Privacy Policy

Data Security

Although we strive to protect your Personal Information, East Rock cannot ensure or warrant the security of any information you provide or transmit to us, and you do so at your own risk. In the event of a breach of the confidentiality or security of your Personal Information, we will attempt to notify you as soon as reasonably practicable so you can take appropriate protective steps. If you have consented to our using electronic communications or electronic delivery of statements, we may notify you under such circumstances using the most current email address you have on record with us.

Data Retention

We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Website and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your Personal Information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

Nevada Privacy Rights

If you are a Nevada resident, you have the right to request that we do not sell (as defined by N.R.S. 603A) certain Personal Information that we have collected, or may collect, from you. We do not “sell” your Personal Information as defined by N.R.S. 603A. However, if you would like to make such a request you may do so by contacting us at legal@eastrockcap.com.

Information Relating to Children

We do not knowingly collect Personal Information from anyone under the age of 18. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

Privacy Policy Updates

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. However, if at any time in the future we plan to use Personal Information in a way that materially differs from this Privacy Policy, we will post such changes here. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

Location

Our Websites are maintained in the United States of America. By using the Websites, you freely and specifically give us your consent to export your Personal Information to the USA and to store and use it in the USA as specified in this Privacy Policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law-enforcement authorities in the USA.

Contact

For questions or concerns relating to this Privacy Policy or your Personal Information, we can be contacted at: legal@eastrockcap.com.

ADDITIONAL U.S. STATE PRIVACY RIGHTS

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, or Montana or another state with a similar comprehensive consumer privacy law (collectively, “Covered States”), you may have specific rights regarding your Personal Information under the California Consumer Privacy Act (“CCPA”), Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, Texas Data Privacy and Security Act, Oregon Consumer Privacy Act, Montana Consumer Data Privacy Act, and similar laws in other U.S. states (collectively, “State Privacy Laws”). This section describes the rights that consumers of Covered States have and explains how to exercise those rights. To be clear, these rights are granted (i) to the extent that East Rock is not otherwise exempt from applicable State Privacy Laws and (ii) only to the extent that you are considered a consumer of a Covered State, and East Rock is acting as a “controller” or “business” (as applicable) under State Privacy Laws with respect to your Personal Information.

The categories of Personal Information we process, our purposes for processing your Personal Information, the categories of Personal Information we share with third parties, and the categories of third parties with whom we share it are set forth in the terms of the Privacy Policy above.

Information We Collect; How We Collect It; How We Use It

General information regarding our collection, use, and disclosure of Personal Information is set forth in the Privacy Policy above. In the past 12 months, we have collected categories of Personal Information described in the section of the Privacy Policy above titled Information We Collect, and we have collected this information from the sources described in the section titled Information We Collect. Depending on your level of interaction with us, we may not have collected your Personal Information from all of the categories listed in the Privacy Policy above. We collect and use your Personal Information for the business or commercial purposes described in the section titled Use of Your Information, and retain it pursuant to the section titled Data Retention. We disclose the following categories of Personal Information for business or commercial purposes to the categories of recipients listed below:

• Identifiers and contact information: We disclose this information to service providers who perform business services for us.
• Device information and unique identifiers: We disclose this information to service providers who perform business services for us; and third parties, such as analytics networks.
• Internet or other electronic network activity information: We disclose this information to service providers who perform business services for us; and third parties, such as analytics networks.

Rights to Your Information

In addition to the rights set forth in our Privacy Policy, State Privacy Laws may, depending on your state of residence, provide you with the following rights:

• Right to Know. You may have the right to know whether we process your Personal Information and to access such Personal Information. You may also have the right to request that we disclose certain information to you about our collection, use, or disclosure of your Personal Information.
• Right to Data Portability. You may have the right to obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means.
• Right to Delete. You may have the right to delete Personal Information that you have provided to us or that we have obtained about you. Please note that we may deny such request if the requested deletion falls under an exception as set forth in the State Privacy Laws.
• Right to Correct. You may have the right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes for which we process it.
• Right to Opt-Out. You have the right to opt out of the processing of your Personal Information for purposes of: (i) targeted advertising; (ii) the sale of Personal Information; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. As of the latest date of the Privacy Policy:
  • We process Personal Information or share it with third parties for the purposes of targeted advertising;
  • We sell your Personal Information in exchange for monetary or other valuable consideration; and
  • We do not engage in profiling decisions based on your Personal Information that produce legal or similarly significant effects concerning you.

To opt out of the sale or sharing of your Personal Information, please visit the page “​​Do Not Sell or Share My Personal Information”. For residents of California, Colorado, and Connecticut and elsewhere when required by State Privacy Laws, we will also treat certain opt-out preference signals (i.e. Global Privacy Controls) as valid opt-out requests. We do not sell or share the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is less than 16 (but greater than 13) years of age, or the parent or guardian of a consumer less than 13 years of age. To our knowledge, we do not sell or share the Personal Information of minors under 16 years of age.

• Right to Non-discrimination. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights. Unless permitted by the State Privacy Laws, we will not:
  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights; Verifying Your Identity

To exercise any of your privacy rights, or if you have any questions about your privacy rights, you may contact us by calling 212-630-5000 between 9:00 AM and 5:00 PM ET or emailing legal@eastrockcap.com.

After submitting a request, we will take steps to verify your identity in order for us to properly respond and confirm that it is not a fraudulent request. In order to verify your identity, we will ask, at a minimum, that you provide your name and email address so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected Personal Information, we may contact you for more information, or we may not be able to meet your request.

Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your personal information. If you are making a request as the authorized agent of a consumer, we will ask you also to submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s Personal Information, we may ask you to submit reliable proof of your identity.

Response Time; Your Right to Appeal

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, State Privacy Laws allow us up to 90 days to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.

If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. Depending on your state of residence you may have the right to appeal within a reasonable period of time after you have received our decision. If you have this appeal right, within 60 days (45 days for residents of Colorado) of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint.

California “Shine the Light”

In addition to the above rights, under California Civil Code Section 1798.83 (“Shine the Light”), California residents may have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of Personal Information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. However, as of the effective date of this Privacy Policy, we have not shared Personal Information with any third party for its direct marketing purposes.