Last Updated and Effective as of: March 1, 2021
- Identity Data, which includes name or other similar identifiers.
- Contact Data, which includes your contact information such as email address, phone number, or mailing address.
When you use our Websites, we may also collect certain other types of information that do not specifically identify you but may nonetheless be considered “personal information” in certain jurisdictions, such as California. This includes information such as:
- Online identifiers such as internet protocol (IP) address, cookie identifiers and similar device identifiers.
- Internet or other electronic network activity information, which includes clickstream data, technical data, and usage data, device and operating system used to access the Websites, information about how you use our Websites including the pages viewed, browsing history, and time spent on our Websites.
- IP Geolocation Data.
We collect this information automatically and indirectly through the use of our cookies and other tracking technologies. For more information on cookies and trackers, please see the sections titled “Cookies and other Tracking Technologies” and “Clickstream Data”.
Clickstream Data – As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of device and browsing software you use and the address of the website from which you linked to the Website. We may collect and use clickstream data to anonymously determine how much time visitors spend on websites, how visitors navigate throughout websites and how we may tailor our services to better meet consumer needs. This information will be used to improve our services. Any collection or use of clickstream data will be anonymous and will not intentionally contain any Personally Identifiable Information.
Use and Disclosure of Your Information: We may send your information (including your Personally Identifiable Information) to our affiliates and third parties to help us process your information for the purposes set out in this policy. We will only use your information as described herein:
- We will use your information to operate our Websites.
- We may use your information to respond to your direct inquires.
- We may permit our vendors and subcontractors to access your information in connection with performing services for us.
- To provide you with notices about your accounts.
- To provide you with information, products, or services that you request from us.
- We may disclose your information as required by law or legal process.
- We may disclose your information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the Website.
- We may disclose your information in connection with a bankruptcy proceeding or the sale, merger or change of control of East Rock or the division responsible for the services with which your information is associated.
Please note that if you specifically consent to additional uses of your Personally Identifiable Information, we may use your Personally Identifiable Information in a manner consistent with that consent.
We may also aggregate information collected from our users (such as the number of users in a particular region or having particular characteristics) and use such aggregated information in any lawful manner.
Third-Party Links: As a convenience to you, we may provide links to third-party websites, apps or services from within the Websites. We are not responsible for the privacy practices or content of these third-party sites, and by providing a link we are not endorsing or promoting such third-party sites. When you link away from our Website, you do so at your own risk. We encourage you to read the policies and terms of every website, app or service you visit.
Cookies – If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web-browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve Personally Identifiable Information from your device without your knowledge.
Do Not Track – Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.
California and Nevada Residents – If you are a resident of California or Nevada, please see “Jurisdiction Specific Notices and Rights” for additional rights you have under applicable law.
Data Security: Although we strive to protect your non-public personal information, East Rock Capital, LLC 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 non-public 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 Personally Identifiable Information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your Personally Identifiable Information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.
Information Relating to Children: We do not knowingly collect information from anyone under the age of 13. 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.
JURISDICTION SPECIFIC NOTICES AND RIGHTS
California law provides California residents with specific rights regarding their personal information. The California Consumer Privacy Act of 2018 (“CCPA”) defines “personal information” as information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This section describes the rights that California residents have and explains how to exercise those rights, subject in all cases to any limitations set forth in the CCPA. Please refer to the section(s) entitled “Information We Collect” and “Use and Sharing of Information” above for more detail about the types of information collected, the purposes for which and sources from where we collect personal information, and the third parties with whom we share personal information.
California Specific Rights, Choices, and Opt-Outs: The CCPA provides California residents with specific rights regarding their personal information. The subsections that follow describe the rights that you have under CCPA if you are a California resident and explain how you can exercise those rights.
- Right to Know About Personal Information Collected, Disclosed, or Sold. You have the right to request that we disclose certain information to you about our collection, use, disclosure, or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Your Right to Know or Delete), and subject to certain limitations that we describe below, we will disclose such information to you. You have the right to request any or all of the following:
- The categories of personal information we collected about you.
- The categories of sources from which the personal information is collected.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The categories of personal information about you that we have sold or disclosed for business purposes and the categories of third parties to whom the information is sold or disclosed.
- The specific pieces of personal information we collected about you.
- Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Right to Know or Delete), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under the CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.
- Exercising Your Right to Know or Delete. To exercise your right to know or delete, please submit a request to us by emailing us at firstname.lastname@example.org.
Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorized representative of that person. For more information about verification, see Response Timing and Format immediately below.
- Response Timing and Format. We will confirm receipt of your verifiable consumer request within ten (10) days and endeavor to respond within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will depend on the type, sensitivity, and value of the information, including the risk of harm to you posed by any authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply.
- Personal Information Sales Opt-Out and Opt-In Rights. In the preceding twelve (12) months, we have not sold personal information as we understand that term to be defined under the CCPA and its implementing regulations.
- Non-Discrimination. We will not discriminate against you for exercising any of your CCPA 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 email@example.com.
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