In the course of doing business with our investors, IPT may collect certain non-public, personal information about our investors and their transactions with our affiliates. For example, this information may include names, addresses, Social Security numbers, account balances and bank account information, and may be derived from account applications, other forms or transactions with IPT or its affiliates.
IPT is committed to using reasonable commercial efforts to keep confidential all non-public, personal information about our investors. We will only disclose this information to third parties as set forth in this policy or as otherwise required or permitted by law. We may share non-public, personal information with our affiliates. We may also disclose such information to unaffiliated third parties in the following circumstances:
- Vendors and Suppliers. We may from time to time have relationships with different vendors, suppliers, authorized representatives and agents (e.g., our transfer agent, custodians, broker/dealers, accountants, lawyers, technology and other service providers) (collectively, “vendors or suppliers”) who help us design and maintain our computer systems and security, manage transactions or otherwise perform services for our investors or to support our business. We may provide personally identifying information to a vendor or supplier if such vendor or supplier needs such information to perform services for us, but we will not authorize our vendors or suppliers to use our investors’ information for any purpose not related either to our business or to performing services for our investors.
- Government Agencies/Law Enforcement. In certain circumstances, we may be called upon to release our investors’ personally identifying information in response to a court order, subpoena, search warrant, law, or regulation. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the personally identifying information that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting our investors who engage in behavior that is illegal or harmful to others and to release information about our investors to the applicable authorities.
- Corporate Transactions. If we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a merger, business transfer or other type of liquidity event, we may, in our sole discretion, transfer, sell or assign our investors’ personally identifying information to a third party as part of or in connection with that transaction. Upon such transfer, sale, or assignment or other liquidity event, the transferee, assignee, successor or acquiring party may use our investors’ personally identifying information in accordance with this Privacy Statement or as otherwise permitted by applicable law or regulation.
We may update this Privacy Statement from time to time and encourage you to periodically review this Privacy Statement to be informed of how IPT is protecting consumer information.