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Privacy Policy

Capteris logo in color

Respecting and protecting investor privacy is vital to our business. This Privacy Policy describes how Capteris Capital, LLC (together with its subsidiaries and affiliates, “Capteris”, “we”, “us” and “our”) gathers and uses personal information about you when you visit our website that links to this Privacy Policy; how we protect and share this information; and the rights you may have in relation to this information. Please read this Privacy Policy carefully, and consult our Terms of Use for more information about the general terms and conditions regarding your use of our website.

A. The Types of Information We Collect

When you visit and browse our website, you may provide us with information, and we will collect certain information automatically.

1. Information You Provide to Us

 

In order to access certain services provided via our website or to request certain information from Capteris via our website, you will be required to provide certain personal information.

 

This may include your name, postal address, e-mail address, telephone number, facsimile number, investor status, or other information about yourself.

 

2. Information We Collect Automatically

 

We also collect information about you automatically.

 

For example, when you visit our website, we collect your IP address, your browser type, your operating system, the pages you view on our website, the duration of your visit, the pages you view immediately before and after you access our website, and the search terms you enter on our website.

 

We collect this information using cookies, which are small files that a website sends to your computer or device while you are viewing the website, or other technical methods to track visitor usage, including web beacons, which are small pieces of data that are embedded in images on the pages of a website.

 

We and other companies use cookies and web beacons for a variety of purposes. For instance, when you return to our website after logging in, cookies provide information to our website so that our website will remember who you are. We use web beacons and other technologies to analyze the traffic patterns on our website, such as the frequency with which our users visit various parts of our website.

 

You may be able to have your browser warn you when a cookie is sent, and you may be able to turn off all cookies. You can do this through your web browser settings. Each browser is different, so look at your browser Help menu to learn the correct way to modify your cookie settings. If you turn cookies off, you won't have access to many features that may improve your browsing, like the features mentioned above, and some of our services may not function properly.

 

Other technical methods including web beacons may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send visitors to our website to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails.

 

3. Additional Information Collection Practices

 

Our website may contain links to websites operated by third-parties, and your personal information may be collected by those third-parties when you use their websites.

 

Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to our website). These links are provided to you for convenience purposes only, and you access them at your own risk.

 

Some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies.

 

The third-party partners we receive personal information from include web hosting providers. We receive information related to name, occupation, address, and contact information from third party partners. Our use of information received from such a third party will be dictated by the third party’s privacy policy and not this Privacy Policy.

 

We will link the information that we collect automatically with the information you provide us, and we will combine the information we collect online with information we collect offline or that is collected by third-parties.

B. How We Use the Information We Collect

We use information we collect about you primarily to: provide services to you in accordance with any contract with you, communicate with you, and manage and improve our services for you and our other investors, as permitted by applicable laws.

 

We use your personal information to:

 

  • respond to your requests for forms, literature, or information, on the basis that it is in our business interests to respond to your requests, and you have requested that we do this;

  • improve our website and learn about how visitors use our website. This is necessary for us to improve the services we offer through our website, and benefits you as it helps us make our website more usable and appealing;

  • communicate with you about our products and services, including providing you with information about features on our website and possible changes to our Privacy Policy or Terms of Use. If required by applicable law, we will only send these messages on the basis that you have consented, or otherwise it will be to meet our business interests in providing information to our investors about new products and features. You can opt out of receiving marketing communications at any time;

  • comply with legal obligations; and

  • protect our rights, your rights, and the rights of others, as this may be necessary to meet our own high standards of business practice.

 

We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you. For example, we may prepare aggregated reports about how visitors tend to interact with our website for research about the use of our website and how our website could be improved, from which your interactions with our website cannot be singled out.

C. How We Share the Information We Collect

1. In Connection with Third Party Offers

 

We will share information about you with third-parties when you engage in certain activities on our website that are sponsored by third-parties. For example, you may choose to obtain products or services offered by a third-party or elect to receive information or communications from a third-party. When you engage in such third-party offerings, we may share information (e.g., your e-mail address) with third-parties in association with the offerings.

 

We disclose this information to third-parties for the purposes and on the basis described above (see Section B), for example, to process your transactions and to respond to your requests for information or communications from third-parties.

 

2. Service Providers

 

Sometimes we engage companies that act on our behalf in association with the operation of our website. For example, such companies may deliver products or services, improve the functionality of our website, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you.

 

Except as otherwise disclosed in this Privacy Policy or as otherwise communicated to you, Capteris takes reasonable steps to require these companies to collect, store, and use information about you only on our behalf and in accord with this Privacy Policy. We share personal information with service providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.

 

3. Analytics Providers

 

We engage third-party analytics providers to help us understand how users engage with our website. These third-parties may use cookies and similar technologies to collect information about your use of our website as well as information about your use of other websites over time.

 

The third-party services we use include, but may not be limited to: Google Analytics and Wix, which may provide you with choices about how they collect and use information. As described above, we share personal information with analytics providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.

 

4. Additional Sharing Practices

 

From time to time, we share your information with our affiliates and subsidiaries, or with our attorneys, banks, auditors, securities brokers and other service providers in connection with the purposes described above. From time to time, we partner with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we will share your information with our co-sponsor(s) and partners to the extent necessary for the partnership to function.

 

We may disclose information when we believe in good faith that such disclosures:

 

  • are required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency's request;

  • will help to protect our rights or enforce our Terms of Use;

  • will support our detection, prevention, or response to fraud or intellectual property infringement;

  • will help protect your safety or security, including the safety and security of property that belongs to you; and

  • will protect the safety and security of our website, databases, and/or third-parties, including the safety and security of tangible and/or intangible property that belongs to us or to third-parties.

  • We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.

 

The above-described disclosures are provided on the basis that they are either necessary to comply with our legal obligations or they are necessary to meet our legitimate interests in managing our business efficiently and for developing future business.

 

Additionally, we reserve the right to share with third-parties information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.

D. The Security Measures We Take to Safeguard Information

The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. From time to time, we review and consider updates for our security procedures. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

E. Updating Your Contact Information

You may update your contact information and/or modify your communication preferences by sending us an e-mail at customerservice@capteriscapital.com. Additionally, we may provide tools on our website that facilitate such updates or modifications.

F. Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.

 

Third-parties, such as our analytics providers, may collect data that relates to you on our website, across time, and over other websites. We cannot control third-parties’ responses to do-not-track signals or other such mechanisms. Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

G. California Privacy Rights

If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you for the third-parties’ direct marketing purposes. If you wish to exercise those rights, please email us at customerservice@capteriscapital.com

H. Your Choices and Rights

If you no longer wish to receive marketing materials from us, you can let us know by contacting us at customerservice@capteriscapital.com or by clicking the 'unsubscribe' link or using other unsubscribe features that we provide in our marketing communications.

 

Subject to local law, you may have certain additional rights regarding your personal information. These may include the following rights to: access your personal information; rectify the information we hold about you; erase your personal information; restrict our use of your personal information; object to our use of your personal information (as described above); receive your personal information in a usable electronic format and transmit it to a third-party (also known as the right of data portability); and lodge a complaint with your local data protection authority, and withdraw any consent you have given to uses of your personal information. If you would like to discuss or exercise the rights you may have, feel free to contact us at customerservice@capteriscapital.com.

I. Where Is Information Processed?

We process information collected via our website in and subject to the laws of the United States, which may not provide the same level protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.

 

In some cases, your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union or other applicable laws. However, we have put in place appropriate safeguards (such as standard contractual clauses approved by the European Commission) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place or to obtain a copy, please contact us at customerservice@capteriscapital.com.

J. How Long Is Information Retained?

We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.

 

When deciding how long to keep your personal information after our relationship with you has ended, we take into account how long we need to retain the information to fulfill the purposes described above and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.

K. Amendments to This Privacy Policy

We process information collected via our website in and subject to the laws of the United States, which may not provide the same level protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.

 

In some cases, your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union or other applicable laws. However, we have put in place appropriate safeguards (such as standard contractual clauses approved by the European Commission) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place or to obtain a copy, please contact us at customerservice@capteriscapital.com.

L. Cookie Table 

Name
Description
Category
 Expiry

M. How to Contact Us

If you have any questions regarding this policy or our privacy or data protection practices, please feel free to contact us at customerservice@capteriscapital.com

AWSALB

AWS ELB application load balancer

Strictly Necessary Cookies

5 Days

ASP.NET

_SessionId

General purpose platform session cookie, used by sites written with Miscrosoft .NET based technologies. Usually used to maintain an anonymised user session by the server.

Strictly Necessary Cookies

0

AWSALBCORS

This cookie is managed by AWS and is used for load balancing.

Strictly Necessary Cookies

5 Days

AWSALBTG

This cookie is associated with Amazon Web Services Elastic Load Balancing functionality. It is used to honor sticky sessions and enable target group stickiness. When the load balancer first routes a request to a weighted target group, the cookie is generated and included in subsequent requests to the load balancer. It is used to route requests to the target group specified in the cookie.

Strictly Necessary Cookies

7 Days

AWSALBTGCORS

This cookie is associated with Amazon Web Services Elastic Load Balancing functionality. It is used to honor sticky sessions and enable target group stickiness. When the load balancer first routes a request to a weighted target group, the cookie is generated and included in subsequent requests to the load balancer. It is used to route requests to the target group specified in the cookie. Specifically, the AWSALBTGCORS cookie is used with CORS (cross-origin resource sharing) requests that require the SameSite attribute to enable stickiness. It includes all the same information as the AWSALBTG cookie, plus the set SameSite attribute.

Strictly Necessary Cookies

7 Days

_gat

This cookie is associated with Amazon Web Services Elastic Load Balancing functionality. It is used to honor sticky sessions and enable target group stickiness. When the load balancer first routes a request to a weighted target group, the cookie is generated and included in subsequent requests to the load balancer. It is used to route requests to the target group specified in the cookie.

Performance Cookies

0

_hjTLDTest

When the Hotjar script executes we try to determine the most generic cookie path we should use, instead of the page hostname. This is done so that cookies can be shared across subdomains (where applicable). To determine this, we try to store the _hjTLDTest cookie for different URL substring alternatives until it fails. After this check, the cookie is removed.

Performance Cookies

0

_gid

When the Hotjar script executes we try to determine the most generic cookie path we should use, instead of the page hostname. This is done so that cookies can be shared across subdomains (where applicable). To determine this, we try to store the _hjTLDTest cookie for different URL substring alternatives until it fails. After this check, the cookie is removed.

Performance Cookies

0

_gid

This cookie name is associated with Google Universal Analytics. This appears to be a new cookie and as of Spring 2017 no information is available from Google. It appears to store and update a unique value for each page visited._gid

Performance Cookies

0

gclxxxx

Google conversion tracking cookie

Performance Cookies

0

_hjid

This cookie name is associated with Google Universal Analytics. This appears to be a new cookie and as of Spring 2017 no information is available from Google. It appears to store and update a unique value for each page visited._gid

Performance Cookies

0

_ga_xxxxxxxxxx

To generate statistical data on how the visitor uses the Service

Performance Cookies

 728 Days

_ga

This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.  By default it is set to expire after 2 years, although this is customisable by website owners.To generate statistical data on how the visitor uses the Service

Performance Cookies

 728 Days

ajs_user_id

This cookie helps track visitor usage, events, target marketing, and can also measure application performance and stability. Cookies in this domain have lifespan of 1 year.

Targeting Cookies

0

_gat_xxxxxxxxxxxxxxxxxxxxxxxxxx

Google Analytics Cookies

Targeting Cookies

0

APISID

This DoubleClick cookie is generally set through the site by advertising partners, and used by them to build a profile of the website visitor's interests and show relevant ads on other sites. This cookie works by uniquely identifying your browser and device.

Targeting Cookies

0

_gat_UA-nnnnnnn-nn

Google Analytics Cookies

Targeting Cookies

0

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