Effective Date: September 20, 2018
1. NOTICE CONCERNING CHILDREN
This Site is a general audience website directed at individuals 13 years of age and older pursuant to the definitions detailed in the Children’s Online Privacy Protection Act and accompanying COPPA Rule. If you are aware of a child under 13 registering for the Site, please contact us immediately.
2. INFORMATION COLLECTION PRACTICES
2.1. WHAT PERSONALLY IDENTIFIABLE INFORMATION DO WE COLLECT ABOUT YOU?
A. CATEGORIES OF PERSONALLY IDENTIFIABLE INFORMATION. The Site offers a variety of different interaction levels for visitors. Should you visit the Site, or purchase a paid subscription, we will collect some or all of the following personal information from you depending upon the particular action you take.
(i.) Paid Subscription. If you purchase a subscription from us, we will collect the following personal information from you:
• First Name
• Last Name
• Company Name (optional)
• Physical Mailing Address
• Email Address
• Phone Number
• Order Notes
(ii.) Contact Us. You may contact us at any time. In doing so, we will collect the following personal information from you:
• Your Name
• Email Address
• Any information you supply with your narrative message
B. MODIFICATION OR REMOVAL PROCESS. You can modify and remove certain personal information by going to your “Account” profile when logged in to the Site. Alternatively, you may contact us using the “Contact Us” function on the Site for assistance.
D. “DO NOT TRACK” SIGNALS. We do not honor “do not track” signals from browsers per se, however, certain Google third party cookies used through the Site can be blocked by following the links in Section E below. You may also use programs such as Privacy Badger to block tracking.
E. THIRD PARTY TRACKING – GOOGLE REMARKETING AND ANALYTICS. We use various Google services, including Google Universal Analytics, to help us evaluate the performance of the Site as well as implement marketing campaigns including remarketing. By visiting the Site, you consent to first and third party cookies being placed on your computer by us and Google to track you. This information will be used to tailor marketing materials to you and for remarketing purposes. To opt-out of these functions, you can visit the following pages:
F. THIRD PARTY TRACKING – SOCIAL MEDIA. We provide social media “buttons” on the Site so you may post particular pages to your accounts on social media sites as well as follow Sigma Point Capital on various social media sites. Anything you post via these buttons is viewable to the public unless you use appropriate privacy restrictions available on the particular social sites on which you share the information. Further, the social media sites can track your actions and create a data profile for you. You should perform due diligence in investigating the privacy policies for each of these sites as follows.
2.2. WHAT AUTOMATIC INFORMATION DO WE COLLECT ABOUT YOU?
A. AUTOMATIC COLLECTION. We employ cookies, flash cookies, pixel tracking and web beacons to automatically collect data regarding how visitors use the Site including, but not limited to, the following:
• How you find and move about our Site, including landing, referral and exit pages.
• Your clicking and browsing behavior.
• The date, time and length of your visit to the Site.
3. USE AND SHARING OF INFORMATION
3.1. WHAT DO WE DO WITH COLLECTED INFORMATION?
A. PERSONAL INFORMATION. We disclose your personal information to vendors that assist us in running this Site such as payment processors and email communication providers. We do not share your personal information with third party advertisers.
B. SALE OF SITE/COMPANY. Should we decide to sell all or part of the Site or our business at some point in the future, your personal information will be included as an asset in the transfer.
C. AGGREGATE DATA. We use data collected from cookies, flash cookies, pixel tracking and web beacons in aggregate in the following manner.
(i.) Site Improvements. We use aggregate data to analyze our Site traffic.
(ii.) Sponsors and Advertisers. We may accept sponsorships and advertisements on the Site from time to time. Should this occur, said sponsors and advertisers will be given access to the aggregate data for the purpose of evaluating the marketing opportunity and performance of campaigns. Your personally identifiable information will not be revealed as part of this process.
D. DISCLOSURE OF PERSONAL INFORMATION. We may disclose personal information about you if required to do so by law or in the good-faith belief that such action is necessary to:
(1) Conform to the edicts of the law or comply with legal process served upon the Site or us.
(2) Protect or defend our rights or the users of the Site.
(3) Act under exigent circumstances to protect the safety of the public or users of the Site.
(4) To investigate any allegation of improper conduct.
We may also disclose your personal information to third parties in the event of the sale of the Site or our business as detailed in section 3.1(B).
E. ACCESS TO INFORMATION. You may access your information in the profile section of your account once you subscribe or contact us to ask for changes to your personal information.
4.1 SECURITY MEASURES. The Site has reasonable security measures in place to prevent the loss, misuse and alteration of the information we obtain from you, but we make no warranty or guarantee about our ability to prevent sophisticated attacks and hacks.
4.2. LOST OR STOLEN INFORMATION. You must promptly notify us if the username or password for your account is lost, stolen, or used without permission. In such an event, we will remove that username or password from your account and update our records accordingly.
5. WEBSITE AREAS BEYOND OUR CONTROL
5.1. THIRD PARTY WEBSITES. From time to time, the Site may contain links to other websites. If you choose to visit those websites, it is important to understand our privacy practices do not extend to those websites. It is your responsibility to review the privacy policies of those websites to ascertain their professional practices.
6. CONTACT INFORMATION AND POLICY UPDATES
6.1. CONTACT US. If you have any questions about this Policy, please contact us using the “Contact Us” function on the Site.