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SARD VERBINNEN & CO. PRIVACY POLICY

This Privacy Policy applies to information that Sard Verbinnen & Co., LLC, and its affiliates (referred to collectively in this Privacy Policy as “we,” “us,” “our” and other similar pronouns) collect through www.sardverb.com, www.sardverb.cn, www.stratgovadvisors.com and www.arcllc.com (collectively, the “Website”).

This Privacy Policy explains the types of information we may collect, how we may use and disclose the information once it is collected, and, where applicable, how you can stop us from collecting, using, disclosing or continuing to hold your information. We want to ensure that in using the Website, you understand the terms of this Privacy Policy, including any subsequent changes made to the Privacy Policy, and are aware of the privacy choices available to you. Please note that this Privacy Policy does not apply to information that you may provide to us, or that we may obtain, where a separate privacy policy is made available to you.

1. What information may be collected?

User-Provided Information

During your use of the Website, you may provide us with personal information, such as your name and e-mail address, or other information that could be used to identify you as an individual or allow someone to contact you, as well as any information associated with such information (collectively, “Personal Information”). Personal Information includes both things that specifically identify you (like your real name) and things that don’t specifically identify you, but might be connected back to you (like the IP address of your computer or the device identifier of your smartphone).

Location Data

When using the Website from a mobile device (a “Mobile Service”), you may share the geographic location of your device with us. Your device location may be transmitted to us whenever a Mobile Service is running (even if you are not actively using the Mobile Service or it is running in the background on your device). Your device may continue to transmit its location to us until you change your device settings.
You should know that turning off location sharing only prevents your device from sharing its precise location. Your network service provider may still provide general location information (based on access points you’ve connected to, for example). The information provided varies by network service provider. You may check with your network service provider to find out what information is provided and if there are ways for you to limit it.

Service Usage Information

As is typical of many web sites and mobile applications, when you use the Website, we may collect information about your device and your usage of the Website, including:

  • Your IP address (which we may associate with your domain name or that of your Internet access provider or wireless carrier, and your location);
  • Unique ID number associated with your device;
  • Other unique identifiers such as advertising identifiers (e.g., “ad-ID” or “IDFA”);
  • Web browser and operating system information;
  • Language of your device;
  • Wireless connections you are using;
  • Referring page that linked you to us;
  • Your activities, including browsing and transaction history;
  • Pages and content you view or click on during your use of the Website, and when and for how long you do so; and
  • Search terms you enter on the Website or a referral site.

In addition, we may deploy tracking technologies through the Website to collect additional information about your use of the Website, as set out in the “Cookies and other tracking technologies” section of this Privacy Policy.

2. How is your information used?

We or our service providers may use the information we collect from or about you to perform the following functions:

  • administer the Website;
  • enable you to use the Website and its features;
  • conduct market research;
  • improve or develop new features and offerings in the Website;
  • send you marketing and other communications, including information about services, developments or events that we think might be of interest to you;
  • assess your level of interest in and use of the Website, e-mails, and other messaging campaigns, both on an individual basis and in aggregate;
  • generate analytics reports on the usage of the Website; and
  • respond to your requests, questions, and concerns.

We may also use Personal Information to meet our internal and external audit requirements and for information security purposes. Where permissible under applicable law, your Personal Information may be used for other purposes, which will be disclosed to you at the time when your information is collected. There may be instances, however, when we will use your Personal Information for purposes that were not disclosed at the time of the data collection; for example, when doing so is necessary to comply with a legal obligation or requirement. We may use Personal Information to: (a) respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (b) enforce our terms and conditions; and (c) protect our rights, privacy, safety, or property, or those of other persons.

Some of the uses specified above are necessary for the performance of a contract between us, or for the provision of a service requested by you. In other cases, the uses are based on our legitimate interests such as marketing our services to people who we believe may have an interest in them or similar services.

3. How do we share the information we collect?

We may share your information:

  • with our lawyers, auditors, and other professional advisors and third party providers of services, such as cloud storage, customer relationship management systems, and analytics databases, which need your information to provide services to us (or on our behalf);
  • when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud, or respond to a government agency, law enforcement, judicial or public authority, or other legal request, or to comply with the law;
  • in connection with a proposed corporate change or dissolution, including, for example, a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business.

We may share anonymous data about usage of the Website (including aggregate data) with others, for their own use, in a de-identified form.

Transfers outside the European Economic Area (“EEA”)

The information described in this section of the Privacy Policy, with respect to the transfer of data outside the EEA, applies to those individuals located in the EEA. To process information of individuals located in the EEA for the purposes set out in this Privacy Policy, it is sometimes necessary for us to share your personal data outside the EEA, for example:

  • with our offices outside the EEA;
  • with service providers located outside the EEA;
  • where we consider that the transfer is necessary for exercising, establishing or defending legal rights including, as appropriate, providing information to respond to a government, law enforcement, judicial or other legal request, or otherwise to comply with applicable law.

Non-EEA countries might not have the same legal framework for data protection as the EEA countries. In particular, the United States, which is the most common destination of our transfers of Personal Information outside the EEA, is not considered to provide a level of personal data protection equivalent to that of the EEA. We will, however, ensure the transfers comply with EU data protection law.

If you would like further information, please see the “Contact us” section below.

4. How do we secure your Personal Information?

We use reasonable technical, administrative and physical security measures to protect Personal Information collected via the Website. We cannot guarantee that any information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from unauthorized access or use (e.g., by hackers). You use the Website, and provide information, at your own risk.

If you correspond with us by e-mail, text message, or using a “Contact us” feature on the Website, a third party could view the information you send in transit by such means. We have no liability relating to disclosure of your information due to errors, omissions or unauthorized acts or failures to act by third parties during or after transmission.

We have procedures in place to deal with any suspected data security breach. If we believe that the security of your Personal Information in our care may have been compromised, we will endeavor to notify you of that development promptly taking into consideration the circumstances. If we have your e-mail address, we may notify you by e-mail. Where legally required to do so, we also will notify any applicable regulator.

5. Cookies and other tracking technologies

We, and/or our service providers or partners on our behalf, may use tracking technologies that may collect information during your visit to the Website. The circumstances in which tracking technologies are deployed may include:

  • We may use cookies or local shared objects, such as “Flash cookies.” Cookies are small data/text files that store information, such as your preferences and account settings, on your computer. Similar to many other websites, if you have enabled cookies to be accepted, we, independently and through enabled third-party tools and programs, collect certain information, such as IP address, browser type, browser language, what pages are visited, the length of each site visit, and the date and time of the user’s visit. This information helps us track trends and improve overall user experiences when using the Website.
  • HTML5 or similar programming technologies may be used to store information on your computer or device about your service usage activities. This information can be retrieved by us to determine how the Website is being used by our visitors and how the Website may be improved.

These tracking technologies may be deployed by us and/or our service providers or partners on our behalf. These technologies may enable us to assign a unique number to your computer or device, and relate information about your use of the Website to other information about you, including your Personal Information. These technologies also enable us to recognize you when you access the Website using different web browsers or devices.

With certain browsers, you may be able to manage website cookies in your browser settings, enable your device to warn you each time a cookie is being sent, and/or change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Website. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser. If you would like to obtain more detailed information about types of cookies, how they are used, and how you can manage your cookie preferences you may want to visit: www.aboutcookies.org or www.allaboutcookies.org. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:

  • Mozilla Firefox®: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
  • Microsoft® Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11
  • Google Chrome™: https://support.google.com/accounts/answer/61416?hl=en
  • Safari®: https://support.apple.com/kb/PH21411?viewlocale=en_US&locale=en_US

6. Links and connections to Third Party Services

The Website may contain links, banners, widgets, or advertisements that lead to third-party web sites. We are not responsible for these other web sites, and so their posted privacy policies (not this Privacy Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of web sites visited after leaving the Website to learn about how your information is treated by others.

7. Do Not Track Disclosures

Some web browsers may transmit “do-not-track” (“DNT”) signals to mobile applications with which the user communicates. We currently do not change our tracking practices in response to DNT settings in your web browser.

Our third party partners, such as web analytics companies, may collect information about you and your online activities over time and across the Website. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. We utilize Google Analytics for our web analytics and you can opt out of your usage data being included in our Google Analytics reports by visiting https://tools.google.com/dlpage/gaoptout.

8. Your rights relating to your Personal Information

You can opt out of our promotional e-mails by clicking the opt-out/unsubscribe link within the e-mail you receive. Please understand that it may take us a few days to process any opt out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions, and communications with us.

In some jurisdictions, including in the countries of the European Economic Area, you have the right, in certain circumstances, to (i) access and receive a copy of your Personal Information, (ii) require us to delete your Personal Information, (iii) require us to restrict processing of your Personal Information (for example, if you contest the accuracy of that information), (iv) receive a copy of the Personal Information you provided to us in a structured, commonly used, and machine-readable format and/or instruct us to transmit that data to a third party; and (v) object to our continued processing of your Personal Information, for direct marketing (including profiling) or other purposes. You can exercise these rights free of charge by contacting us using the details in the “Contact us” section below.

9. Data Retention

Your Personal Information will be held for the purposes and uses set out in this Privacy Policy and for as long as there is a legal, taxation, accounting, risk management or business requirement to do so. Different retention periods apply to different types of records and data which are dependent on the nature of your interaction with us.

10. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. When we do, we will let you know by posting the changed Privacy Policy on this page with a new “Last Updated” date. In some cases, we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you.

11. Children’s privacy

The Website is not aimed at children. If, however, we collect and use information about children, we will comply with industry guidelines and applicable laws.

12. Contact us/complaints

If you have any questions or comments regarding our privacy practices, you may contact us at: SVC-Legal@SARDVERB.com. We will work to resolve any query or concern you may raise about our use of your information.
Individuals located in the EEA have the right to lodge a complaint with a supervisory authority of the EEA state where you work or live or where any alleged infringement of data protection laws occurred. A list of the supervisory authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Effective Date: July 30th, 2018


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