CHAUCER CREEK CAPITAL PRIVACY POLICY

Last modified: June 27, 2022

1. Introduction

Chaucer Creek Capital LLC (the “Company”) respects your privacy and is committed to maintaining robust privacy protections for our users through our compliance with this Privacy Policy.  Our Privacy Policy is designed to (i) help you understand the types of information we may collect from you or that you may provide to us through our Sites (as defined below) and Services (as defined below) and how we collect, use, maintain, disclose and safeguard that information, and (ii) to assist you in making informed decisions when using our Services.

For purposes of this Privacy Policy, “Sites” refers to any web properties owned and/or controlled by us including, without limitation, our main corporate website at www.ChaucerCreek.com (“Site”), our Facebook, Twitter, LinkedIn, and YouTube pages, and other social media pages and sites. 

This policy applies to information we collect on this Site; in email, text, and other electronic messages between you and this Site; and through mobile and desktop applications you download from this Site or another third-party application store, which provides dedicated non-browser-based interaction between you and this Site. 

“Services” refers to the Company’s services accessed through the Sites, in which users can download documents and reports, subscribe to receive newsletters, communications or publications, or contact us to learn more about our services.

The terms “we,” “us,” and “our” refer to the Company.

“You” refers to you, as a user of our Sites or Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information (as defined below) and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Sites or Services. By accessing or using any of our Sites or Services, you accept and agree to this Privacy Policy and our Terms and Conditions (found here: www.ChaucerCreek.com/terms-conditions) and you consent to our collection, use, storage, and disclosure of your Personal Information as described in this Privacy Policy.  If you do not agree with our policies and practices, your choice is not to use our Site.  This policy may change from time to time. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. Information We Collect about You and How We Collect It

We collect information from and about persons that access or use our Site or Services. Information may be collected (i) directly from you when you provide it to us; (ii) automatically when you use the Site or Services, such information being collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies; or (iii) by third parties.  When you access or use our Sites or Services, we may ask you to provide, and we may collect, “Personal Information” and “Non-Personal Information.”  “Personal Information” includes your name, postal address, email address, telephone number, job title or position, company or organization name, business address and IP address, or any other information the Sites or Services collect that is defined as personal information under an applicable law, as well as any other identifier by which you may be contacted online or offline. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks.

Information Collected Through Automatic Data Collection Technologies

As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including (i) traffic data, location data, logs and other communication data and the resources that you access and use on our Sites, (ii) information about your computer or mobile device and internet connection, including server log data, IP address, operating system information and browser type, and (iii) if you have provided permission through your device to allow us to collect location information, we may obtain your physical location information, from technologies such as GPS, Wi-Fi, or cell tower signals (“Location Information”). You may withdraw your permission for us to acquire your Location Information, but we do not control this process.  We use this information to understand usage patterns on our Sites, such as to determine the parts of our Sites visitors find most valuable.  The technologies we use for automatic information collection may include:

• Cookies. A cookie is a small file transferred by a web server and stored on the hard drive of your computer or mobile device. Sending a cookie to a user’s browser enables us to collect Non-Personal Information about that user and keep a record of the user’s preferences when utilizing our Sites and Services, both on an individual and aggregate basis. Cookies do not identify you personally and you remain anonymous unless you have otherwise provided us with your Personal Information. You may refuse to accept cookies by activating the appropriate setting on your browser.  However, if you select this setting, you may be unable to access certain parts of our Sites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Sites.
• Web Beacons.  Pages of our Sites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
• IP Addresses.  An IP address is a computer’s numeric address, by which it can be located within a network. We may record your IP address when you visit our Sites or use our Services. We may use your IP address to help diagnose problems with its servers, or to administer the Sites. We may also use your IP address to identify you when we believe it necessary to enforce compliance with our Privacy Policy, our Terms and Conditions, and to protect our Sites, Services, employees, systems, information, business providers, customers, and users.

When you use our Sites or Services, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include (i) analytics companies, who evaluate usage of our Sites and Services, (ii) your mobile device manufacturer, or (iii) your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use our Sites and Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, applications, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.  We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

1. How We Use and Share Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

• Provide you with our Sites and Services and its content, and any other information that you request from us.
• Provide you with information or services that you request from us.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you about changes to our Sites or Services.
• Allow you to participate in interactive features on our Site.
• Respond to your comments, questions, and requests, and provide customer service.
• Provide news and information we think will be of interest to you.
• Detect and protect the Company against error, negligence, breach of contract, fraud, theft, and other illegal activity, and to audit compliance with our policies and contractual obligations.
• Monitor compliance with our Terms and Conditions.

Non-Personal Information

In general, we use Non-Personal Information to help us improve our Sites and Services and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Sites. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.

Personal Information

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We do share Personal Information with our contractors, service providers, vendors and other third parties who are performing services for and support the Company, such as the servers for our email communications that are provided access to user’s email address for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy.

We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms and Conditions, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.

In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. 

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to info@chaucercreek.com.
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by at any other time by sending us an email stating your request to info@chaucercreek.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request to info@chaucercreek.com.

IV.        How We Protect Your Personal Information

We implement security measures designed to protect your information from unauthorized access, use, alteration, and disclosure. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software. 

Any transmission of Personal Information is at your own risk. By accessing or using our Sites or Services, you acknowledge that you understand and agree to assume these risks.

V.        Your Rights Regarding the Use of Your Personal Information

You have the right at any time to prevent us from contacting you for marketing purposes.  When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. You can also indicate that you do not wish to receive marketing communications from us by notifying us at info@chaucercreek.com. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out by notifying us at info@chaucercreek.com, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.

VI.          Links to Other Websites

As part of the Services, we may provide links to other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Sites and Services. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link on our Sites or via our Services. To the extent that you access or use the Services through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

VII. Children’s Privacy

We understand the importance of protecting children’s privacy. Our Sites and Services are not designed for, or intentionally targeted at, children and any persons under the age of eighteen (18). It is not our policy to intentionally collect or store information about children and we do not knowingly collect personal information from children. If you believe we have collected such information, please contact us at info@chaucercreek.com.

VIII.     State Privacy Laws

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, visit https://oag.ca.gov/privacy/ccpa.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information;
• Access and delete certain personal information;
• Data portability; and
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose; and
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please contact us at info@chaucercreek.com. To appeal a decision regarding a consumer rights request please contact us at info@chaucercreek.com.

IX. Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.  You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this privacy page to check for any changes.

X.         Contact Us

If you have any questions regarding this Privacy Policy or the practices of our Sites, please contact us by sending an email to info@chaucercreek.com.