Last Updated January 28, 2023
“Personal Information” is data that relates to you and can–either on its own or in combination with other information–identify you as an individual. Personal Information does not include data that has been aggregated or made anonymous such that you can no longer be identified using means reasonably available to us.
We collect the following types of Personal Information:
- Identifying or Contact Information that you choose to provide (Telegram handle, Twitter handle, or identifying information in emails that you send us)
- Device/IP Data (e.g., IP address, name of the device, operating system, and browser, depending on the device you use and its settings)
- Usage Analytics (e.g., interactions with our web properties and emails that you voluntarily signed up to receive, including number of people that access the Materials, peak hours of access, which information visitors access, which browsers visitors use to access the Materials, and navigation pattern)
- Geolocation Data (e.g., location based on IP addresses)
We may use Personal Information for the following purposes:
How We Share and Disclose Your Personal Information
- To provide the Materials;
- To send you any information that you request about the Materials, or otherwise respond to your inquiries, comments, feedback, or questions;
- To maintain and improve the Materials;
- To investigate any complaints or feedback received from you or others about the Materials;
- To protect against or deter fraud, criminal activity, or misuse of the Materials, and to ensure the security of our IT systems, architecture, and networks;
- To comply with legal and regulatory obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties; and
- For any other business purpose set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
- We may create aggregated or anonymized data from the Personal Information that we collect. We may use such aggregated data and share it with third parties for lawful business purposes, including to analyze the effectiveness of the Materials, or to improve and add features to the Materials and promote our business, provided that we will not share such data in a manner that could identify you.
In certain circumstances, we may share the types of Personal Information described above without further notice to you, unless required by law, with the following categories of third parties:
|Types of Personal Information Shared||Purposes for Sharing|
|Service Providers||Contact Information|
|Help provide the Materials and operate our business, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services|
|Business Transfers||Contact Information|
|In the diligence process with counterparties and others assisting with a contemplated merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, or transferred to a successor affiliate as part of such transactions along with other assets|
|Legal Requirements||Contact Information|
Data Device/IP Data
|If required to do so by law or in a good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements; (ii) protect and defend our rights or property; (iii) prevent fraud; (iv) act in urgent circumstances to protect the personal safety of users of the Materials, or the public, or (v) protect against legal liability.|
We do not knowingly collect Personal Information from minors, nor do we target the Materials to minors.Links to Other Websites
The Materials may contain links to other websites not operated or controlled by Electric Capital. We do not imply that we have reviewed or that we endorse these websites, and are not responsible for the privacy practices of any such other website (whether accessed through an advertisement, service or content link). Please review the privacy practices of such websites before you share any Personal Information with them.Users Outside of the United States
By using the Materials, you understand and acknowledge that your Personal Information will be transferred to, processed in and accessed by our facilities and servers in the United States. Individuals in certain jurisdictions may have certain rights in relation to their Personal Information. These rights vary, but they may include the right to:
- Request access to and rectification or deletion of their Personal Information;
- Restrict or object to the processing of their Personal Information; and
- Obtain a copy of their Personal Information in a portable format.
Individuals may also have the right to submit a complaint about Electric Capital's processing of their Personal Information with a data protection authority.
We may need you to take certain steps to verify your identity to exercise these rights. These rights may be limited in certain circumstances or subject by law to certain exceptions (e.g., where they would infringe on the rights of a third party, or where Electric Capital's legal obligations prevent us from fulfilling your request). We will inform you of relevant exemptions we rely upon when responding to any request you make.Security
You use the Materials at your own risk. We have implemented measures to help protect Personal Information from loss, misuse or unauthorized access or disclosure. Although we strive to protect your Personal Information, we cannot guarantee its security.Data Retention
We will not keep your Personal Information for longer than is necessary for the purpose for which it is used. In general, this means that we will generally not keep your Personal Information for longer than 5 years, subject to any applicable laws and/or regulatory requirements.
We may change this policy from time to time. If we make any changes, we will update the “Last Updated” date above.