OUR COMMITMENT TO PRIVACY
Your privacy is important to Declaration Partners LP and its affiliates (together, “Declaration,” “our,” “us” or “we”). To better protect your privacy, we are providing information explaining our online information practices.
THE INFORMATION WE COLLECT AND HOW WE USE IT
We may collect various types of information in connection with use of the Website. For example, knowing how users use our website – tracking their movement through this website via “cookies”– helps us improve website design and usefulness. As a result, Declaration’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (“IP”) addresses. Declaration generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” page.
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through the Website; any transmission of information or data by you to or through the Website is at your sole risk.
You may request to access any personally identifiable information we have about you by contacting us at 1.833.968.8686.
You may access any personally identifiable information we have about you by contacting us at 1.833.463.0211.
NOTIFICATION OF CHANGES
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
We collect limited types of personal information through the Website. The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we collect from individuals on the Website may include the following:
We do not knowingly collect or solicit personal information from anyone under the age of 18.
HOW DO WE OBTAIN YOUR PERSONAL INFORMATION?
In connection with forming and operating the Website, we may collect and maintain your nonpublic personal information from the following sources:
We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We will use your personal information for one or more of the following business purposes:
Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We do not sell any of the personal information we collect about you to third parties.
We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth above in “WHAT INFORMATION DO WE COLLECT ABOUT YOU?”
We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.
HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?
We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
YOUR RIGHTS UNDER THE CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
Call us at the following toll-free number: 1.833.463.0211; or call Leigh Rovzar at 212.321.4038.
Email us at the following email address: email@example.com
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline.
GDPR PRIVACY NOTICE
OUR COMMITMENT TO PRIVACY
Your privacy is important to Declaration LP and its affiliates (together, “Declaration,” “our” or “us,” “we”). To better protect your privacy, we are providing information explaining our online information practices.
In this GDPR Privacy Notice, “European Data Protection Legislation” means all applicable laws relating to the protection of personal data in force from time to time in the EU or the UK, including (without limitation): Regulation (EU) 2016/679 (the “EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland, the Privacy and Electronic Communications (EC Directive) Regulations 2003, and any other legislation which implements any other current or future legal act of the European Union or the United Kingdom concerning the protection and processing of personal data (including any national implementing or successor legislation), and including any amendment or re-enactment of the foregoing. The terms “controller”, “processor”, “data subject”, “personal data” and “processing” in this GDPR Privacy Notice shall be interpreted in accordance with the European Data Protection Legislation.
For the purposes of European Data Protection Legislation and this GDPR Privacy Notice, Declaration will be a controller of any personal data collected by us. If this GDPR Privacy Notice applies, such visitors (as data subjects) have certain rights with respect to such personal data, as outlined below. If you have any questions regarding our use of your personal data, or this GDPR Privacy Notice, please contact us at 1.833.463.0211.
THE PERSONAL DATA DO WE COLLECT ABOUT YOU
HOW WE OBTAIN YOUR PERSONAL INFORMATION
We will collect your personal data either through you directly providing such data to us in your electronic communications with us via the Website, or through our
use of various technologies, including cookies, to monitor your use of the Website.
WHY WE USE YOUR PERSONAL INFORMATION
We will process your personal data for the following purposes in reliance on the following legal bases under the European Data Protection Legislation:
|To provide you with the services or products you have requested.||Contractual necessity|
|To keep a record of your relationship with us.||Legitimate interest|
|To verify your identity.||Legal requirement|
|To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to.||Legitimate interest|
|Fraud and abuse prevention.||Legitimate interest|
|Litigation management and conducting internal audits and investigations.||Legitimate interest|
|To administer and protect our business and Website.||Legitimate interest|
|To make suggestions and recommendations to you about goods or services that may be of interest to you.||Legitimate interest|
No automated decision-making, including profiling, is used when processing your personal information.
Failure to provide certain personal data may mean that we cannot provide our services or products to you and/or that you may no longer be able to use the Website fully or at all. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We may send you direct marketing communications to keep you informed of our products and services in which you might be interested either where we have obtained your prior consent or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in or opt-out of receiving any such direct marketing communications by contacting us at 1.833.463.0211.
SHARING AND TRANSFER OF PERSONAL DATA
Your personal data will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this GDPR Privacy Notice, including professional advisors, CEOs and CEOs-in-Training, recruitment firms, consultants, placement agents and data hosting providers. We seek to ensure that anyone who provides a service to, or for us, involving the processing of your personal data enters into an agreement with us and meets our standards for data security. To the extent that we transfer your personal data to countries outside of the UK or EEA, such transfers will only be made in accordance with the European Data Protection Legislation. For further information about the safeguards/derogations used, please contact us at 1.833.463.0211.
We reserve the right to disclose your personal data as required by applicable law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal data to the new owner of the relevant business and their advisors on the basis of our legitimate interest.
SECURITY AND RETENTION OF PERSONAL DATA
We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the personal data we have about you is protected to the extent possible from unauthorised access and improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through the Website; any transmission of information or data by you to or through the Website is at your sole risk.
We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this GDPR Privacy Notice, unless a longer retention period is required by applicable law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact us at 1.833.463.0211.
You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what personal data we store and process about you. To exercise these rights and controls, please contact us at 1.833.463.0211. Your rights in respect of the personal data processed by us under this GDPR Privacy Notice are:
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
NOTIFICATION OF CHANGES
We reserve the right to amend this GDPR Privacy Notice from time to time by updating this GDPR Privacy Notice. If we decide to change our GDPR Privacy Notice, we will post those changes so our users are always aware of what personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users. We will use personal data collected as described in this GDPR Privacy Notice only in accordance with this GDPR Privacy Notice.
If you have any questions or concerns about this GDPR Privacy Notice, please contact us at 1.833.463.0211.
Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.