Privacy Policy


Atreus Capital Management, LLC respects your privacy. This Privacy Policy is intended to inform you of how we protect your information.

ONE POLICY

Atreus Capital Management, LLC has one global Privacy Policy for consumers applying to the entire ACM family of companies ("ACM"). ACM is committed to complying with all local and worldwide privacy laws.

INFORMATION COVERED BY THIS POLICY

Our Policy covers all non-public, personal information received by us that may be used to identify you ("Personal Information").

HOW WE OBTAIN PERSONAL INFORMATION

We rely on many sources of information to understand and meet your needs. We may receive personal information about you from:

  • You directly, when you complete an application or when you visit us in person, over the phone, through the mail or through our websites;
  • Your transactions with any of the companies in the ACM family;
  • Consumer reporting agencies;
  • Mortgage, title, appraisal or other companies connected with a financial product or service involved in the sale or purchase of your home;
  • Your employer;
  • Anyone who you have authorized to provide information; and
  • Other sources, in connection with providing you with financial product or service.

Although we do not receive personally identifiable information from your browser, we monitor certain types of information about visitors to our website--namely, the type of browser used, their country, whether they were referred to us by a search engine, which of our pages they visit, and how those pages perform on their computer. This helps ACM make decisions on how to better design, streamline, and improve performance on our websites. If you do not want this information monitored, you may turn off JavaScript. Please be advised, however, that the websites may not provide full functionality if those settings are turned off.

We also use “cookie” technology to improve your experience on our site. For details on our cookie policy, please see our website. We do not knowingly collect Personal Information from children and will destroy such information if it is disclosed to us without proper parental consent.

INFORMATION SHARING WITHIN THE ACM FAMILY OF COMPANIES

To provide you with the full range of financial, relocation, and moving services you may need, ACM takes an integrated approach to the services we provide. To be able to provide a full range of services for your needs and make recommendations about a variety of the services offered by ACM we may share personal information among the ACM family of companies.

INFORMATION SHARING WITH NON-ACM FAMILY COMPANIES

Depending on the type of services you are to receive, ACM may work with and provide your information to companies or persons outside of the ACM family to provide those services to you. For example, ACM may share personal information to:

  • service and support our operations generally and to support your account and services that we provide to you, including proposed or actual financing, securitization, secondary market sale, or similar transactions.
  • process or administer a transaction or product in connection with a product or transaction that you have requested;
  • data storage and processing; • those you have authorized us to disclose the information;
  • other suppliers with whom we have agreements to offer services to you through or with ACM;
  • other suppliers with which we jointly market or provide products or services

We may also share your Personal Information with these other organizations outside of the ACM family when required by law. For example, we may share personal information to:

  • protect against fraud;
  • respond to a subpoena or summons; or
  • respond to law enforcement or regulatory authorities

We will not disclose your Personal Information to anyone outside of ACM unless you have authorized us to do so or as otherwise indicated in this Policy or as required by law.

We maintain agreements with our external suppliers limiting the use of your Personal Information only for the purposes you have intended in providing the information. These suppliers are bound to uphold our standards and procedures regarding privacy under the terms of our agreements with them.

ACCESS & CHOICE

ACM provides you with a reasonable opportunity to access your own Personal Information, to correct that information if inaccurate, or to have it deleted as appropriate--subject to the exceptions stated below. Reasonable access means, for example, that requests for access are made during normal business hours; that you provide requested identification; and that requests are not excessive in number. If, at any time, ACM denies you access to any Personal Information, we will provide you with reasons for denying access and information about how you may make further inquiries. For instance, ACM reserves the right to deny access to information related to investigations or potential or actual litigation where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy, or where the rights of other individuals would be violated. To update your information, please send your request by electronic mail to info@atreuscapitalmanagement.com, or by telephone to the number (480) 239-4040.

You have the right to opt out of any use of your Personal Information at any time. If you opt out of this policy it may affect your receipt of services.

DATA INTEGRITY & SECURITY

ACM will make every reasonable effort to keep Personal Information accurate while we are using that information to serve you. ACM appreciates your cooperation in maintaining complete and up-to-date Personal Information and will facilitate your efforts in this regard. ACM retains Personal Information for as long as we have determined it is needed for the purposes for which it was received or as required by contractual, record keeping or other legal requirements.

We limit access to personal information about you to those employees who need to know that information to provide products and services to you.

We do not sell your personal information.

We maintain physical, electronic, and procedural safeguards to protect your Personal Information.

We regularly assess security standards and procedures to protect against unauthorized access to personal information.

You should always safeguard your own Personal Information by protecting passwords used to access a ACM system and by safely disposing of records and reports no longer needed.

ACM will notify and work with regulatory and/or law enforcement officials as required by law to address any issues or security breaches where they arise.

ENFORCEMENT

A. Verification

Employee training and internal procedures are in place to allow ACM to ensure compliance with its Privacy Policy. ACM provides for regular internal compliance reviews of its privacy practices, and ACM has a Privacy Office that is responsible for privacy implementation and compliance. For assistance with privacy concerns, you may send comments by electronic mail to info@atreuscapitalmangement.com, by telephone to the number (480) 239-4040.

B. Dispute Resolution

ACM recognizes the importance of providing you the opportunity to address and resolve complaints about the processing of your Personal Information. Therefore, in addition to any legal remedies that may be available, if you make a complaint with us about the processing of your Personal Information and it is not resolved to your satisfaction internally at ACM, you may also file a complaint with the American Arbitration Association ("AAA") at the AAA website, located here, or seek its independent alternative dispute resolution services. The American Arbitration Association ("AAA") is also located at the following address:

225 North Michigan Avenue, Suite #2527 Chicago, Illinois 60601-7601 USA The AAA can be reached by telephone at (312) 616-6560 or by facsimile at (312) 819-0404.