PRIVACY POLICY
General
Welcome to 91, Inc.’s website. This privacy policy (this “Privacy Policy”) only applies to information collection and use practices on the 91, Inc. website. 91, Inc.’s website is directed to financial professionals, e.g., independent and insurance broker-dealers, national wirehouses, registered investment advisors and their employees, owners, directors, officers, and contractors (collectively, “Financial Professionals”), and our investors and employees.
Links
There might be links from the 91, Inc. website or portals on the 91, Inc. website to other websites. This Privacy Policy only applies to the 91 Inc. website and not to websites of any other company or organization linked to or through the 91 Inc. website, which may have different policies. 91, Inc. is not responsible for privacy practices or content of such other sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each website that you visit.
Gathering, Modifying and Removing Information
We may request and/or collect personal information on the 91, Inc. website that you might elect to provide to 91, Inc. (“Personal Information”) when, via the 91, Inc. website, you: (a) contact 91, Inc.; (b) use 91 Inc. services; and/or (c) send requests for information, questions, inquires, or comments to 91, Inc. You are not required to provide Personal Information to access the 91, Inc. website. Personal Information may include: (a) contact information (e.g., name, address, phone number and email address); (b) information regarding certain of your preferences related to 91, Inc. or the 91, Inc. website; and/or (c) information regarding how you became aware of the 91, Inc. website.
If you would like to review, correct or remove your Personal Information, please contact 91, Inc. at the address listed under “Contact Us.” 91, Inc. will then make all reasonable efforts to correct your Personal Information from the 91, Inc. active database or discontinue the use of your Personal Information.
Gathering Anonymous Information
91, Inc. might collect non-personal and aggregate information about the use of the 91, Inc. website, such as page hits, number of visits, web pages viewed and the length of visits to the 91, Inc. website (collectively, “Non-Personal Information”). 91, Inc. does not tie this Non-Personal Information to your Personal Information.
Use and Disclosure of Information
The Personal Information that you provide will be available to 91, Inc., our agents, representatives and service providers and contractors, as appropriate, to be used to respond to your inquiries or questions about 91, Inc. and for the purposes indicated or which may reasonably be inferred by your voluntary provision of such Personal Information and otherwise in connection with the conduct of 91, Inc.’s business and operations. For Financial Professionals, this use may include periodic telephone calls and postal and email mailings from 91, Inc. about new products, services or upcoming events offered by 91, Inc. 91, Inc. may also use your Personal Information, alone or in combination with the information submitted by other users, to improve our navigation or infrastructure. Also, we may use Non-Personal Information to improve your experience on the 91, Inc. website and to enhance the 91, Inc. website. Third party contractors or providers of services to 91, Inc. that have access to your Personal Information are also expected to protect such Personal Information in a manner consistent with this Privacy Policy and to use such Personal Information only to carry out the activities or services they are performing for you or for 91, Inc. 91, Inc. might disclose Personal Information and Non-Personal Information, if in our opinion such disclosure is required: (a) by law; (b) to protect and/or defend 91, Inc. rights; and/or (c) to protect the personal safety of any individual. In addition, in the event that all or substantially all of 91, Inc.’s ownership and/or assets are transferred or sold to, or 91, Inc. is merged with, another entity, or there is a change of control of 91, Inc., 91, Inc. may transfer Personal Information and Non-Personal Information to the successor entity.
Internet Communications
Communications and submissions over the Internet might not be secure. Please consider this fact before communicating or submitting any personal or confidential information through the 91, Inc. website.
Notice to California Residents (Do Not Track)
California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how 91, Inc. responds to “Do Not Track” browser settings. 91, Inc. does not currently take actions to respond to Do Not Track signals.
Children’s Privacy
Our website is not directed to minors, and we do not knowingly collect personal information from minors.
Changes
91, Inc. reserves the right to change, modify, amend and/or update this Privacy Policy at any time with or without prior notice at the sole and absolute discretion of 91, Inc. We will not, however, revise our policy to permit the sharing of non-public personal information other than described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.