Privacy Statement

A2 Access, LLC (“A2”) has developed this privacy statement for you, the visitor/user, to demonstrate its commitment to privacy on the Internet. This Privacy Statement applies to the information gathering and dissemination practices for A2’s online application software (the “A2 Platform”).   

Your privacy is important to us. This Privacy Statement applies to the online collection of personal information via the A2 Platform.

The A2 Platform also may contain links to websites maintained by others. This Privacy Statement does not reflect the privacy practices of those sites, and you should consult the privacy policies of those sites to learn about their practices. The A2 Platform does not knowingly collect information about children under the age of 18.

1. Collection of Information

We collect information from you in several different ways.  We use this information primarily to provide you an experience with our A2 Platform that is personalized for you and that delivers the information, services, resources and products that are most relevant and useful to you.  Much of the information we collect (beyond the information provided directly by you) is not personally identifiable about you. We do not share information provided by you that is Personally Identifiable Information (as defined below) with others unless we say so in this Privacy Statement or where we are otherwise required by law or contract to do so. 

Personally Identifiable Information. A2 may require users to register before using the A2 Platform. During registration, we collect basic online contact information about you, including but not limited to, your name, email address, country of residence, and the name and type of organization you represent, which may make it possible to identify you (“Personally Identifiable Information”).

Access Information. Once you are logged in, the A2 Platform may also collect information when your web browser accesses the A2 Platform, including the internet protocol (IP) address of your computer, geographic location as determined by your IP address, your browser software and operating system, your web server, the date and time you access our site, session information (such as download errors and page response times), information about your viewing and search history, and information about the referring URL and the URL clickstream to, through and from the A2 Platform (“Access Information”).

Usage Information. We may further gather non-personal information on your use of the A2 Platform while logged in, such as: the number of people that visit the A2 Platform, or which pages you visited on the A2 Platform (“Usage Information”). Access Information and Usage Information may be used internally to improve the A2 Platform and for product development and marketing purposes generally. The information we collect in Web server logs helps us administer our sites, analyze usage, protect the website and its content from inappropriate use, and improve user experience.

Cookies. Once you have logged in to the A2 Platform, we may gather Access Information and Usage Information in various ways, including but not limited to, through the use of “cookies.” A “cookie” is a piece of information that the A2 Platform sends to your browser, which then stores this information on the hard drive of your computer. We use cookies and similar technologies to help remind us who you are and to help you navigate our sites during your visits. Cookies allow us to save passwords and preferences for you so you won't have to reenter them each time you visit. The use of cookies is relatively standard. Most browsers are initially set up to accept cookies. However, if you prefer, you can set your browser to either notify you when you receive a cookie or to refuse to accept cookies. The A2 Platform may not function properly if you decline or disable Internet cookies while visiting or otherwise using the A2 Platform. A2 does not use cookies for users who visit our public-facing website without logging in to the A2 Platform.

User-Submitted Data. You and other users of the A2 Platform may also submit various types of data to A2 for display to other users of the A2 Platform. If you access the A2 Platform on behalf of a fund or other investor entity, such data is referred to as “Investor Data.” If you access the A2 Platform on behalf of a bank, sell-side firm, primary research firm, issuer, industry group or other financial institution, such data is referred to as “Resource Data.” If you submit information regarding attendance at events, contact relationships and other activities used by investors to track their interactions with banks, sell-side firms, primary research firms, issuers, industry groups or other financial institutions, such information is referred to as “Tracking Data.” Investor Data, Resource Data, and Tracking Data are collectively referred to as “User-Submitted Data.” User-Submitted Data may include information that is personally identifiable about you and/or other users of the A2 Platform, even if such information is submitted to A2 by another user of the A2 Platform.

Other Information. Also, in order to improve the A2 Platform, we may offer you an opportunity to ask questions, provide suggestions and submit contributions by completing a contact form which may collect Personally Identifiable Information.

2. Use of Information

Personally Identifiable Information, Access Information and Usage Information. A2 may use Personally Identifiable Information, Access Information and Usage Information to deliver the A2 Platform, to contact you regarding functionality that we think may be of interest to you, to analyze the wants and needs of our customers, to help us create and publish content most relevant to you, to allow you access to limited-entry areas of the A2 Platform, as appropriate and for other purposes.

User-Submitted Data. Investor Data you submit may be shared with other users accessing the A2 Platform on behalf of the same fund or other investor entity. Resource Data you submit may be shared with other users of the A2 Platform authorized by the applicable bank, sell-side firm, primary research firm, issuer, industry group or other financial institution to access such Resource Data. Tracking Data you submit will be shared with users accessing the A2 Platform on behalf the fund or other investor entity to which such Tracking Data relates and may be shared with other users of the A2 Platform authorized by such fund or other investor entity.

Other Information. Please note that any comments or materials sent to us, including feedback data, such as questions, comments, suggestions and any other responses are deemed to be non-confidential and we may use, reproduce, distribute and publicly display such comments and materials without reference to you personally. We may also use any ideas, concepts, know-how or techniques contained in such responses for any purpose whatsoever.

Disclosure of Information and Data. We may transfer the Personally Identifiable Information you provide us to our affiliates and subsidiaries or to our third party service providers, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. We may make statistics based on Access Information and Usage Information available to third parties and may use such Access Information and Usage Information for commercial purposes, including, without limitation, for marketing purposes. We may also transfer Personally Identifiable Information, Access Information, Usage Information and/or User-Submitted Data to a third party in the event that A2 or the A2 Platform is purchased by such third party, in which case this Privacy Statement will be binding on such third party for information and data collected prior to such transfer. A2 reserves the right to disclose your Personally Identifiable Information as required by law, when we believe disclosure is necessary to comply with a judicial proceeding, court order or legal process served upon us, and when necessary to enforce or apply the terms of the applicable End User License Agreement for the use of the A2 Platform, if any.

3. Corrections and Deletions of Personally Identifiable Information

A2 strives to maintain the accuracy of the Personally Identifiable Information you submit through the A2 Platform. Where A2 maintains specific Personally Identifiable Information collected from you, A2 will provide you with access to such Personally Identifiable Information you provide through the A2 Platform for as long as A2 maintains that information in a readily accessible and retrievable format. A2 will also work with you to correct or delete any such information upon your request by contacting A2 Access, LLC via email or telephone at the addresses below.

The access, correction, and deletion provisions of this Privacy Statement only apply to Personally Identifiable Information collected from you through the A2 Platform.

Given that certain investors who use the A2 Platform use Tracking Data for compliance purposes, A2 will not be able to correct or delete Tracking Data that is submitted by another user of the A2 Platform, even if such Tracking Data contains information that personally identifies you.

4. Changes to Privacy Statement

A2 reserves the right to change this Privacy Statement at any time by posting a new or revised statement. A2 will also notify you by email or through the A2 Platform of any upcoming changes to this Privacy Statement. This Privacy Statement was last revised and is effective as of July 13, 2015.

5. How to Contact A2

A2 Access, LLC can be contacted:

By email to support@a2-access.com; or

By telephone to 646-412-4800.