Your Privacy is Important
At ReFlow, we recognize the importance of protecting the confidentiality and security of information we collect about our clients. We know that you may be concerned about what we do with this information. Please read the following statement to understand how your financial information will be treated as you use our services. This Privacy Policy addresses our use of the data that we collect from you while you use the service. If we change this policy in a material way, we will provide notice of that change. Other data that we exchange through correspondence, document delivery, or otherwise is subject to our confidentiality procedures, but this Privacy Policy applies to the information that we collect via our web site. ReFlow is committed to safeguarding your privacy.
What information do we collect?
We do not collect information about you unless you specifically and knowingly provide it. We limit the collection and use of information to the minimum required to deliver superior service to you. The information we collect includes:
- Information provided by you, such as your name, address, email, and telephone number.
- Information such as the fund’s name, a description of the fund, the fund company, fund value, ticker symbol, primary contact (including contact address, email, telephone number and fax number), fund type (i.e. Morningstar Category), the fund’s net redemptions, the fund’s net asset value, bid information, bid fee, name of bidder, and locale settings, (including currency, date format, time format, and number format) and time when data was entered or changed.
How do we use cookies?
“Cookies” are small data files delivered to your web browser by a web server. Your browser stores the file, which is then sent back to the server each time your browser requests a page from the server. We use cookies. They allow us to help you navigate easily around the web site. Cookies are used for internal purposes only and are not used to collect or disseminate personal information to any third party. We use in-memory temporary cookies that will not be physically stored in your machine. These cookies will be available only when you log in and they expire when you logout.
How do we use your personally identifiable information?
ReFlow does not disclose nonpublic information about you. We also do not disclose nonpublic information about former customers, except as required or permitted by law.
We use your information to help us process transactions and to improve our services to you.
Do we sell your information to third parties?
We do not sell your information to third parties.
As our business evolves, we may transfer the information we have received from you to another company or to a new company if we merge with, sell our assets to or enter into a joint venture with another party to carry on the business.
Who else might we allow to access your information?
We may disclose any information when we believe it necessary for the conduct of our business or where disclosure is required by law. For example, we may be required to share information with the Internal Revenue Service, the Securities and Exchange Commission, or other regulatory and government entities. We also may be compelled by a court order to disclose your information. We have little or no control over making these disclosures or how these entities might use your information. Unless otherwise prohibited by court or regulatory authority order, law or regulation, we will notify you in the event we are compelled to share information about you with regulatory or government agencies.
We are permitted to disclose information if you have provided your consent.
What measures do we use to protect your privacy?
We restrict access to nonpublic personal information about you to those employees who need to know such information to provide services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
We have a variety of security procedures in place to protect your information. We place your account information on the secure portion of our web site. You are required to enter a unique user name and password each time you want to access your account information or other information that we have authorized you to view. Your password should never be shared with anyone. In addition, when you access our site using Netscape Navigator® or Microsoft® Internet Explorer® browsers, Secure Socket Layer (SSL) encryption technology is used to protect your communications through server authentication and data encryption. We also have installed security firewalls on our systems, and we house our servers in secure facilities to prevent unauthorized access to our web site, either through hacking or through physical intrusion. Finally, where appropriate, we enter into non-disclosure agreements with anyone who will have access to our servers or your data.


