Last Modified: 26 October 2020

This Privacy Policy sets forth the privacy practices of Liberty Hall Capital Partners, L.P. (“Liberty Hall,” “we,” “our,” or “us”) with respect to Personal Information (defined below) that Liberty Hall may collect through this web site (the “Site”), how it is protected and used, and the circumstances under which it may be shared and disclosed. This Privacy Policy, along with our User Agreement, which is incorporated by reference in its entirety, constitute a legally binding agreement between you and Liberty Hall that conditions your use of the Site, where and as permitted by applicable law.

1. Personal Information We Collect
In order to better provide you with services through the Site, we may collect, process, and store Personal Information about you.
For the purposes of this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or reasonably could be linked, directly or indirectly, with a particular consumer, device, or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.

On our Site, the Personal Information collected will depend on which of our services you utilize. Some of our services may require you to provide us with Personal Information. In these situations, the Personal Information requested will include, and has included in the past 12 months, email address, username, and password.

Use of cookies
Like many other websites, Liberty Hall and its service providers use and have used within the past 12 months text files or images (e.g., “cookies” or other cached files) sent to your web browser to collect Personal Information about your use of the Site in order to facilitate and customize your use of the Site. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customize your experience on this website and to monitor use of this website. You may set your web browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org. For detailed information on the cookies on our Site and the purposes for which they are used, please consult our Cookie Policy.

2. Use of Personal Information
We use your Personal Information in the following ways:

• to ensure that content from our Site is presented in the most effective manner for you and your computer and to notify you about any changes to our Site or services;
• to provide our services;
• to process your requests and inquiries;
• to confirm your identity;
• to debug, identify, and repair errors that impair existing intended functionality of the Site;
• to comply with legal obligations and respond to court orders;
• to prevent or investigate fraud or other unlawful activity, and detect security incidents; and
• to protect the security and integrity of the Site.

Liberty Hall may combine your Personal Information and other information collected about your use of the Site, and also supplement with information from external sources for the purposes described in this Privacy Policy. For example, information that Liberty Hall collects about you may be combined by Liberty Hall with other information available to Liberty Hall through third parties for research and measurement purposes. This information from other sources may include age, gender, demographic, geographic, or other information. We may report aggregate information, which is not able to be identified back to an individual user of the Site, to our current or prospective business partners.

In addition, Liberty Hall may use Personal Information about you for other purposes that are disclosed to you at the time we collect the information and/or with your consent.

3. How We Share Personal Information

We provide some of our services through contractual arrangements with affiliates, services providers, partners, and other third parties. We and our affiliates, services providers, partners, and other third parties may use your Personal Information to operate our Site and to deliver our services. Third parties with whom we share your Personal Information are bound to comply with similar and equally stringent undertakings of privacy and confidentiality.

Occasionally, we may be required to share your Personal Information with third parties for legitimate business purposes, or to comply with legal obligations. For example, we may share Personal Information when we believe in good faith that an applicable law requires it; at the request of law enforcement, judicial authorities (e.g. upon receipt of a court order or subpoena), or appropriate governmental authorities; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety or security of third parties, visitors to our Site, our businesses, or the public.

4. We Do Not Sell Personal Information
Liberty Hall does not sell, and has sold within the past 12 months, Personal Information to non-affiliated third parties.

5. How Personal Information is Secured and Retained

Liberty Hall seeks to carefully store and safeguard your private information and, to that end, restricts access to your Personal Information to those employees and to certain other persons, including service providers such as a third party that hosts this Site, who need to know such information. We will retain your Personal Information for no longer than is necessary for purposes for which it was collected. The precise period will depend on the reason why it was collected and requirements of applicable data protection, legal, and regulatory requirements.

We implement and maintain reasonable security appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Though we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be completely secure.

6. Data Transfer Abroad
The information submitted to us may be transferred and processed for the purposes described above in locations outside the country in which you are viewing this Site, potentially including countries which may not require an adequate level of protection for your Personal Information compared with that provided in your country. By accepting this Privacy Policy, you consent to the transfers as described in this section, where and as permitted by applicable law.

Any transfers of Personal Information of an individual residing in the European Economic Area (“EEA”) outside of the EEA will only be made where appropriate safeguards have been put in place.

7. Links to Other Websites

Our Site may, from time to time, contain links to and from websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to the websites. We do not endorse or make any representations about third-party websites. Any Personal Information you choose to give to unrelated third parties is not covered by this Privacy Policy.

8. Children

We are committed to protecting the privacy of children. Our Site is not designed or intended to attract children under the age of 18. Our Site does not collect Personal Information from any person we actually know is under the age of 18. If we become aware that we have collected Personal Information from children without verification of parental consent, we will take steps to remove that information from our servers. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us.

9. Notice to Users Within the European Economic Area
When you use the Site, we collect, store, use and otherwise process your Personal Information as described in this Privacy Policy.

Bases for Processing

Liberty Hall relies on legal bases to process your Personal Information, including where: (i) you have consented to the processing, which you can revoke at any time; (ii) necessary for our legitimate interests of our service providers, in keeping our Site safe and secure, and providing and improving the Site; (iii) necessary to perform our contractual obligations in the Liberty Hall User Agreement; (iv) you have expressly made the information public; (v) necessary to comply with a legal obligation such as a law, regulation, search warrant, subpoena, or court order, or to exercise or defend legal claims; and (vi) necessary to protect your vital interests, or those of others.

EEA User Rights

If you are in the EEA, you can: (i) access Personal Information we have about you (we will try to provide information within 30 days of your request); (ii) have your Personal Information corrected or deleted; (iii) in certain circumstances, you can object to our processing of your Personal Information and we will discontinue such processing unless we have legitimate grounds to continue; (iv) withdraw consent previously provided (however, a withdrawal does not affect the lawfulness of processing of your personal data that occurred prior to the date of withdrawal); or (v) if you believe that we have not complied with applicable data protection laws, you may lodge a complaint with your local supervisory authority. If you wish to exercise any of those rights that are available to you with respect to such Personal Information, you may contact us as described in the “Contact” section below. We will respond to your request within the time limits set by applicable law.

10. Notice to California Users

The California Consumer Privacy Act (“CCPA”) provides California residents with certain rights regarding their Personal Information.

California User Rights

Right to Know and Access Personal Information Collected, Disclosed, or Sold

California residents may have the right to request that a business that collects Personal Information disclose the following: (i) categories of Personal Information we collected about you within the past 12 months, as well as the related purposes for collection and the sources of the Personal Information; (ii) specific pieces of Personal Information we collected about you within the past 12 months; and (iii) categories of Personal Information that a business disclosed about you for a business purpose within the past 12 months.

You may only make a verifiable consumer request for access or data portability from us twice within a 12 month period, free of charge.

Right to Request Deletion of Personal Information

California residents may have the right to request that a business that collects Personal Information about you (and its service provider(s)) delete that Personal Information, unless an exception in the CCPA applies. If we cannot grant your deletion request, we will specify the basis for denial.

Right to Opt-Out of Sale of Personal Information

Liberty Hall does not sell, and has not sold within the past 12 months, Personal Information to non-affiliated third parties.

Right to Non-Discrimination

Liberty Hall will not discriminate against you for exercising any of your rights under the CCPA.

How to Exercise Your Rights

If you have the rights described above, you may exercise those rights by submitting a verifiable request to us by contacting us using the information outlined below. Only you or an authorized agent (as described below) may make a verifiable consumer request related to your Personal Information.

How to Authorize an Agent

An authorized agent may submit your verified consumer request on your behalf, but only if the authorized agent also submits a power of attorney or your written permission and a copy of the agent’s registration with the California Secretary of State.

How We Verify Your Request

To respond to your request under the CCPA we must verify your identity or the authority of your authorized agent to make the request. Making a verifiable consumer request does not require you to create an account with us.

To allow us to verify your request, please include the following information: name, address, phone number and email address. We will verify your consumer request by comparing the information you provide to information already in our possession, and taking additional steps to minimize the risk of fraud.

11. Changes to This Privacy Policy

This Privacy Policy applies to individuals only and may be changed at any time. If we make any material changes to this Privacy Policy, we will notify you by posting a prominent announcement on the Site and will post the updated Privacy Policy here. We encourage you to check this page from time to time to take notice of any changes we make. If you do not consent to the collection, use, and disclosure of your Personal Information as set forth in this Privacy Policy, please refrain from visiting this Site.

12. Contact Information
If you have any questions or comments about Liberty Hall’s Privacy Policy, please feel free to contact Liberty Hall at info@libertyhallcapital.com or +1 (646) 291-2601.