First Oregon LLC
My Alts Data Platform
December 10, 2025
I. Introduction
First Oregon LLC (“First Oregon,” “Firm,” “we,” “us,” or “our”) recognizes that the confidentiality, integrity, and appropriate use of client information are fundamental to maintaining trust and fulfilling our responsibilities as a financial technology provider supporting investment reporting and data aggregation.
This Privacy Notice describes the Firm’s policies and practices regarding the collection, use, protection, and limited disclosure of information obtained through the My Alts Data platform (the “Platform”).
First Oregon does not sell, lease, distribute, or otherwise monetize client personal information or investment data.
II. Scope of This Notice
This Notice applies to information collected in connection with:
- Use of the My Alts Data platform
- Interactions with affiliated advisors and authorized users
- Data provided by users, financial professionals, or fund sponsors
This Notice does not govern third-party platforms or services not controlled by First Oregon.
III. Categories of Information Collected
The Firm may collect and maintain the following categories of information:
A. Personal and Account Information
- Identifiers such as name, email address, and contact details
- Account credentials and authentication data
- Professional affiliations, including financial advisor relationships
B. Financial and Investment Information
- Holdings in private funds and alternative investments
- Capital commitments, distributions, and valuation data
- Investor reporting records, including performance analytics
- Documents and materials uploaded to the Platform
C. Technical and Usage Data
- Device identifiers, IP address, and browser characteristics
- Log files, session activity, and system interactions
- Platform usage metrics for performance and security monitoring
IV. Purpose and Use of Information
Information is collected and processed solely for legitimate business purposes consistent with the operation of the Platform, including:
- Delivering reporting, analytics, and data aggregation services
- Generating investor reports and portfolio summaries
- Facilitating authorized communication between users, advisors, and sponsors
- Maintaining system integrity, security, and access controls
- Enhancing platform functionality and user experience
- Satisfying applicable legal, regulatory, and compliance obligations
The Firm does not use client information for:
- Data brokerage activities
- Behavioral advertising
- Third-party marketing or commercial resale
V. Data Sharing and Disclosure Practices
First Oregon adheres to a restricted data-sharing model.
A. No Sale or Monetization of Data
The Firm does not:
- Sell personal information
- Sell financial or investment data
- License client data to third parties
- Participate in data aggregation marketplaces
B. Permitted Disclosures
Information may be disclosed only under limited circumstances:
- Service Providers
To third-party vendors providing technology, hosting, security, or analytics services, subject to contractual confidentiality and data protection obligations. - Authorized Parties
To financial advisors, investment professionals, or fund sponsors, strictly as directed or authorized by the user within the Platform. - Legal and Regulatory Requirements
When required to comply with applicable law, regulation, subpoena, or governmental request. - Protection of Rights and Security
To protect the rights, property, or safety of the Firm, its users, or others.
VI. Sponsor-Provided Content and Communications
The Platform may include communications, updates, and commentary provided by private fund sponsors or issuers.
- Such content is provided by the sponsor and is not independently verified by First Oregon
- Sponsors are solely responsible for the accuracy and compliance of their communications
- User data is not sold or distributed to sponsors beyond functionality expressly authorized by the user
VII. Data Security and Safeguards
The Firm employs commercially reasonable administrative, technical, and physical safeguards designed to protect information, including:
- Encryption of sensitive data in transit and at rest
- Role-based access controls and authentication protocols
- Secure cloud infrastructure and monitoring systems
- Periodic review of security practices and controls
While no system can guarantee absolute security, the Firm maintains a continuous focus on risk mitigation and data protection.
VIII. Data Retention
Information is retained only for as long as necessary to:
- Fulfill the purposes outlined in this Notice
- Maintain business and operational records
- Comply with legal and regulatory requirements
Data may be retained beyond account closure where required by applicable law or for legitimate business purposes.
IX. User Rights and Access
Subject to applicable law, users may have the right to:
- Request access to personal information maintained by the Firm
- Request correction of inaccurate or incomplete data
- Request deletion of personal information, subject to legal retention obligations
- Restrict or object to certain data processing activities
Requests may be submitted using the contact information below.
X. California Privacy Rights
For California residents under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):
- Users may request disclosure of categories and specific pieces of personal information collected
- Users may request deletion of personal information
- Users have the right to opt out of the sale of personal information
First Oregon does not sell personal information.
XI. Children’s Information
The Platform is intended for use by adults and is not directed to individuals under the age of 18.
The Firm does not knowingly collect personal information from minors.
XII. Updates to This Notice
This Privacy Notice may be updated periodically to reflect changes in business practices, technology, or legal requirements.
The “Effective Date” will indicate the most recent revision.
XIII. Contact Information
First Oregon LLC
Email: support@myaltsdata.com
Firm Data Commitment
First Oregon LLC operates under a strict data stewardship model.
Client information is used solely to deliver reporting and platform functionality—never as a product for sale.