Privacy Policy

We Value Your Privacy

Private Access Network values your privacy and the trust you place in us in using and viewing our website.

We are committed to protecting your personal and financial information. This Privacy Policy answers some questions about what information we collect, what we do with it, and how we protect it. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Our Policy

Welcome to the web site www.privateaccessnetwork.com (the “Site”) owned and operated by Private Access Network, LLC (henceforward “Private Access Network,” “we,” “us,” and/or “our”). This Site has been created to provide information about us, our services and the services provided by our affiliate, PAN Investment Management Group, LLC (“PIMG”), in facilitating access to private investments through special purpose vehicles (“SPVs”) to members of Private Access Network (each a “Member”). This Privacy Policy sets forth Private Access Network’s policy with respect to information, including personally identifiable data (“Personal Data”), and other information that is collected from visitors to the Site (“Visitors”), Visitors that elect to register with us (“Users”), and persons who register to become full-fledged members of the Private Investment Network and obtain access to investment opportunities through the SPVs (“Members”).

If you have questions or complaints regarding our privacy policy or practices, please contact us at [email protected].

Information We Collect

We may collect Personal Data from Visitors, Users and Members. When you interact with us through the Site as a Visitor, User or become a Member, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Site:  We collect Personal Data from you when you voluntarily provide such information, such as when you register for access to the Site (for example, contact information such as your name, email address, and mailing address) as a User, and when you wish to join Private Access Network as a Member (for example, information regarding your net worth, income, age, occupation, investing experience and other information to determine whether you are an accredited investor and qualified to become a Member), or contact us with inquiries or respond to one of our surveys.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Private Access Network and the authorized third parties referred to herein located in the United States.

Non-Identifiable or Aggregated Data: When you interact with Private Access Network through the Site, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you.

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. Private Access Network may store such information itself or such information may be included in databases owned and maintained by Private Access Network affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, the domain names of our visitors’ Internet service providers, and how our users use and interact with the Site. Also, in an ongoing effort to better understand and serve the users of the Site, Private Access Network often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us.

This research may be compiled and analyzed on an aggregate basis. Private Access Network may share this non-identifiable and aggregate data with its affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. Private Access Network may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.

In operating this Site, we may also use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Site without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive 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 Site’s features.

The use of cookies by our any of our affiliates or service providers is not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners use session ID cookies to make it easier for you to navigate our site and use services provided by Private Access Network and its affiliates.

Our Use of Your Personal Data and Other Information

Private Access Network uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Site as a User or a Member, we will use your Personal Data to screen your qualifications to obtain such access, provide you with access to such services and to monitor your use of such services. We also may obtain information about you from third party sources to verify your identity so we can properly process your requests and prevent fraud.

Private Access Network and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Site to help us improve the content and functionality of the Site, to better understand our users and to improve the services offered by the Site. Private Access Network and its Related Companies may use this information to communicate with you regarding the Site or the services offered by our affiliates or to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note, however, that as a User of the Site or a Member of Private Access Network, we will send you administrative communications that are reasonably necessary and appropriate to level of use and access, such as billing or service notifications. If Private Access Network intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Your Personal Data and Other Information

We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

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 or similar event, Personal Data may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties: Private Access Network, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, ID verification, processing applications, shipping and fulfillment, and processing payments and completing transactions. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These companies are authorized to use your personal information only as necessary to provide these services to us.

Legal Requirements: Private Access Network may 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 the rights or property of Private Access Network, (iii) act in urgent circumstances to protect the personal safety of Visitors, Users, Members or the public against fraud or other harm, or (iv) protect against legal liability.

Your Choices

If your personal information changes, or if you no longer desire our services, you may correct, update, amend, delete or request deletion of your Personal Data by making the change in your registered account settings page, or by contacting us at the contact information listed below. We will respond to your request within 30 days.

For Users and Members, we will retain your information for as long as your User or Member account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

When you sign up as a User of our Site or a Member of Private Access Network, we will send periodic emails to you regarding the services you have signed up to receive or access, or to tell you about services we believe will be of interest to you. Out of respect for your privacy, you may choose to stop receiving our emails by following the unsubscribe instructions included in these emails or you can contact us at [email protected].

Security

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at [email protected].

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Private Access Network other than Personal Data collected through the Site. This Privacy Policy shall not apply to any unsolicited information you provide to Private Access Network through this Site or through any other means. This includes, but is not limited to, information posted to any public areas of the Site, such as bulletin boards (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Private Access Network shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

In addition, this Privacy Policy does not govern use of information provided by Members to our affiliate, PIMG, in connection with the Members’ investments in SPVs. Use of such information is governed by a separate privacy policy that will be communicated to Members by PIMG.

Blog

Our Site may offer a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Testimonials

We may display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent, we may post your testimonial along with your name and other information. If you wish to update or delete your testimonial, please contact us at [email protected]

Children

Private Access Network does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on this Site without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Private Access Network through this Site, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Web Sites

This Privacy Policy applies only to the Site. This Site may contain links to other web sites not operated or controlled by Private Access Network (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from this Site do not imply that Private Access Network endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Other Terms and Conditions

Your access to and use of this Site is subject to the Terms of Use.

Changes to Private Access Network’s Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify Users and Members by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage Visitors, Users and Members to periodically review this page for the latest information on our privacy practices.

Contacting Private Access Network

Please feel free to contact us if you have any questions about Private Access Network’s Privacy Policy or the information practices of this Site: [email protected].