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Privacy Policy

LAST UPDATED AND EFFECTIVE AS OF: MARCH 1, 2021

East Rock Capital, LLC and its affiliates (collectively, “East Rock”, “we”, “our” or “us”) understand that privacy is important to users of our websites. This Privacy Policy discloses our practices regarding information collection and usage at www.eastrockcap.com, and any of our other websites where this Privacy Policy appears (collectively, the “Websites”). This Privacy Policy does not apply to any other websites, applications or services provided by us or our affiliates, unless it appears on such website, application or service.

For clarity, this Privacy Policy does not apply to the information we collect from our investors. If you are an investor with East Rock, please see our Privacy Notice separately distributed to you in connection with your investment to understand how we handle information we collect about our investors.

Information We Collect

Your provision of your Personally Identifiable Information to us is completely voluntary. As used in this Privacy Policy, “Personally Identifiable Information” is information that specifically identifies you. The Personally Identifiable Information we collect about you can be provided directly by you to us if you have an account with us, or by contacting us or through other means on our Websites. Categories of Personally Identifiable Information we collect on our Websites include:

  • 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”.

Cookies and other Tracking Technologies
We or our third-party partners may store some information on your device or device hard drive as a “cookie” or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect online identifiers and internet or other electronic network activity information for the purpose of facilitating and enhancing your communication and interaction with the Websites. Such data may include, without limitation, the address of the websites you visited before and after you visited the Websites, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Websites you visit, and what links you clicked on. We use this information to help us maintain and enhance the efficiency and usefulness of the Websites and may use it and other non-personally identifiable information for the purposes described in this Privacy Policy.  Please note that some of this information may include data, such as IP address data or the identifiers associated with your device that are unique to your computer or device. Cookies and similar items are not used by us to automatically retrieve Personally Identifiable Information from your device without your knowledge. Please be advised that certain third parties that are beyond the scope of this Privacy Policy, such as advertisers, may collect information in connection with the Website. We are not responsible for the acts or omissions of such third parties. 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 the Opt-Out of Cookies section below.

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.

Opt Out

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.

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 Personally Identifiable 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 Website is maintained in the United States of America. By using the Website, you freely and specifically give us your consent to export your Personally Identifiable 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 information, we can be contacted at: legal@eastrockcap.com.

JURISDICTION SPECIFIC NOTICES AND RIGHTS

California

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.

  1. 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.
  2. 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 Your 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.
  3. 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 legal@eastrockcap.com.

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.

  1. 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.
  2. 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.
  3. Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.

Nevada

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.