Privacy Policy

This Privacy Policy sets out the privacy practices of the Website located at www.stockdalecapital.com, owned and operated by Stockdale Capital Partners, LLC (“STOCKDALE”) and which is defined in our Terms of Use (of which this Privacy Policy forms a part) as the “Website.” For purposes of clarity, the Website does not include the Client Portal hosted by IntraLinks or any other websites not hosted on www.stockdalecapital.com. This Privacy Policy applies to Personally Identifiable Information that you provide to us through the Website and describes the types of information we gather about you through the Website and the ways in which we use and share this information. This Privacy Policy does not apply to any information that we may collect offline, through another website (including the Client Portal), or through any other means (for example, at a live event or through the mail, which, for natural persons, is subject to STOCKDALE’s privacy policy). Any terms that are not defined in this Privacy Policy shall have the meaning ascribed to them in our Terms of Use.

Please read this Privacy Policy carefully, since it forms part of the Terms of Use that together constitute a binding legal agreement between you and us.  By using or attempting to use our Website, you accept, without limitation or qualification, and are agreeing to be bound by and comply with everything contained in our Terms of Use, including this Privacy Policy. If you do not agree to any of these provisions, do not use or attempt to use our Website. In addition, this Privacy Policy applies only to information provided by or collected from users in the United States and is not intended to describe data handling procedures for information collected by other linked websites or business partners.

For purposes of this Privacy Policy, “Personally Identifiable Information” means individually identifiable information about you (e.g., first and last name, address, email address, telephone number, or any other information that permits a specific individual to be contacted physically or online). Personally Identifiable Information does not include any aggregate or combined information, such as data that is related to you but studied as a group and does not identify you specifically, nor does it include any Technical Information (as defined below).

Collection and Use of Personally Identifiable Information

Except for Personally Identifiable Information you voluntarily choose to provide to us through the “Contact Us” form on the Website (e.g., name, email address, and phone number), we do not collect Personally Identifiable Information about you on or through our Website. We will use your information to respond to your requests, inquiries or questions you submit to us using our Website, to communicate with you about our services, to offer you products or services, and for other purposes.

When you complete Website forms online (including through the “Contact Us” form), you agree to provide accurate, complete and true information. You agree not to use or submit any false or misleading names or any other inaccurate or misleading information.

Collection and Use of Technical Information

In some cases, when you visit our Website, we and our operational service providers may collect and store certain technical information about your visit that our technology is able to detect automatically, such as your device’s IP address, MAC address, the type of browser and operating system you are using and your device identification number (“Technical Information”). None of the Technical Information is deemed to be Personally Identifiable Information. We don’t collect Personally Identifiable Information about you in this process and we use Technical Information to help administer and improve our Website and to enable us to provide users like you, a more customized or personalized experience on our Website. We may study aggregate data in order to enhance our existing services or develop new services. In limited situations, we may use IP addresses and/or MAC addresses to identify a device when we determine that it is necessary to enforce compliance with our Terms of Use or to protect our Website, our users or other individuals or if we know or have reason to believe any law or regulation is being violated.

Sharing of Information

Our policy is to not sell or rent your Personally Identifiable Information to unrelated third parties without your consent. We may, however, share the information we collect about you (including Personally Identifiable Information) in certain situations, including, without limitation, the following:

  • With our affiliates and business partners; When you expressly consent, including consent included in your agreement to be bound by this Privacy Policy and our Terms of Use, of which this Privacy Policy forms a part;
  • With third parties who perform services on our behalf (e.g., we may use third parties to host our Website);
  • With law enforcement agencies, governmental and regulatory officials, in regard to legal proceedings or with other third parties when required by or in cooperation with law, court orders, regulation or legal processes;
  • When we believe, in our sole determination, that disclosing this information may be necessary to enforce our policies, our rights or these Terms of Use or to protect any of our other rights or property, safety or the rights of any third party;
  • When we believe, in our sole determination, that disclosing such information is necessary to address an emergency that poses a threat to health or safety, a security risk or to take action in response to actual or potentially illegal activities (e.g. fraud protection); and/or
  • With other business entities should we plan to merge with or be acquired by that business entity or in connection with any sale of assets, acquisition, transition of service to another provider, bankruptcy, insolvency or receivership or other corporate restructure or re-organization.

 

Use of Cookies and Other Web Technologies

We may use cookies, web beacons and other technologies (“cookies”) on the Website in a number of ways. We may use cookies, for example, for record keeping, to track your movements when you visit the Website and/or to help us determine what type of information might be best to present to you and among other things, our objective is to enhance the user’s experience on our Website and make it more useful and relevant to our users. Although you can choose not to accept cookies through a setting on most browsers (which can also be set to notify you each time a cookie is set), if you choose to refuse cookies, you may not be able to use all of the features or functions of the Website.

Online Tracking

STOCKDALE does not track its Website users over time and across third party websites, nor does it allow third parties to collect Personally Identifiable Information from the Website. As such, the Website does not respond to browser “Do Not Track” requests.

Retention of Information

Any information we collect may be retained for an indeterminate period of time.

Security

We urge you to take every precaution to protect your Personally Identifiable Information when you are on the Internet. We are committed to protecting the security of the information collected from users of our Website. However, it is not possible to guarantee the security or integrity of information disclosed online because no data transmission over the Internet is completely secure. Because no physical or electronic security is impenetrable, by using our Website, you agree to assume all risk in connection with your use of the Website. We will not be liable for any lack of security relating to the use of the Website by you. You agree that you will not hold STOCKDALE liable for any damages resulting from any loss of privacy or security occurring in connection with any communications over such networks.

Links to Other Sites

The Website may contain links to third party websites (including the Client Portal website and any social media websites). Please be aware that, when you click on (i.e., select) a link applicable to another website, your browser will re-direct and leave our Website, and your activities and the collection of information about you will no longer be subject to the provisions of this Privacy Policy. For example, any content you post on social media platforms, such as pictures, information, opinions, or any Personally Identifiable Information that you make available to other participants on these social platforms, is subject to the terms of use and privacy policies of those platforms. We are not responsible for the privacy practices of other websites or third party service providers, and we do not control or monitor such third party websites, nor do we assume any liability or responsibility for any content or materials or anything else associated with or on third party websites.  You should review the terms and conditions and privacy policies of those websites so you know what terms and conditions apply to you when you are visiting or using these third party websites.

Non-U.S. Residents

The Website is intended for users in the United States only, and this Privacy Policy applies only to information provided by or collected from users in the United States. If you provide Personally Identifiable Information to us, it may be transferred to and processed on computers in the United States and other countries.  Do not provide Personally Identifiable Information to us if you do not want or consent to this information being transferred to the United States or to other countries, or if the laws in your country have restrictions on these types of transfers.  Your provision of Personally Identifiable Information to us will be handled in accordance with this Privacy Policy.  Your provision of Personally Identifiable Information to us through the Website means that you agree to the terms of this Privacy Policy.

Changes to our Privacy Policy

You understand that we have the right to change this Privacy Policy from time to time, subject always to applicable law and regulation. If we make changes, we will post the revised Privacy Policy on our Website and update the “Effective Date” date to reflect the effective date of the changes. We will notify you of any material changes to this Privacy Policy by posting them on this page and may, at our option, also choose to alert you to the changes in a more prominent way (e.g., via email). You acknowledge and agree that if you use the Website after we post changes, you will have agreed and accepted the Privacy Policy with any and all changes and modifications we have made. If you do not agree to all of the changes we make, do not use our Website.

Questions

If you have any questions about this Privacy Policy, please complete our “Contact Us” form on our Website.

Effective Date: September 1st, 2017

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