of personal information protection, the transfer will be performed:

  • Pursuant to the recipient’s compliance with standard contractual clauses, or Binding Corporate Rules;
  • Pursuant to the consent of the individual to whom the personal information pertains; or
  • As otherwise permitted by applicable European requirements.

You may contact us  if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.