We at Cache Financials, Inc., Cache Securities LLC (our registered broker dealer), and Cache Advisors LLC (our registered investment advisor) (collectively, “Cache”, “we” or “us”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy is designed to help you understand how we collect, use, process, and share information we collect via our website located at https://www.usecache.com and other domain names offering or linking to the website (the “Site”), our services, including but not limited to, broker-dealer services, investment advisory services, and any corresponding mobile application (together with the Site, the “Platform”) offered by Cache and to help you understand and exercise your privacy rights within the scope of applicable laws. The Site, our services and Platform are collectively called the “Services.”
This Privacy Policy applies to information processed by us, including in connection with our Services. For more information on how we process your nonpublic personal information as a financial institution, please refer to our Financial Information Privacy Notice available in our legal disclosure library.
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
We may collect the following personal information that you provide to us.
Account Creation. To create an account with us and use our Services, we may collect the following information from you:
We may collect personal information automatically when you use our Services:
Our uses of these Technologies fall into the following general categories:
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
We use your information to fulfill our contract with you and provide you with our Services, such as:
We will take reasonable measures (e.g., by contract) to require that any party receiving any of your personal information from us, including for purposes of providing the Services, undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Policy; (ii) not disclose your personal information except with your consent, as permitted by applicable law, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of your personal information. Additionally, certain services may be provided through independent third parties, including but not limited to, clearing houses, that are not affiliated with Ainvest, and may operate under their own privacy policies.
We use your information for various administrative purposes, such as:
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising.
If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
In order to use our Services, you may be required to provide our third-party payment processor(s) such as Plaid (each a “Payment Processor”) with certain credit or debit card information, ACH transfer information, bank account information, or wiring instructions (collectively, the “Payment Information”). We do not obtain access to the Payment Information. Our Payment Processor(s) will collect on our behalf information about your payment for Services (“Transaction Information”). By using the Services, you acknowledge and agree that if and to the extent your Payment Information, Transaction Information, and/or any other information is collected by or transferred to Plaid, or any other Payment Processor, such information will be governed by its applicable privacy policy, and that you expressly agree to the terms of such privacy policy. You hereby expressly grant us the right, power, and authority to access and transmit your information as reasonably necessary for the Payment Processor(s) to provide its services to you in connection with your use of our Services.
We also use your information for other purposes as requested by you or as permitted by applicable law.
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
The categories of third parties with whom we may share your information are described below.
Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes, but is not limited to, service providers that provide us with brokerage and custodial services, administrative support, marketing support, IT support, hosting, payment processing, customer service, and related services.
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction.
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
We take commercially reasonable steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
If we transfer personal information to countries outside the European Economic Area, we will put in place appropriate safeguards to ensure that this transfer complies with the applicable laws and regulations. For more information about these safeguards, please contact us as set forth below.
If you are located outside the United States and choose to use the Services, you do so at your own risk.
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Cache has collected about them and whether Cache disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
Right to Know About Personal Information
You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your personal information. Once we receive and verify your request, we will disclose to you the following (to the extent applicable to your request):
You may exercise this right up to two times in any 12-month period.
Right to Request Deletion
You may also have the right to request deletion of your personal information. We will honor such request, but might not be able to fulfill your request if we (or our service providers) are required to retain your personal information. Examples of such exceptions are:
Disclosures of Personal Information under the CCPA
Cache does not sell your personal information and has not done so over the last 12 months. However, if you elect to do so, we may disclose your information to our partners. To the extent that such disclosure is, for legal purposes, deemed to be a “sale” under the CCPA, you may opt-out of having your information disclosed by not opting in to disclose your information, disabling third-party cookies on your device, or by contacting us as set forth in “Contact Us” below.
Opt-out. California residents may opt-out of the disclosure of their personal information to our partners by contacting us as set forth in “Contact Us” below.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. We will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties, (iii) provide you a different level or quality of products or services, and (iv) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you. Making a verifiable consumer request does not require you to create an account with us.
We will confirm receipt of a verifiable consumer request within then (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this Privacy Policy, please do so from your web browser or by saving the page as a PDF.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties. You can exercise this right by contacting us at support@usecache.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion, and will post changes on the Services as soon as they go into effect. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
Cache Financials, Inc.
Attn: Legal
Address: 95 Third St, 2nd Floor
San Francisco, CA - 94103
Email: legal@usecache.com
Last updated
April, 2023
Cache Advisors LLC (“Cache Advisors”) is an investment adviser registered with the Securities and Exchange Commission (“SEC”). Registration does not imply a certain level of skill or training. Cache Advisors is a wholly-owned subsidiary of Cache. Cache Advisors’ investment advisory services are available only to residents of the United States in jurisdictions where Cache is registered. Account holdings and other information provided are for illustrative purposes only and are not to be considered investment recommendations. The content on this website is for informational purposes only and does not constitute a comprehensive description of Cache Advisors’ investment advisory services. Please refer to Cache Advisors’ Form ADV for important additional information. Certain investments are not suitable for all investors. Before investing, you should consider your investment objectives and any fees charged by Cache Advisors.
Cache Securities LLC (“Cache Securities”) is a broker-dealer registered with the SEC, and is a member of the Financial Industry Regulatory Authority Inc. (“FINRA”) and of the Securities Investor Protection Corporation (“SIPC”), which protects securities customers of its members up to $500,000 (including $250,000 for claims for cash). For additional information and an explanatory brochure, please see www.sipc.org. Cache Securities provides security trading to self-directed customers. Cache Securities is a wholly-owned subsidiary of Cache. Additional information about Cache Securities can be found on FINRA’s BrokerCheck. Clearing, execution and settlement of securities transactions is provided by Apex Clearing Corporation (“Apex”). For additional information on Cache Securities, please visit BrokerCheck at https://brokercheck.finra.org/
Cache Financials Inc. (“Cache”), which operates this website is neither a registered broker-dealer nor a registered investment adviser. Cache Financials does not give any investment advice, analysis, or recommendations with respect to any securities. By accessing this website, you agree to be bound by our terms of service and privacy policy.
This website contains endorsements from third-parties who are not current clients of Cache Advisors or investors in a private fund managed by Cache Advisors and represent their opinion at the time such statements were given. No compensation was paid in connection with such endorsements. Certain endorsements are by individuals who are investors in Cache, indicated as 'Cache Investor'. Such individuals have an indirect financial incentive to endorse Cache Advisors LLC to increase the value of their investment.
Please visit Investment Adviser Platform Disclaimer for important disclosure regarding Cache Advisors, LLC’s services through the website, as well as our legal disclosure library for additional terms and conditions and other important disclosures.
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