Last Updated: February 17, 2021

Privacy Policy

The following policy applies to prospective member sand members doing business in and regulated by U.S. market regulators.

Welcome to the website (“Site”) of ReFlow Services, LLC and ReFlow Fund LLC, and their affiliates collectively ReFlow (“ReFlow,”“we,” “us”). This privacy policy (“Policy”) explains what personal and other data we collected through the Site, other interactions with us, and through third-party data providers (collectively the “Services”), how we use and share that data, and your choices concerning our data practices. This Privacy Policy forms part of our Terms of Service, which are available at:

By providing us with your personal data when using the Services you agree to the data practices described in this Privacy Policy. If you do not agree to these practices, please do not access or use the Services. Before you submit any Personal Data (as defined below) to ReFlow through the Services, please review this Privacy Policy carefully, and contact us if you have any questions. For details on sharing your Personal Data, see “Sharing and Disclosure” section below.

Personal Data You Voluntarily Provide Us

Personal Data. When you interact with our Services, contact us, or become a user, we collect information you voluntarily give us that alone or in combination with other information could be used to identify you. This includes for instance, your‎ name, contact information (including postal address, email address, phone number), username, password, social security number, tax identification number, bank account information, other financial information related to accredited investor status and wire transfer instructions, as well as any other information you provide to us, including but not limited to, by joining our mailing list or seeking to become a member. For purposes of this Policy, “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a member or a member representative. It does not include de-identified or aggregate information, or public information lawfully available from governmental records. 

Information We Receive Automatically From Your Use Of The Site

When you visit, use, and interact with the Site, we may receive certain information about your visit, use or interactions with the Site. For example, we may monitor the number of people that visit our Site, peak hours of visits, the domains our visitors come from (e.g.,,, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Chrome, etc.), broad geographical information, and Site-navigation patterns. The types of information we collect depends on the type of device used and its settings.

Information We Receive From Third Parties

We may also collect personal data from third parties, such as parties that interact with us, including other financial institutions, product sponsors, business partners and contacts, service providers, background check companies, recruiters or referral sources, subscription information or analytic services, public sources, government records and sources, and other parties that interact with us or store information on our systems.

Types Of Personal Data We Collect

In particular, in the past twelve (12) months, we may have collected and disclosed the following categories of personal data for business purposes to our third-party service providers, our affiliates and business partners, and regulators/government agencies. We may also continue to collect these categories of Personal Data.

Categories of Information

Address and other identifiers

Name, postal address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers

Characteristics of protected classifications

Age, gender, and marital status

Unique and online identifiers

IP address, device IDs, browsing history, search history, and information on consumer’s interaction with a website

Internet or other electronic network activity information

Browsing history, search  history, settings, and information regarding an individual’s interaction with an internet website, application, or advertisement, device information, including name of device and operating system, cookies and pixel tags, city of login, and other data that your browser automatically sends

Audio or video footage or other visual information

Visual copy of Government Issued ID

Professional or Employment Information


The table includes examples in each category, but these examples are not exclusive. In addition, we may draw inferences about you or the entity you represent based on the information provided, such as individual preferences or characteristics, and we may collect and use information as described when collecting the information. We may also receive Personal Data that individuals provide to use or store on our system.

Cookies And Marketing

Cookies. In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze usage more accurately. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features. In order to personalize your use of the Site, we may use local shared objects, also known as Flash cookies, to display content based upon what you view. Flash cookies are different from browser cookies (discussed above) because of the amount and type of information they generate, and how they store that information. Cookie management tools provided by your browser will not remove Flash cookies. When you visit the Site or view one of our emails, we may use pixel tags or “clear” gifs to track links and/or similar technology to note some of the pages you visit on our Site and to personalize your experience.  Pixel tags are a technology similar to cookies that can be embedded in online content or within the body of an email for the purpose of tracking activity on websites (for example, to know when content has been shown to you), or to know when you have viewed particular content or a particular email message.

Analytics and Tracking Technologies. We may, and we may allow third-party service providers, to use cookies (as noted above) or other tracking technologies (e.g., Google Analytics), to help us understand your use of our Site and collect information about your browsing activities over time and across different websites. For more information on how Google uses this data, go to  Please note that while we provide these links for your convenience, we do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.

How We Use Your Personal Data

In the past twelve (12) months, we may have collected and used Personal Data for the following purposes; 

To process and facilitate transactions and maintain accounts. 

To operate, maintain, and improve the Site, products, and services. This includes use of personal and other information to support delivery of our services under contract, assist with service requests, monitor for errors, remedy security or technical issues, and analyze website and application performances. 

To communicate with you, respond to comments and questions, verify permission access, and provide customer service. 

To send information including confirmations, technical notices, updates, security alerts, and administrative messages. 

To communicate system updates, upcoming events, and other news and information about products and services offered by us. For instance, we may contact you to inform you about important services-related notices, such as privacy and policy updates or changes in our terms of service. 

For statistical and business operations and planning purposes. 

To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity. 

To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties. 

To improve, provide, and deliver products and services. 

We may also continue to collect and use Personal Data for these purposes.

We do not sell personal information and in, the preceding twelve (12) months, we have not sold any personal information to any other entity. 

Aggregated Data

We may aggregate the information that we collect and use such aggregated data for commercial, statistical, and market research purposes, including sharing it with affiliates, third parties and business partners. This data may include location information derived from your IP address or mobile device.

How We Share Personal Data

We do not share your Personal Data outside of ReFlow except in following circumstances:

Business Transfers.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, bankruptcy, or similar event, Personal Data may be part of the transferred assets and may otherwise be shared with business partners and non-affiliates for the purposes of carrying out transactions.

Affiliates, Non-Affiliates and Business Partners. We may also share your Personal Data with our affiliates and non-affiliates and our business partners for business purposes, including the processing of consumer transactions.

Agent, Consultants, Vendors, and Service Providers.
Like many businesses, we sometimes hire other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments.

Legal Requirements. We may also disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (v) protect against legal liability.

Information Access And Choice

You can contact us at 888-648-0668 or to do the following at anytime:

See what data you provided through the Services, if any. Change/Correct any data you provided through the Services. Express any concern you have about our use of your data. Request we delete your data.

California Privacy Rights And Disclosures

California residents may request information regarding the types of personally identifiable information we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. As noted above, we do not provide Personal Data to third parties for their direct marketing purposes.

Residents of California may have rights under the California Consumer Privacy Act (“CCPA”) as described in this section of our Privacy Policy. We note, however, that some of the Personal Data that we collect is exempt from the following provisions of the CCPA, which do not apply to Personal Data collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act. The CCPA also includes certain exceptions related to certain information in a business-to-business context and information collected about employees, job applicants, and contractors. You can review our Gramm-Leach-Bliley Act Privacy Notice for more information on how we share information here.

Access Requests: If you are a California resident whose information is covered by the CCPA, you have a right to request access to certain information about the Personal Data we collect about you. In particular, these individuals have a right to request that we provide the following information:

The categories of Personal Data that ReFlow or Provenance has collected about you. 

The categories of sources from which ReFlow or Provenance collected the Personal Data. 

The business or commercial purposes for which ReFlow or Provenance collected and/or sold the Personal Data. 

The categories of any third parties with which ReFlow or Provenance shared the Personal Data. 

The specific pieces of Personal Data Provenance collected over the past year. 

The categories of Personal Data, if any, ReFlow or Provenance has sold about you, categories of third parties to which ReFlow or Provenance sold that Personal Data, and the categories of Personal Data sold to each type of third party. 

The categories of Personal Data that we have disclosed for a business purpose. 

Our responses to such requests will cover the 12-month period preceding our receipt of the request.

To request access to this information, you may contact ReFlow at 888-648-0668 or email us your request via You may need to submit certain information in order for us to verify your identity or request before we process your request including your name, address, email address, phone number, attestation that you are a California resident and your relationship with ReFlow. You may also designate an agent to submit a request on your behalf. We will likewise need to verify the agent.

Deletion Requests: If you are a California resident whose information is covered by the CCPA, you have a right to request that we delete certain personal information from our records, subject to certain exceptions. We are not required to delete information that is necessary for us to: complete the transaction for which we collected the information; provide you with a good or service you requested; perform a contract Provenance entered into with you; detect security incidents; maintain the functionality or security of ReFlow’s systems; comply with or exercise rights provided by law; or the use of information internally in ways that are comparable with the context in which you provided the information to ReFlow or that are reasonably aligned with expectations based on your relationship with ReFlow, among other things. We may also retain information where another exception to the deletion requirements in Cal. Civ. Code § 1798.105(d) applies.

To submit a deletion request, you may contact ReFlow at 888-648-0668 or email us your request via You may need to submit certain information in order for us to verify your identity or request before we process your request including your name, address, email address, phone number, attestation that you are a California resident and relationship with ReFlow.

We will respond to requests for access or deletion as soon as practicable and in any event generally not more than within 45 days after receipt of your request. We may extend this period to 90 days in some cases.

Non-Discrimination: If you exercise any of the rights explained in the Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than other consumers.

Accessibility. We are committed to ensuring that our communications are accessible to individuals with disabilities. Individuals with disabilities can access this policy in alternative formats by contacting us at the address, phone, or email address below.

This website is designed to meet content accessibility guidelines. To submit accessibility-related requests or report barriers to accessibility, please contact us by either:

Calling us at 888-648-0668
Emailing us at  

Our Site currently does not respond to “Do Not Track”(DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Age Limitations

To the extent prohibited by applicable law, ReFlow does not allow use of our services and Site by anyone younger than 18 years old, and we do not knowingly collect or sell the Personal Information of children under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage to help enforce our Privacy Policy. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Links To Other Websites

This Privacy Policy only applies to information collected by ReFlow through our Services. Our Services may contain links to other websites or online services not operated or controlled by ReFlow (“Third Party Sites”). The policies and procedures described here do not apply to Third Party Sites. By providing links to Third Party Sites or services we do not imply that we endorse or have reviewed such websites or services. We suggest that you contact those sites directly for information about their data practices and policies.


You use the Services at your own risk. We use reasonable precautions, including technical and administrative measures, to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent toor from us in connection with the Services may not be secure. Therefore, you should take special care in deciding what information you send to us.

International Transfer Of Data

Because we are based in the United States, if you use our Site or Services from outside the United States your information will be transferred to the United States. By using our Site, products and services, you consent to the collection, international transfer, storage and processing of your information. If it is illegal to access our Site or transfer your data to the United States, please do not use our Sites.

International Transfer Of Data

We welcome your comments or questions about this Privacy Policy. You can contact us at 888-648-0668 or You may also contact us at our address: ReFlow Services LLC:  650 California St., Suite 2700, San Francisco, CA 94108.

Changes To This Privacy Policy

We reserve the right to amend, alter, or otherwise change this Policy at our sole and absolute discretion. If we make material changes to this Privacy Policy, we will change the “content last updated date” above and post a notice to our website. For material retroactive changes, we will notify you consistent with the law. Further use of the website following any such changes constitutes your agreement to follow and to be bound by the amended Privacy Policy, so we encourage you to check the Site for updates.