Privacy Notice
| Facts | WHAT DOES QUANTSTREET CAPITAL DO WITH YOUR PERSONAL INFORMATION? |
|---|---|
| Why? | Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
| What? | The types of personal information we collect and share depend on the product or service you have with us. This information can include:
When you are no longer our customer, we continue to share your information as described in this notice. |
| How? | All financial companies need to share customer personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customer personal information; the reasons QuantStreet Capital chooses to share; and whether you can limit this sharing. |
| Reasons we can share your personal information | Does QuantStreet Capital share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| For our marketing purposes – to offer our products and services to you | Yes | No |
| For joint marketing with other financial companies | Yes | No |
| For our affiliates’ everyday business purposes – information about your transactions and experiences | No | We don’t share |
| For our affiliates’ everyday business purposes – information about your creditworthiness | No | We don’t share |
| For nonaffiliates to market to you | No | We don’t share |
| Questions? | Call212-537-3877 or go to www.quantstreetcapital.com/contact |
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| Who we are | |
|---|---|
| Who is providing this notice? | EBH Capital Management LLC, which uses the name QuantStreet Capital |
| What we do | |
|---|---|
| How does QuantStreet Capital protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. |
| How does QuantStreet Capital collect my personal information? | We collect your personal information, for example, when you
|
| Why can’t I limit all sharing? | Federal law gives you the right to limit only
State laws and individual companies may give you additional rights to limit sharing. |
| Definitions | |
|---|---|
| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial companies.
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| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies.
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| Joint marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
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Download our privacy notice as a PDF
Full Privacy Policy
Last Modified: 1/2022
Introduction
EBH Capital Management LLC (DBA QuantStreet Capital) (“Company” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website www.quantstreetcapital.com (“Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect on this Website and in email, text, chat, form submissions, and other electronic communications between you and this Website.
It does not apply to information collected by: (1) us offline or through any other means, including on any current or future website operated by the Company or a third party; (2) any third party, including through any application or content (including advertising) that may link to or be accessible from the Website; or (3) Charles Schwab or any other custodian that maintains funds for Company clients.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see the Changes to Our Privacy Policy section below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Children Under the Age of 18
This Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect Personal Information (defined below) from children under 18. If you are under 18, do not provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn that we have collected or received Personal Information from a child under 18 without verification of parental consent, then we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at hello@quantstreetcapital.com.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including information: (1) by which you may be personally identified, such as name, postal address, email address, telephone number, business/employer name and postal address, or other identifiers by which you may be contacted online or offline (“Personal Information”); (2) that is about you but individually does not identify you; and/or (3) about your internet connection, the equipment you use to access our Website, and usage details.
We collect this information directly from you when you provide it to us and automatically as you navigate the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies, as explained in more detail below.
Information You Provide to Us
The information we collect on or through our Website may include: (1) Personal Information and optional comments that you provide by filling in forms on our Website, including forms to request our pitch book, request a phone call, request a video call, or invest with us; (2) records and copies of your correspondence (including email address) if you contact us or chat with us; and (3) your search queries on the Website.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (1) details of your visits to our Website, including traffic data, location data, logs, and other communication data, and the resources that you access and use on the Website; and (2) information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For information about how we respond to web browser “do not track” signals and other mechanisms that enable consumers to exercise choice about behavioral tracking, see the section below called Choices About How We Use and Disclose Your Information.
The information we collect automatically may include Personal Information. It may also include other (non-Personal) information that we may maintain or associate with Personal Information that we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to: (1) estimate our audience size and usage patterns; (2) store information about your preferences, allowing us to customize our Website according to your individual interests; (3) speed up your searches; and (4) recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Cookies (or Browser Cookies).A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Flash Cookies.Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons.Pages of our the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company to gather certain information, such as seeing if you opened an email or counting users who have visited certain pages, and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We collect certain information automatically, but we do not collect Personal Information automatically. However, we may tie automatically-collected information to Personal Information that you or other sources provide to us.
How We Use Your Information
We may use information that we collect about you or that you provide to us, including Personal Information: (1) to present our Website and its contents to you; (2) to provide you with information, products, or services that you request from us; (3) to fulfill any other purpose for which you provide it; (4) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; (5) to notify you about changes to our Website; (6) to inform you of any services we offer or provide through the Website; (7) in any other way we may describe when you provide the information; (8) for any other purpose with your consent; and (9) and for any other lawful purpose.
(10) In addition, we may use your information to contact you by phone or email about our services that may be of interest to you. If you do not want us to use your information in this way, please email hello@quantstreetcapital.com to opt out. For more information, see the Choices About How We Use and Disclose Your Information section below.
(11) We may also use the information we have collected from you to enable us to display advertisements to you using behavioral advertising and “remarketing” campaigns. This means that you may receive advertisements about our services when you browse other websites across the internet. Third party vendors like Google use cookies and other identifiers to serve advertisements based on your past visits to the Website.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Information that we collect or you provide:
- to contractors, service providers, analytics services, email and similar platforms from which we send content (e.g., MailChimp and Substack), and other third parties we use to support our business (e.g., a marketing firm that sets up various campaigns, including behavioral and remarketing campaigns to advertise our services);
- to other investment advisers, financial services companies, or similar entities to facilitate joint marketing;
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred;
- to fulfill the purpose for which you provide it (e.g., if you provide information by completing the Website’s Invest With Us form, we may share that information with our custodian to help set up your account);
- for any other purpose disclosed by us when you provide the information;
- for other reasons with your consent;
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- to enforce or apply our Terms of Use (link at bottom of page) and other agreements, including for billing and collection purposes; and
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of QuantStreet Capital, our customers, or others.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising.You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Promotional Emails from the Company. If you do not wish to receive marketing emails from us, then you can opt out by emailing hello@quantstreetcapital.com. If we have sent you a promotional email, then you may also send us a return email asking to be omitted from future email distributions or click the unsubscribe option in the email.
- Do Not Track Signals. Your web browser may have a “do not track” or similar feature, which sends a signal to our Website requesting that it not engage in behavioral tracking. This Website does not currently respond to that feature.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI website.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to hello@quantstreetcapital.com. However, please know that we do not currently sell data triggering that statute’s opt-out requirements.
Accessing and Correcting Your Information
You may send us an email at hello@quantstreetcapital.com to request a copy of, correct, or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Data Security
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, despite the safety measures we take, the transmission of information via the internet is not completely secure. This means we cannot guarantee the security of your Personal Information transmitted to or on our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ Personal Information, then we will notify you by email or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the policy. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
Contact Information
For questions, comments, concerns, or complaints about this privacy policy or our privacy practices, please contact us at hello@quantstreetcapital.com or 212-537-3877.