The Capstreet Group Privacy Notice
Last Updated: September 6, 2024
This Privacy Notice explains how Capstreet Group, LLC (“Capstreet Group”, “we”, “us”, “our”) collects Personal Data about individuals who use our website at www.Capstreet.com (“Website”) or interact with us via email, how we use your Personal Data and how you can assert your rights in accordance with applicable data protection laws. This Privacy Notice does not address our collection, use and disclosure of Personal Data from investors in funds that we sponsor or manage; we address such practices in separate notices to investors.
1. Personal Data we collect
“Personal Data” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The Personal Data we collect and have collected in the preceding 12 months in connection with the Website includes information you provide to us and automatically collected information, as respectively described below in this Section 1.
Personal Data you provide to us
We collect Personal Data (including sensitive Personal Data, as such term is defined under applicable laws) that you voluntarily provide to us, such as through the “contact us” form on our Website, or other communications. Such Personal Data may include:
- Basic contact details, such as name, address, phone number, and email address.
- Information listed in the California Customer Records statute, such as commercial information, and professional and employment related information.
- Any other Personal Data you choose to include with communications with us, for example when sending a message through the Website.
Personal Data we collect automatically
When you visit our Website, we and third parties on our behalf may automatically collect data about you through the use of cookies, pixels, web server logs and other electronic tools and technologies (collectively referred to as “Cookies”). Such data may include:
- Device and browser data, such as device type, operating system, unique device identifier, Internet Protocol (IP) address, and the Internet browser you use.
- Location data, such as approximate location based on IP address.
- Other data regarding your interaction with the Website, such as browser type, log data, date and time stamps, the websites accessed before and after you visit our website, and clickstream data.
To the extent we collect any of your sensitive Personal Data under this Privacy Notice, we only use and disclose such sensitive Personal Data for the purposes specified in the California Consumer Privacy Act or otherwise with your consent.
2. How do we use your Personal Data?
We may use Personal Data: (i) for communication and marketing purposes, such as sending you information about the Capstreet Group and/or our investment funds, and maintaining our list of contacts, (ii) for other business purposes, such as in connection with managing our business and funds’ investments, researching investment opportunities, communicating with service providers and vendors, and analyzing, maintaining, and improving the Website, and (iii) with your consent.
In addition, we will use some or all of your Personal Data to comply with any applicable legal obligations, to enforce any applicable terms and conditions and/ or terms of service, and to protect or defend the Website, our rights, the rights of our users, or others.
3. With whom do we share your Personal Data?
We may disclose Personal Data to the following parties and as otherwise described in this Privacy Notice, in other applicable notices, or at the time of collection.
- Affiliates. Our affiliates or others within our corporate group.
- Service Providers. Vendors or other service providers who help us provide the Website, including for system administration, cloud storage, security, customer relationship management, marketing communications, web analytics, payment networks, and payment processing.
- Professional Advisors, such as auditors, law firms, or accounting firms.
- Transaction Parties. Third parties in connection with or anticipation of an asset sale, merger, or other business transaction, including in the context of a bankruptcy.
- User Directed Parties. Third parties to whom you request or direct us to disclose Personal Data.
We do not share mobile phone information with affiliates or third parties for marketing or promotional purposes (other than service providers who help us with such marketing), and we do not share text messaging originator opt-in data or consent with any third parties unless required by law. The Capstreet Group does not “sell” or “share” (as those terms are defined under the California Consumer Privacy Act) Personal Data, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we sell or share Personal Data of individuals under 16 years of age. However, in the preceding 12 months we have disclosed Personal Data to Affiliates, Service Providers, Professional Advisors, and as directed by you.
4. Cookies and other tracking technologies
Cookies are small pieces of data placed on your computer, phone, or similar device when you use that device to visit or use our Website. Most browsers accept Cookies automatically, but you may be able to control the way in which your devices permit the use of Cookies. If you so choose, you may block or delete certain Cookies from your browser; however, blocking or deleting Cookies may cause some of the Website, including certain features and general functionality, to work incorrectly.
Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about Cookies, visit https://www.allaboutcookies.org/.
5. How long do we retain your Personal Data?
We retain your Personal Data for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your Personal Data, we consider various criteria, including whether we need the Personal Data in connection with the Website, or to resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property, and investments.
We may store aggregated, de-identified and/or anonymized data for as long as needed for our lawful business purposes.
6. Rights with respect to Personal Data
Your rights described in this Privacy Notice are applicable only if you reside in a jurisdiction where the provision of such rights is required by the data protection and privacy laws of the applicable governing regulatory authority. Depending on where you reside you may have the below, similar or other rights; but such rights may be limited and subject to further legal requirements.
- Know/Access. You may have the right to request access to Personal Data that we hold about you, or to be informed about what Personal Data is being processed, how we use it, who we share it with, and the rationale for the processing;
- Correct. You may have the right to request that we rectify (i.e., correct) Personal Data if it is inaccurate or out of date;
- Delete. You may have the right to request that we delete your Personal Data under certain circumstances;
- Opt Out of Marketing. You can object to marketing at any time by opting-out using the unsubscribe / opt-out function displayed in our communications to you. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you administrative messages that are required to provide the Website; and
- Portability. You may have the right to request a transfer of your Personal Data to a third party in certain circumstances.
You may submit a request to exercise any of these rights by contacting us using the methods described in Section 11.
We will not discriminate against you for exercising any of these rights. Further information may be needed to verify your identity before exercising these rights, such as your email address or government-issued ID. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
7. What security do we have in place over your Personal Data?
The Capstreet Group has implemented appropriate procedural and technical security measures intended to help protect your Personal Data. However, risk is inherent in all internet and information technologies and we cannot guarantee the security of your Personal Data. Any information you send to us electronically, while using the Website, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.
8. Changes to this Privacy Notice
We may amend this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by updating the “Last Updated” date at the top of this Privacy Notice, or by other means consistent with applicable law. Any modifications to this Privacy Notice will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Website.
9. Children
Our Website is not intended for children. Children are not permitted to use the Website, and we do not seek or knowingly collect any Personal Data about children. If we become aware that we have unknowingly collected Personal Data about a child, including any child under 13 years of age, we will make commercially reasonable efforts to delete such data. If you are the parent or guardian of a child under 13 years of age who has provided us with their Personal Data, you may contact us through the methods set out in Section 11 below to request that it be deleted.
10. Other sites and services
The Website may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and online services you use.
11. How to contact us
If you have any questions about our privacy practices or this Privacy Notice, please email us at info@capstreet.com or contact us at +1 (877) 236-2496.
Toll-free number 1-877-236-2496
E-mail info@capstreet.com