Dakota California Privacy Policy

Last Updated: November 14, 2024

You privacy is important to us at Dakota Funds Group, LLC and Dakota Live!, LLC and its affiliates and subsidiaries (collectively, “Dakota,” “we,” “our,” or “us”) and we are committed to safeguarding, preserving and respecting your privacy rights. This online privacy Policy (the “Policy”) describes how we collect, use, disclose, and secure the personal information we gather about you through our websites, including www.dakota.com/ and https://dakotafunds.com/ (the “Sites”) when you use our sites and apps, and when you otherwise interact with us (collectively, the “Services”).

This California Privacy Policy describes how we collect, use, share, disclose, retain, and secure of the personal information we gather about you through our website www.dakota.com (the “Site”), when you interact with us as a customer or otherwise interact with us (collectively, the “Services”) in a way that is subject to the CCPA. It does not apply to personal information that is excluded or exempted. It also does not apply to personal information collected from employees or contractor acting in that capacity.

We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others.

Information We Collect

The below examples are illustrative examples from the CCPA and do not reflect the specific pieces of information we collect.

In the previous 12 months, we have collected the following categories of personal information:

Category	Examples	Collected	Retention Period
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes	Duration to fulfill the purpose for which it was collected or as required by law
B. Personal Information	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes	Duration to fulfill the purpose for which it was collected or as required by law
C. Protected Classification Characteristics Under California or Federal Law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No	N/A
D. Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	Duration to fulfill the purpose for which it was collected or as required by law
E. Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No	N/A
F. Internet or Other Similar Network Activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes	Duration to fulfill the purpose for which it was collected or as required by law
G. Geolocation Data	Physical location or movements.	Yes	Duration to fulfill the purpose for which it was collected or as required by law
H. Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	No	N/A
I. Professional or Employment-Related Information	Current or past job history or performance evaluations.	Yes	Duration to fulfill the purpose for which it was collected or as required by law
J. Non-Public Education Information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No	N/A
K. Inferences Drawn of the Consumer	Inferences drawn from Personal Information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No	N/A
L. Sensitive Personal Information	Personal information that reveals (a) Social Security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; or (f) genetic data. Biometric information processed for the purpose of uniquely identifying a consumer, personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Some sensitive personal information included in this category may overlap with other categories. Purposes for collection: Payment for services we provide Is the sensitive personal information sold or shared? No	Yes	Duration to fulfill the purpose for which it was collected or as required by law

Sources From Which Personal Information Is Collected

We collect your personal information directly from you, from your interaction with the Site, from publicly available sources such as public-facing websites and public filings, and from third parties which collect the personal information directly from you. For more, please see the “Information We Collect From Other Sources” section in our Privacy Policy.

Business or Commercial Purposes for Which Personal Information Is Collected

Your personal information is used for the following purposes:

To present our Services and their contents in a suitable and effective manner for you and your device;
To contact you to provide you with information or services that you request from us;
To comply with applicable laws and regulations;
To advertise opportunities, services, or special events that we think may be of interest to you;
To provide customer support, troubleshoot issues, manage accounts, and respond to requests, questions, or comments;
To carry out our obligations and enforce our rights arising from any contracts; and
To notify you about any additions, upgrades, or changes in our services.

Third Parties with Whom Personal Information Is Disclosed, Shared, or Sold

In the preceding 12 months, we have disclosed the following personal information about consumers for business purposes. We disclose personal information in categories A (identifiers), B (personal), I (employment), and L (sensitive) with service providers.

We may disclose all of our information, including your personal information to our subsidiaries and affiliates in connection with providing the Services to your or otherwise in connection with business operations.

In the preceding 12 months, we have shared for cross-contextual behavioral advertising personal information in categories A (identifiers), B (personal), D (commercial) F (internet), G (geolocation) and K (inferences).

In the preceding 12 months, we have sold personal information in categories A (identifiers), B (personal), and I (employment). We also use cookies and other tracking technologies that may be considered a sale of personal information under the CCPA. Categories of third parties to whom personal information is sold under the CCPA include data analytics providers, advertising and marketing providers, and customers that purchase memberships to our marketplace.

You can opt out of our tacking technologies for analytics and advertising service providers by clicking the Your Privacy Choices link. Please not that your use of our website will still be tracked by Dakota and our service providers.

We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

Individual Rights

(a) Right to Know About Personal Information Collected, Disclosed, Shared, or Sold

You have the right to know what personal information we collect about you and how we use, share, and disclose that information (“Right to Know”). If you make a Right to Know Request you may request the following information about Dakota’s information practices: about you to third parties. There are two types of Rights to Know requests that you can make:

Categories of personal information we collect, sell, or share about you;
Categories of sources from which we collect personal information about you;
Categories of third parties to whom we sell, share or disclose your personal information;
Business or commercial purpose for which we collect, sell or share your personal information;
Specific pieces of personal information we collect about you.

This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

There are certain exceptions to a consumer’s Right to Know. We will state in our response if an exception applies.

(b) Right of Deletion

You have the right to request that we and our service providers delete any personal information about your which we have collected from you upon receipt of a verifiable request. This right is subject to certain exceptions. We will state in our response if an exception applies.

(c) Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to opt-out of the sale or sharing of your personal information by a business subject to certain laws and regulations.

We recognize the Global Privacy Control (“GPC”). Your browser must be able to support the GPC for us to recognize your opt-out preference signal.

Please note that opt-out choices may be stored via cookies. If you clear cookies, if your browser blocks cookies, or if you view the page from a different browser or device, your opt-out choice may no longer be logged or recognized.

For more information, please visit our Do Not Sell or Share My Personal Information page.

(d) Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law. We will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. We will also not retaliate against any employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.

(e) Right of Correction

If we maintain inaccurate personal information about you, then you have the right to request that we correct the inaccurate personal information. We will process this request upon receipt of a verifiable request and will take into account the nature of the personal information and purposes of processing the personal information.

(f) Right to Limit Use and Disclosure of Sensitive Personal Information

If we process information from category L (sensitive personal information), we will only do so for the purposes specifically authorized by California law and in a manner that is necessary and proportionate for those purposes. As such, we do not perform any processing for which a Right to Limit request is available.

(g) Submitting Requests

You can submit your request by emailing us at privacy@dakota.com, or by toll-free phone at 800-264-8574.

(h) Verifying Requests

To ensure the protection of your personal information, we must verify that the individual submitting a request to know, request to delete, or request to correct is the consumer to whom the request relates prior to processing the request. To verify a California consumer’s identity, we may request up to three pieces of personal information about you when you make a request to compare against our records. We may also request that you sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.

(i) Authorized Agents

You may choose a person or a business registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in Dakota denying your request.

Contact Us

If you have any questions about this California Privacy Policy, please contact us by email at privacy@dakota.com or via phone at 800-264-8574.