Last Updated: September 2021
The Company is a holding company for various operating businesses that interact with consumers and other individuals and maintain their own websites and separate privacy policies. The Company is not an operating entity and is not a consumer-facing business. In general, the Company’s interactions with individuals are almost exclusively with shareholders and potential investors.
For purposes of this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.
Personal Information We Collect
We may collect Personal Information from you when you visit our Site, request information from us, register to participate in investor events or receive email alerts, or when you voluntarily provide information to us.
The categories of Personal Information we collect include the following:
- Personal identifiers: Name, email address, telephone numbers, IP address or other unique identifier
- Internet or other electronic activity information: Device information, operating system information, browser type, your browsing and search history on our Site, referring website details, information regarding your interaction with our Site
- Professional information: Business contact data; professional experience and background data
- Audio or visual information: Recordings of investor meetings, video conferences or other events during which you may have spoken or appeared on camera; video captured on CCTV security cameras installed in our offices
How We Use the Personal Information We Collect
We use your Personal Information to provide you with information you request from us, to contact you, to provide you with news and other information about the Company, to facilitate your participation in investor meetings or events, and for general corporate communications.
Additionally, we use Personal Information, including information about your use of our Site, to prevent fraud, activities that violate our Terms of Service or that are illegal; and to protect our rights and the rights and safety of others.
How We May Share Personal Information
We may share your Personal Information with third-party vendors that need such information to perform services for us in the operation of our business. We may also share your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your Personal Information with third parties to help detect and protect against fraud or data security vulnerabilities. We may transfer your Personal Information to a third party in the event of a sale, merger, reorganization of our entity or other restructuring.
We do not sell your Personal Information.
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
Do Not Track
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, our Site does not respond to browsers’ do not track signals.
Personal Information of Minors
Our Site is not directed to minors under the age of 13.
Third Party Websites
Our Site may contain links to other third-party websites, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Similarly, we are not responsible for the activities and practices that take place on the websites of our subsidiaries or companies in which we invest, each of which is a separate business entity.
How We Keep Your Personal Information Secure
We implement and maintain reasonable security measures appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, physical and technical safeguards, although such safeguards may not always be adequate to prevent all breaches of security.
Changes to This Policy
We will review and update this Policy periodically. We will notify you of material changes to it by posting on our Site a notification that the Policy has been revised and by updating the effective date of the Policy.
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at firstname.lastname@example.org.
If there are any questions regarding this Policy or to request a copy of this Policy in another format you may contact us at email@example.com.