Privacy Policy

PRIVACY POLICY FOR WIZARRD ASSET MANAGEMENT

Effective October 26, 2022

INTRODUCTION TO PRIVACY POLICY

This Privacy Policy explains how AD.Visory Solutions, LLC, through its Wizarrd Asset Management application platform (“Wizarrd”), collects, processes, stores, discloses, and otherwise uses personal data collected about individuals and organizations that use and interact with Wizarrd’s asset management interface (the “Services”).

If you do not agree with the terms of this Privacy Policy, you should not use Wizarrd or the Services, or otherwise provide Wizarrd with access to your personal data.  By using, accessing, or interacting with Wizarrd or the Services, or otherwise providing Wizarrd with your personal data, you acknowledge that you have read, understood, and agree with this Privacy Policy.  Your use of Wizarrd and the Services is also governed by Wizarrd’s Terms & Conditions (https://console.wizarrd.app/terms-not). 

This Privacy Policy is effective as of the date set forth above.  From time to time, this Privacy Policy may be revised or updated.  If changes are made, the revised or updated Privacy Policy will be posted on this page.  Wizarrd will notify you of any material modifications to this Privacy Policy that might affect the way it uses or discloses your personal data prior to the change becoming effective by means of a message on Wizarrd’s website, unless another type of notice is required by the applicable law.  Your continued use of Wizarrd and the Services after it has posted changes to this Privacy Policy or notified you, if applicable, is deemed to be your acceptance of those changes.

  1. INFORMATION WIZARRD COLLECTS

Wizarrd collects and processes data, including personal data, about you as you use, access, or otherwise interact with Wizarrd and the Services.  Specifically, Wizarrd collects and processes three categories of personal data:

  1. Information provided directly by you; and
  1. Information collected via third parties;
  1. Information collected automatically.
  1. Information Provided Directly by You

Account Registration Data.  If you register with Wizarrd through its website or through a separate subscription agreement, then, as part of such registration, you will be asked to provide certain personal data, including your name, your company name (if applicable), your email address, your physical address, and password.

Communications with Wizarrd.  Wizarrd also collects personal data that you voluntarily disclose when you contact Wizarrd with inquiries (including by filling out relevant forms on Wizarrd’s website) or for customer support.

Payment Information. Wizarrd collects payment and billing information when you register for paid Services.  For example, upon registration Wizarrd ask you for billing details, including name and contact information.  You may also provide payment information, such as payment card details, which is collected via secure payment processing services.  If you sign-up for a free trial account, you are not required to enter your credit card information unless and until you decide to continue with a paid subscription to the Services.

  1. Information Collected Via Third Parties

To provide the Services, Wizarrd integrates user asset accounts (including hardware, software, and networking accounts) via application programming interfaces (“APIs”).  Wizarrd will ask your permission to integrate with an asset account via APIs.  After such integration, Wizarrd will be able to store in its database (in an encrypted way) the information related to that asset account.  

Notwithstanding anything herein to the contrary, Wizarrd will use the data received via asset account integration only to provide you with the Services and for monitoring purposes.  Wizarrd may also transfer data received via asset account integration as necessary to comply with applicable law or as a part of a merger, acquisition, or sale of assets with notice to users.  All other transfers or sales of user data received via asset account integration are prohibited. 

Wizarrd will not use the data received via asset account integration for any other purposes except providing you with the Services; specifically, Wizarrd will not use the data received via asset account integration for any advertising purposes, including retargeting, personalized, or internet-based advertising.  All the data received via asset account integration will be processed only at the software level.

  1. Information Collected Automatically

Like many other commercial websites, Wizarrd uses certain technologies, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies, to automatically collect information that may contain personal data as you navigate Wizarrd’s website or use the Services.

Device and Usage Data.  Wizarrd may track, collect, and aggregate information indicating, among other things, which pages of Wizarrd’s website were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked.  Wizarrd may also collect information from the URLs from which you linked to Wizarrd’s website.  Collecting such information may involve logging the IP address, operating system, and browser software used by each user of the website.  Wizarrd may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of the point of connectivity.

Cookies and Similar Technologies.  Wizarrd uses Google Analytics, including “Universal Analytics” operating mode, which facilitates the assignment of data, sessions, and interactions across several devices to a pseudonymous user ID, and thus the analysis of a user’s activities across devices.  

  1. HOW WIZARRD USES YOUR INFORMATION

Wizarrd uses the personal data it collects as follows:

  • To provide the Services and any related support, to process transactions, to manage your user account, and to respond to your requests.  
  • To the extent permitted by applicable law, and for certain legitimate interests, including:
    • To manage the relationship with you, which includes sending administrative information to you, for example, information regarding the website and changes to Wizarrd’s terms, conditions, and policies, and responding to your requests or communicating with you;
    • For other internal business purposes, such as data analysis, benchmarking, audits, conducting research, analysis, studies, or surveys, and identifying usage trends. 
    • To prevent fraud or criminal activities, misuse of products or services, and ensure the security of Wizarrd’s IT systems, architecture, and networks;
    • To: (a) comply with legal obligations and legal process; (b) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (c) enforce Wizarrd’s Terms and Conditions; (d) protect operations; (e) protect Wizarrd’s rights, privacy, safety of property, and/or that of you or others; and (f) allow Wizarrd to pursue available remedies or limit the damages that it may sustain.
  1. HOW WIZARRD SHARES YOUR PERSONAL DATA

Wizarrd will not sell, rent, lease, or otherwise provide your personal data to others, except in order to provide you with the Services, with your permission, or as required by applicable law.

Third Party Service Providers.  Wizarrd may engage other companies and people to perform tasks on its behalf.  In particular, Wizarrd uses third party providers for payment processing, fraud prevention, and risk assessment, hosting and other information technology services, email communication, and customer support services, analytics, and data providers.  Following Wizarrd’s instructions, these parties may process your personal data in the course of providing the relevant services to Wizarrd.

Legal Requirements.  Wizarrd may share your personal data to comply with a legal obligation to which Wizarrd is subject, protect and defend the rights or property of Wizarrd, act in urgent circumstances to protect your personal safety or that of the public, or protect Wizarrd against legal liability.  For example, where Wizarrd is obliged to share your personal data with regulatory bodies which govern its work and services; government departments such as law enforcement, courts orders; financial institutions; external auditors; etc.

  1. HOW WIZARRD RETAINS YOUR PERSONAL DATA

Wizarrd retains your personal data for as long as reasonably necessary to provide the Services while complying with legal obligations or for other legitimate business purposes, such as maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing agreements.  After the applicable retention period has elapsed, your personal data will be anonymized and deleted.

  1. HOW WIZARRD PROTECTS YOUR PERSONAL DATA

Wizarrd uses industry-standard physical, technical, and administrative security measures to keep your personal data confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Policy.  

The internet, however, cannot be guaranteed to be completely secure, and Wizarrd cannot ensure or warrant the security of any personal data you provide over the internet.  It is your responsibility to protect the security of your login information.

If you know or suspect that your personal data have been lost, stolen, misappropriated, or otherwise compromised, or in case of any actual or suspected unauthorized use of your Wizarrd account, please immediately contact us by email.

  1. UPDATING AND ACCESSING YOUR PERSONAL DATA

You may access, review, modify, and delete your account profile information by going to your account in Wizarrd and editing your information.  However, if you want to update, delete, limit the use or disclosure of, or access the personal data held about you in Wizarrd’s systems, you will need to email your request to do so. 

  1. CHILDREN

Wizarrd and the Services are not directed to children who are under the age of 16.  Wizarrd does not knowingly collect personal data from children under the age of 16.  If you have reason to believe that a child under the age of 16 has provided personal data to Wizarrd or through use of the Services, please contact Wizarrd to delete such information from Wizarrd’s databases.

  1. STATE-SPECIFIC DATA PRIVACY INFORMATION

Wizarrd is a “service provider” for the purposes of the California Consumer Privacy Act (“CCPA”) and is receiving personal information from you pursuant to an agreement for a business purpose.  Wizarrd shall not sell any such personal information.  Wizarrd shall not retain, use, or disclose any personal information provided by you pursuant to any agreement, except as necessary for the specific purpose of performing the Services, or otherwise as set forth in this Privacy Policy, or as permitted by the CCPA.  

The terms “personal information,” “service provider,” “sale,” and “sell” are as defined in Section 1798.140 of the CCPA.  Wizarrd certifies that it understands the restrictions of this paragraph.

  1. CONTACT INFORMATION

If you have any questions or concerns regarding Wizarrd’s Privacy Policy or use of personal data, or if you want to exercise your rights regarding your personal data, please contact Wizarrd by email at the designated request address at getintouch@advisory.nyc or by regular mail to:

AD.Visory Solutions, LLC (d/b/a Wizarrd Asset Management)

16 West 36 Street, Suite 501

New York, NY 10018
Attention: General Counsel