Privacy Policy
Effective date: February 22, 2024
At The Criterion Fund, we take your privacy seriously. Please read the following to learn how we treat your personal information. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.
You may print a copy of this Privacy Policy directly from this page.
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
Personal Data
Categories of Personal Data We May Collect
This chart details the categories of Personal Data that we may collect:
Category of Personal Data
Examples of Personal Data We Collect
Categories of Third Parties With Whom We Share this Personal Data:
Profile or Contact Data
· First and last name
· Phone number
· Mailing address
· Unique identifiers such as passwords
· Service Providers
Identifiers
· Social security number
· Driver’s license number
· Passport number
· Service Providers
Payment Data
· Bank account number, credit card number, debit card number or any other financial information
· Billing address, phone number, and email
· Service Providers
Commercial Data
· Purchase history
· Information from a successfully completed electronic check transaction
· Service Providers
Device/IP Data
· IP address
· Device ID
· Domain server
· Type of device/operating system/browser used to access the Services
· Service Providers
· Analytics Partners
Web Analytics
· Web page interactions
· Referring webpage/source through which you accessed the Services
· Non-identifiable request IDs
· Statistics associated with the interaction between device or browser and the Services
· Service Providers
· Advertising Partners
· Analytics Partners
Consumer Demographic Data
· Age / date of birth
· Zip code
· Gender
· Race
· Ethnicity
· Service Providers
· Advertising Partners
· Analytics Partners
Professional or Employment-Related Data
· Job title
· Job history
· Service Providers
Geolocation Data
· IP-address-based location information
· Service Providers
· Advertising Partners
· Analytics Partners
Other Identifying Information that You Voluntarily Choose to Provide
· Identifying information in emails or letters you send us
· Service Providers
· Advertising Partners
· Analytics Partners
· Parties You Authorize, Access or Authenticate
Other
· Internal Revenue Service Form W-9.
Investors must also provide other information sufficient to meet regulatory “suitability” requirements for investing through the Services. Depending on the nature of the offering, this information will include: (i) information concerning an Investor’s net worth and income; (ii) information concerning his or her residency; and (iii) other information we might request to determine whether an Investor qualifies for a particular investment.
· Service Providers
The subsections below identify the categories of Personal Data that we may collect. Note that we receive your Personal Data both from you and from Third Parties, and we disclose it to service providers or other parties only for the business purposes listed in this Privacy Policy:
Site Visitors
The following subsection applies only if you are a visitor to the The Criterion Fund website and you do not sign up for an account:
Internet or other similar network activity information.
Examples of Personal Data Collected:
IP address
Device ID
Domain server
Type of device/operating system/browser used to access the site
Geolocation data.
Investors
The following subsection applies if you wish to invest through the Services, which requires that you fill out information in our 3rd party investment management software. This may include items such as:
Personal identifiers.
Examples of Personal Data Collected:
First and last name
Social Security number
Driver’s license number
E-mail
Phone number
Mailing address
Customer records identified by state law.
Examples of Personal Data Collected:
A copy of your drivers’ license, passport or other government issued identification
Bank account number, credit card number, debit card number or any other financial information
Commercial information.
Examples of Personal Data Collected:
Information from a successfully completed electronic check transaction
Internet or other similar network activity information.
Examples of Personal Data Collected:
IP address
Device ID
Domain server
Type of device/operating system/browser used to access the Services
Geolocation data.
Protected classification characteristics under state or federal law
Professional or employment-related information.
Age or date of birth.
Additional Qualification Information.
Investors may complete an Internal Revenue Service Form W-9. Investors may also provide other information sufficient to meet regulatory “suitability” requirements for investing through the Services. Depending on the nature of the offering, this information will include: (i) information concerning an Investor’s net worth and income; (ii) information concerning his or her residency; and (iii) other information we might request to determine whether an Investor qualifies for a particular investment.
The following information applies to all users.
Sources of Personal Data
We collect Personal Data about you from:
You:
when you provide such information directly to us, and
when Personal Data about you is automatically collected in connection with your use of our Services.
Our subsidiaries and affiliates (together, “Affiliates”), when they provide us with Personal Data about you.
Third parties, when they provide us with Personal Data about you (“Third Parties”). Third Parties that share your Personal Data with us include:
Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
Social networks connected to the services. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your account with us.
Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services
To meet or fulfill the reason you provided the information to us.
To provide support and assistance for the Services.
To create and manage your account or other user profiles.
To personalize website content and communications based on your preferences, including targeted offers and ads served through the Services.
To process orders or other transactions.
Improving the Services, including test, research, internal analytics and product development.
To improve and develop the Services, including testing, research, analysis and product development.
Doing fraud protection, security and debugging.
For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
Marketing the Services
Marketing and selling the Services
Corresponding with You
Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about The Criterion Fund or the Services.
Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
Protecting the rights, property or safety of you, The Criterion Fund or another party.
Enforcing any agreements with you.
Responding to claims that any posting or other content violates third-party rights.
Resolving disputes.
As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services.
We may occasionally send you text messages to schedule calls, tell you about investment opportunities or send other communications. Reply STOP to unsubscribe. Message frequency may vary. Message and data rates may apply. Carriers are not liable for delayed or undelivered messages.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
Hosting, technology and communication providers.
Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or control.
Custodial or escrow providers.
Staff augmentation and contract personnel.
Payment processors.
Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
Ad networks.
Data brokers.
Marketing providers.
Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
Companies that track how users found or were referred to the Services.
Companies that track how users interact with the Services.
Our Affiliates.
Business Partners. These parties partner with us in offering various services. They include:
Businesses that you have a relationship with.
Companies that we partner with to offer joint promotional offers or opportunities.
Parties You Authorize, Access or Authenticate.
Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services).
Social media services (if you intentionally interact with them through your use of the Services).
Third-party business partners who you access through the Services.
Other parties authorized by you.
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Tracking Tools, Advertising and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We may use the following types of Cookies:
Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. In particular, the site uses:
Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
Information about Interest-Based Advertisements:
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.
We may retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 13; if you are a child under 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Data, please contact us.
No communication by The Criterion Fund, Inc. or any of its affiliates (collectively, “The Criterion Fund”), through this website or any other medium, should be construed or is intended to be a recommendation to purchase, sell or hold any security or otherwise to be investment, tax, financial, accounting, legal, regulatory or compliance advice. Nothing on this website is intended as an offer to extend credit, an offer to purchase or sell securities or a solicitation of any securities transaction.
The material contained on this website is not intended to be a recommendation or investment advice, does not constitute a solicitation to buy, sell or hold a security or investment strategy and is not provided in a fiduciary capacity. The information provided does not take into account the specific objectives or circumstances of any particular investor or suggest any specific course of action. The information represents The Criterion Fund’s view of the current market environment as of the date appearing above. There can be no assurance that any The Criterion Fund fund or investment will achieve its objectives or avoid substantial losses. Investment decisions should be made based on an investor’s objectives and circumstances and in consultation with her or her financial professionals. Past performance is no guarantee of future results.
All research and other information provided on this website has been prepared for informational purposes only and The Criterion Fund assumes no liability or responsibility for any errors or omissions in the content of this website or any linked website.
Any financial targets or returns shown on the website are estimated predictions of performance only, are hypothetical, are not based on actual investment results and are not guarantees of future results. Estimated targets do not represent or guarantee the actual results of any transaction, and no representation is made that any transaction will, or is likely to, achieve results or profits similar to those shown. In addition, other financial metrics and calculations shown on the website (including amounts of principal and interest repaid) have not been independently verified or audited and may differ from the actual financial metrics and calculations for any investment, which are contained in the investors’ portfolios. Any investment information contained herein has been secured from sources that The Criterion Fund believes are reliable, but we make no representations or warranties as to the accuracy or completeness of such information and accept no liability therefor.
Private placement investments are NOT bank deposits (and thus NOT insured by the FDIC or by any other federal governmental agency), are NOT guaranteed by The Criterion Fund or any other party, and MAY lose value. Neither the Securities and Exchange Commission nor any federal or state securities commission or regulatory authority has recommended or approved any investment or the accuracy or completeness of any of the information or materials provided by or through the website. Investors must be able to afford the loss of their entire investment.
Investments in private placements are speculative and involve a high degree of risk and those investors who cannot afford to lose their entire investment should not invest. Additionally, investors may receive illiquid and/or restricted securities that may be subject to holding period requirements and/or liquidity concerns. Investments in private placements are highly illiquid and those investors who cannot hold an investment for the long term (at least 5-7 years) should not invest. Real estate and other alternative investments should only be part of your overall investment portfolio.
Articles or information from third-party media outside of this domain may discuss The Criterion Fund or relate to information contained herein, but The Criterion Fund does not approve and is not responsible for such content. Hyperlinks to third-party sites, or reproduction of third-party articles, do not constitute an approval or endorsement by The Criterion Fund of the linked or reproduced content.
Investing in securities or real property investments (the ""Investments"") listed on The Criterion Fund pose risks, including but not limited to market risk, credit risk, interest rate risk, and the risk of losing some or all of the money you invest. Before investing you should: (1) conduct your own investigation and analysis; (2) carefully consider the investment and all related charges, expenses, uncertainties and risks, including all uncertainties and risks described in offering materials; and (3) consult with your own investment, tax, financial and legal advisors. Such Investments are only suitable for accredited investors who understand and willing and able to accept the high risks associated with private investments.
Investing in private placements requires long-term commitments, the ability to afford to lose the entire investment, and low liquidity needs. This website provides preliminary and general information about the Investments and is intended for initial reference purposes only. It does not summarize or compile all the applicable information. This website does not constitute an offer to sell or buy any securities or other investments. No offer or sale of any Investments will occur without the delivery of confidential offering materials and related documents. This information contained herein is qualified by and subject to more detailed information in the applicable offering materials. The Criterion Fund is not registered as a broker-dealer. The Criterion Fund does not make any representation or warranty to any prospective investor regarding the legality of an investment in any The Criterion Fund Investments.
Our site may use a third party service to match browser cookies to your mailing address. We may then use another company to send special offers through the mail on our behalf. Our company never receives or stores any of this information and our third parties do not provide or sell this information to any other company or service