Iron Path Capital, L.P.

PRIVACY POLICY

At Iron Path your privacy is important to us. Our Privacy Policy describes the information we collect, how we collect information, and the reasons we collect information. This Privacy Policy also describes the choices you have with the information we collect, including how you can manage, update, or request to delete information.

Please take a moment to review this Privacy Policy. You may scroll through this Privacy Policy or use the headings below. It is important that you understand this Privacy Policy. By using our Website, you are agreeing to the terms of this Privacy Policy. If you have any questions or concerns about this Privacy Policy, you may Contact Us at any time.

Table of Contents

I. Key Terms & Definitions and Our Privacy Policy

II. Personal Information

III. Who may use the Website and/or the Services?

IV. Children’s Privacy

V. Does Iron Path respond to Do Not Track signals?

VI. Data Security

VII. California’s Shine the Light Law.

VIII. Changes to our Privacy Policy

IX. Contact Us

I. Key Terms & Definitions and Our Privacy Policy

It is helpful to start by explaining some of our key terms and definitions used in this Privacy Policy.

Key TermDefinition
“Personal Information”Any information relating to an identified or identifiable individual and any information listed here.
“Privacy Policy”This privacy policy.
our “Services”Any services provided through our Website.
our “Terms of Use”Our terms of use located here[FL1] .
our “Website(s)”Our websites, including: https://www.ironpathcapital.com  
“Iron Path,” “we,” “us,” or “our”Iron Path Capital, L.P.

 

When does our Privacy Policy apply?

This Privacy Policy describes the types of information we may collect from you when:

  • You visit or use our Website;
  • We communicate in email, text message and other electronic messages between you and us; and
  • We communicate in person, such as on the phone or through video interaction. [FL2] 

When does our Privacy Policy not apply?

This Privacy Policy does not apply to information collected by any other website operated either by us or by a third party, unless the website is listed above or links to this Privacy Policy. It also does not apply to any website that we may provide a link to or that is accessible from our Website.

Under certain circumstances we may be considered a “financial institution” governed under the Gramm-Leach-Bliley Act (GLBA). In such instances we will deliver a GLBA Privacy Notice to you. [You can view a copy of our GLBA Privacy Notice.][FL3]   In the event of a conflict or discrepancy between this Privacy Policy and our GLBA Privacy Notice, the terms and provisions of the GLBA Privacy Notice will apply.

 

Our Privacy Policy and Terms of Use.

This Privacy Policy is incorporated into our Terms of Use, which also apply when you use our Website.

II.  Personal Information

What is Personal Information?

Personal information is information from and about you that may be able to personally identify you. We treat any information that may identify you as personal information. For example, your name and email address are personal information. See Categories of Personal Information below for additional details.

What types of Personal Information do we collect?

We may collect and use the following personal information (hereinafter, collectively referred to as “Personal Information”):

Categories of Personal InformationSpecific Types of Personal Information Collected[FL4] 
Personal Identifiersa real or legal name, birth date, or email address.
Information that identifies, relates to, describes, or is capable of being associated with a particular individualusername or online identifier, or telephone number.
Internet or other electronic network activity informationIP address, device mode, device ID, OS version, device language, operating system, browser type, browsing history, search history, page view, click activity and information regarding a consumer’s interaction with a website, application, advertisement or email.
Geolocation dataPhysical location or movements, local time, and local time zone.

How do we collect your Personal Information?

We collect most of this Personal Information directly from you. For example, when we speak to you by phone, text message, and email. Additionally, we will collect information from you when you visit our Website.

We may also collect Personal Information in the following ways:

  • From your mobile device, smart watch or other mobile or wearable connected device.
  • From third-party apps you choose to connect your mobile device to.
  • When You Contact Us. When you contact Iron Path directly we will receive the contents of your message or any attachments you may send to us, as well as any additional information you choose to provide.

Information Collected Automatically.  We will also collect Internet or Other Electronic Network Activity Information automatically as you navigate through our Website. We use the following technologies to automatically collect data:

  • Cookies and Other Tracking Technologies. We and our service providers may use pixels, web beacons, session replay tools, and other tracking technologies whenever you use or interact with our Website or Services through your computer or mobile device. A “cookie” is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. Some of the cookies we use are “session” cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the Website and to limit the amount of redundant data that is downloaded during a single session.
  • We also may use “persistent” cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our Website and/or the Services. We and third parties may use session and persistent cookies for analytics and advertising purposes, as described herein. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access or use certain parts of our Website or the Services. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Website. Google Analytics uses cookies, to help our Website analyze how users use our Website. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). For more information, please visit Google and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

How do we use your Personal Information?

We may use your Personal Information for the following purposes:  

  • Fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • Anonymize and aggregate information for analytics and reporting.
  • To respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations.
  • Authenticate use, detect fraudulent use, and otherwise maintain the security of our Website and the safety of others.
  • Any other purpose with your consent.

How do we share your Personal Information?

We may share Personal Information with third parties in certain circumstances or for certain purposes, including:

  • Our business purposes. We may share your Personal Information with our affiliates, vendors, service providers, and business partners, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security advisors. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
  • With your consent. We may share your Personal Information if you request or direct us to do so.
  • Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
  • Business Transfer. We may share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users are among the assets transferred.
  • To enforce our rights. We may share your Personal Information to enforce any applicable terms and conditions and Terms of Use, and to ensure the safety and security of our Services and our users.
  • De-identified information. We may also disclose de-identified information, so that it cannot be reasonably used to identify any individual, with third parties for marketing, advertising, research, or similar purposes.
  • Third Party Analytics. We use Google Analytics and other data analytics tools to understand and evaluate how visitors interact with our Website and/or the Services. These tools help us improve our Website and/or the Services, performance, and your experience.

Your choices about how we share your Personal Information.

This section of our Privacy Policy provides details and explains how to exercise your choices. We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted advertising. We do not control the collection and use of your information collected by third parties. These third parties may aggregate the information they collect with information from their other customers for their own purposes. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (NAI) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its websites (www.aboutads.info and www.privacyrights.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

Each type of web browser provides ways to restrict and delete cookies. Browser manufacturers provide resources to help you with managing cookies. Please see below for more information.

For other browsers, please consult the documentation that your browser manufacturer provides.

If you do not wish to have your email address used by Iron Path to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email. This opt out does not apply to information provided as a result of your use of our Website and/or the Services. You may have other options with respect to marketing and communication preferences through our Website.

You may also see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests.

How do I request to have Personal Information deleted?

You may request to have any Personal Information we collected deleted at any time by emailing us at scottm@ironpathcapital.com. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

III. Who may use the Services?

Iron Path operates subject to state and federal regulations, and the Website and/or the Services may not be available in your state. You represent that you are not a person barred from enrolling for or receiving the Services under the laws of the United States or other applicable jurisdictions in which you may be located. Access to and use of the Website and/or the Services is limited exclusively to users located in states within the United States where the Website and/or the Services isa available. The Website and/or the Services are not available to users located outside the United States. Accessing the Website and/or obtaining the Services from jurisdictions where content is illegal, or where we do not offer the Website and/or the Services, is prohibited

IV. Children’s Privacy

Our Services are not intended for children under 18 years of age. We do not knowingly collect or sell Personal Information from children under the age of 18. If you are under the age of 18, do not use or provide any information on or to the Website or through any of its features. If we learn we have collected or received Personal Information from a child under the age of 18 without verification of parental consent, we will delete it. If you are the parent or guardian of a child under 18 years of age whom you believe might have provided use with their Personal Information, you may Contact Us to request the Personal Information be deleted.

V.  Do Not Track Signals

Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Website is not currently set up to respond to those signals.

VI. Data Security

We have taken steps and implemented administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use. The Internet is not 100% secure and we cannot guarantee the security of information transmitted through the Internet. Where you have been given or you have chosen a password, it is your responsibility to keep this password confidential.

The sharing and disclosing of information via the internet is not completely secure. We strive to use best practices and industry standard security measures and tools to protect your data. However, we cannot guarantee the security of Personal Information transmitted to, on, or through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Website, in your operating system, or mobile device.

VII. California’s Shine the Light Law.

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website and/or the Services that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g. requests made in 2021 will receive information regarding such activities in 2020). You may request this information once per calendar year. To make such a request, please Contact Us using the information below.

VIII. Changes to our Privacy Policy

We may update our Privacy Policy periodically to reflect changes in our privacy practices, laws, and best practices. We will post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on our Website’s homepage. If we make material changes to our practices with regards to the Personal Information we collect from you, we will notify you by email to the email address specified in your account and/or through a notice on the Website’s home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and reviewing this Privacy Policy to check for any changes.

IX. Contact Us

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact Us” page on the Website.

How to Contact Us:

Iron Path Capital, L.P.

424 Church Street, Suite 2240

Nashville, Tennessee 37219

Telephone: (615) 953-7133

Email: scottm@ironpathcapital.com

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