Privacy

Privacy

 

Your Privacy Matters

The Forge Community mission is to connect single family offices, their executives, and the families they serve across the globe by creating a trusted and confidential peer-to-peer network which will enable an exchange of knowledge and resources in an efficient and effective way. To achieve this mission, it is imperative that we protect and safeguard your personal data. Our commitment is to be transparent about any personal data that we collect about you, how it is used and with whom it is shared.

 

This Privacy Policy applies when you use, acknowledge, agree and accept our Services (described below). We offer our users choices about the personal data we collect, use and share as described in this Privacy Policy and the cookie policy.

 

Definitions

The term “data” on its own includes both information that belongs to you and information that belongs to Forge and other Forge Community members.

 

“Personal Data” includes your personally identifiable information (information that, when used alone, can identify you) and your personal usage information (data generated by your use of the platform).

 

Introduction

The Forge Community is an invitation-only online private community made available to select individuals (“Family Office executives/family members”). The Web Site may help Members obtain and share information associated with establishing, managing, and running a family office practice from other peer family offices.

Community features may include, among other things, access to articles, blog posts, webinars and interactive discussions and may make it possible for Members to engage in conversations with other like-minded family office personnel by sharing experiences and knowledge in online discussion forums.

 

Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and find business and career opportunities. Content and data on some of our Services is viewable to non-members (“Visitors”).

 

Our Privacy Policy applies to any Member or Visitor to our Services.

 

Services

This Privacy Policy applies to the Forge Community Web Site and Forge Connect Platform, sites, apps, communications and services (“Services”).

 

Forge (“we” or “us”) will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services; you are agreeing to the Terms and Conditions of the Forge Community Web Site and Platform.

 

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy and updates.

 

Change

Changes to the Privacy Policy apply to your use of our Services after the effective date.

Forge can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

 

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

 

1. Data we collect

 

1.1 Data you provide to us

You provide personal data to create an account with us. This personal data is your data, and we will never sell your personal data.

 

When you share, publish, post or provide information in connection with using our Services, you acknowledge and agree that such information is accessible to all Members [and Visitors, to the extent applicable.]

 

Registration

To create an account, you need to provide personal data including your legal name, an active email address, a phone number and a password.

 

Next, you create your Forge profile (a complete profile helps you get the most from our Services).

 

Profile

You have choices about the information on your profile, such as your education, work experience, skills, photo, city or area and endorsements. You do not have to provide additional information on your profile although profile information helps you to get more from our Services. It is your choice whether to include sensitive information on your profile. Please do not post or add personal data to your profile that you would not want to be made publicly available.

 

Posting and uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data or information about your family office), or respond to a survey.

 

 

1.2 Data from others

You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. You have the right to request that this be removed from the platform or to report it to the community manager.

 

1.3 Service use

We log your visits and use of our Services, including accessing features through mobile apps.

 

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., learning video), participate in the forum, perform a search, install or update one of our mobile apps, or share articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

Our purpose in collecting and analyzing this data is to improve your experience with the platform. We will never share your personal data with others or sell your personal data. Aggregate, blinded data on content performance or application performance may be shared with partners to improve the content or services provided. We are not obligated to publish any information or content provided by you through our Services and we have the rights to remove any information or content in our sole discretion without notice.

 

1.4 Cookies, Web Beacons and Other Similar Technologies

Forge Community and our third-party service providers may use cookies and similar technologies to support the operation of our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device ( e.g., computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. Forge cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

 

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie, or if you delete cookies from your device, you may experience some inconvenience in your use of our digital offerings. For example, you may not be able to sign-in and access your account, or we may not be able to recognize you, your device, or your online preferences.

 

Both Forge and third-party service providers we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below.

 

Information for foreign investors

The Forge Community Sites are intended to be made available only to individuals in the United States, and the information on the Forge Community Sites is only for such persons. Nothing on the Forge Community Sites shall be considered a solicitation to buy or an offer to sell a security, or any other product or service, to any person in any jurisdiction where such offer, solicitation, purchase or sale would be unlawful under the laws of such jurisdiction.

 

1.5 Your device and location

We receive data from your devices and networks, including location data.

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP of your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

 

1.6 Messages

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a Forge connection request, we track whether you have acted on it and will send you reminders. We will also track and monitor public forum participation and will send you notifications.

 

We do not proactively monitor or scan your status updates, private messages or messages within your groups. If you wish to report abuse or violations of our professional community policies, you can contact the community managers.

 

1.7 Other

We are constantly improving our Services, which means we frequently receive new data and create new ways to use data.

 

Our Services are dynamic and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

 

2. How we use your personal data

We use your personal data to provide, support, customize and develop our Services.

 

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and customize, with the help of automated systems and inferences we make, our Services so that they can be more relevant and useful to you and others.

 

2.1 Services

Our Services help you connect with others, stay informed, and engage with your family office group.

 

We use your data to authorize access to our Services.

 

Stay Connected

Our Services allow you to stay in touch and up-to-date with colleagues, partners, clients, and other professional contacts. To do so, you will “connect” with the professionals who you choose, and who also wish to “connect” with you.

 

We will use data about you (such as your profile, profiles you have viewed) to help others find your profile, suggest connections for you and others (e.g. Members who share your contacts, interests or job experiences). You can also opt-in to allow us to use your precise location or proximity to others for certain tasks (e.g. to suggest other nearby Members for you to connect with or notify your connections that you are at a professional event).

 

It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your name, photo, and contact information you have made available through your profile. We will send invitation reminders to the people you have invited.

 

Stay Informed

Our Services allow you to stay informed about news, events and ideas regarding professional topics you care about, and from professionals you respect. We use the data we have about you (e.g., personal data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant content and conversations on our Services. For example, if you let us know that you are interested in a particular topic, we will use this information to personalize content in your feed, suggest that you watch or read related content or engage in Forum threads about that topic.

 

Engage with your Groups

Our Services allow you to engage with your family office group(s) in a private, invitation-only sub-group of the larger Forge Community. Your family office group leader will have access to some of your activity data on the platform, such as your response to events he or she has invited you to, surveys he or she has asked you to participate in and how often you are engaging in group discussions. The family office group leader will have access to aggregate, blinded data on content performance and topic interests that relate to your group and other groups.

 

2.2 Communications

We enable communications between Members. We may also contact you directly. We offer settings to control what messages you receive and how often you receive some types of messages.

 

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your Forge inbox, and other ways through our Services, including push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, and content suggestions. You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices. You may alter your settings to control and limit messages provided by us.

 

We also enable communications between you and others through our Services, including for example invitations, groups and messages between connections.

 

2.3 Marketing

We promote our Services to you and others.

 

We use data and content for invitations and communications promoting membership and network growth, engagement and our Services.

 

2.4 Developing Services and Research

We develop our Services and conduct research.

 

Service Development

We use data, including member feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other.

 

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations at any time.

 

2.5 Customer Support

We use data to help you and address problems.

We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

 

2.6 Aggregate Insights

We use data to generate aggregate insights.

We use your data to produce and share aggregated insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry.

 

2.7 Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) if we think it is necessary for security purposes or to investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm our Members or Visitors.

 

3. How We Share Information

 

3.1 Our Services

Any personal data that you include on your profile and any content you post or social action (e.g. likes, follows, comments, shares) you take on our Services will be seen by others, unless you request to not engage in the national Forge Community and only be seen by members of your Family Office Group.

 

Profile

Your profile is fully visible to all Members of our Services unless you choose to only be visible to members of your Family Office Group. Your settings, and degree of connection with viewing Members, affect the availability of your profile and whether viewing Members can view certain fields in your profile.

 

Posts, Likes, Follows, Comments, Messages

Our Services allow viewing and sharing information including through posts, likes, follows and comments.

• When you share an article or a post (e.g., an update, image, video or article) as part of the national community, it can be viewed by everyone in that group and re-shared anywhere (subject to your settings). Members who participate in the national group will be able to find and see your national community content, including your name (and photo if you have provided one).
• In a Family Office Group, posts are visible to others in the group. Your membership in groups is public and part of your profile, but you can change visibility in your settings.
• When you connect with a person or join a Family Office Group, you are visible to others and that “page owner”.
• When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).

3.2 Communication Archival

Regulated Members may need to store communications outside of our Service.

Some Members (or their employers) need, for legal or professional compliance, to archive their communications and social media activity, and will use services of others to provide these archival services. We enable archiving of messages by those Members outside of our Services. For example, a financial advisor needs to archive communications with her clients through our Services in order to maintain her professional financial advisor license.

 

3.3 Service Providers

We may use others to help us with our Services.

 

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and may look at aggregate data for use of improving their services. Your individual information will not be disclosed or used for other purposes. 

 

However, certain third-party service providers, such as payment gateways and other payment transaction processors (as outlined below), have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.  For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

 

3.4 Stripe

 

As detailed in our Terms of Use, Forge Community charges a fee for access to value added member benefits. These benefits may change over time. We may add or remove certain benefits over time. Forge Community members can elect premium membership each year during their membership renewal cycle. Membership renewal occurs annually, on the anniversary of the last member pledge date. Members have the option to opt-in to premium membership or remain a basic member at no cost. This will happen automatically on the anniversary of the member’s membership, or members can elect in early by selecting the option to upgrade the platform. Individual members can pay online using a credit card via the Forge Community platform. Third parties (family offices, etc.) paying for individual members will be invoiced. Invoices can be paid online via credit/debit card.

Our credit and debit payment processing is currently handled and managed through Stripe, Inc., a third-party processing service (stripe.com) that allows us to accept your payment online.

 

Your data may be stored through Stripe’s data storage, databases, and the general Stripe application.

 

As our direct payment gateway, Stripe stores your credit card or debit card data. Your credit or debit card stored on file with Stripe will be charged on the date of renewal unless you make changes to your account settings in advance of the renewal date. According to our best information, your data is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards. Your subscription transaction data should be stored only as long as is necessary to complete your subscription transaction. After that is complete, your subscription transaction information should be deleted.

 

All direct payment gateways are required to adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

 

PCI-DSS requirements help ensure the secure handling of credit card information by our service provider(s).

 

For more insight, you may also want to visit and review Stripe's Terms of Service or Privacy Policy.

 

3.5 Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

 

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Forge, our Members, personnel, or others. We will attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

 

4. Your Choices & Obligations

 

4.1 Data Retention

We keep most of your personal data for as long as your account is open.

 

We retain your personal data while your account is in existence or as needed to provide you Services or to satisfy legal or regulatory requirements. This includes data you or others provided to us, and data generated or inferred from your use of our Services. Even if you only use our Services when attending a Family Office Group meeting, we will retain your information and keep your profile open until you decide to close your account. In some cases, we choose to retain certain information in a depersonalized or aggregated form.

 

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

 

We provide many choices about the collection, use and sharing of your personal data, from deleting or correcting personal data you include in your profile to controlling the visibility of your posts to communication controls. We offer you settings to control and manage the personal data we have about you.

 

For personal data that we have about you:

• Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
• Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

You may contact us using the contact information below, and we will consider your request in accordance with applicable laws.

 

4.3 Account Closure

We keep some of your personal data even after you close your account.

 

If you choose to close your Forge account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

 

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

 

Information you have shared with others (e.g., messages, updates or group posts) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

 

Forge may terminate your use of the Services immediately and without notice.

 

5. Other Important Information

 

5.1. Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

 

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

 

5.2 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

 

At any time, you can withdraw consent you have provided by going to settings.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Forge Services you have requested) and “legitimate interests”. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

 

5.3 Questions and Contact Information

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, please contact our Privacy Compliance Officer at Chase.Wick@fmr.com.

 

This privacy policy is provided on behalf of Forge Community, a wholly owned subsidiary of FMR LLC.

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[LAST UPDATED April 25, 2022]