Privacy and Disclaimer
Last Updated: June 21, 2023
We may change this Policy from time to time and we will notify you by revising the “Last Updated” date at the top of this Policy. If we change this Policy in a way that we believe materially affects how we process your personal information, we will provide you with advance notice such as via email or by posting a notice on our Sites. Unless otherwise required by laws in your residence, your continued access or use of our Services after receiving the notice of changes constitutes your acknowledgment that you accept the updated Policy.
1. Personal Information We Collect
We may collect the following categories of personal information that you voluntarily provide while using our Sites:
- Account Information. When you use our investor portal, we may collect your account information, such as your account’s username and password.
- Transaction Information. When you carry out transactions through our Sites, we may collect transactional information such as financial account number.
- Client Support Information. When you choose to get in touch with us via email or phone, we may collect your first and last name, email address, copies of your correspondence, and additional information you choose to share with us.
- Other Information. We may collect any other information that you voluntarily send to us.
To the extent permitted under applicable law, and to improve the performance of our Sites, we may collect the following types of personal information automatically from you:
- Log Data and Usage Information. When you browse our Sites, we automatically collect log data such as your web request, Internet Protocol (“IP”) address, browser type, domain names, referring and exit pages and URLs, pages viewed and the order of these page views, the date and time you access our servers, and other diagnostic data
2. Cookies and Similar Tracking Technologies
We, and third parties on our behalf may employ various tracking technologies, such as cookies and other similar technologies (collectively, “Tracking Technologies”) to collect personal information automatically as you interact with our Sites, to help us customize your experience and better manage content on our Sites, including to:
- Analyze our web traffic using an analytics package
- Identify whether you already visited our Sites
- Store information about your preferences
- To recognize when you return to our Sites
Cookies are small text files that a website can use to recognize a repeat visitor to the Site. The following types of cookies are used on our Sites:
- Strictly Necessary Cookies. These cookies are essential because they enable you to use our Sites as you reasonably expect. Without these cookies, some Site features cannot function. This category of cookies is essential for our Site to work and so they cannot be disabled.
- Functional Cookies. We use functional cookies to remember your choices so that we may tailor our Sites to provide you with enhanced features and personalized content. While these cookies can be disabled, this may result in less functionality during your use of our Site.
- Analytics Cookies. These cookies allow us to collect passive information about your use of our Sites, for example, count page visits and traffic sources to measure and improve our Sites’ performance.
- Advertising Cookies. These cookies may be set through our website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to your interests.
You have the right to decide whether to accept cookies. If you do not want Blue Wolf to deploy cookies in your browser, you may exercise your preference by modifying your web browser setting to either refuse some or all cookies, or notify you and ask for your permission when a website tries to set a cookie. If you want to learn the correct way to modify your browser settings, please use the “Help,” “Tools,” or “Edit” menu in your browser or review the instructions provided by your local browse. If you choose to disable cookies in your browser, you can still use our Sites, although your ability to use some of the features may be affected.
Our Sites and our third-party technology providers use third-party analytics services (such as Google Analytics) to evaluate your use of the Sites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Sites and Internet usage. For more information on how to opt-out of Google Analytics’ tracking, please click here.
Interest-Based Advertising. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1. If you reside in the European Economic Area, the United Kingdom, and Switzerland (collectively, the “European Countries”), you may opt out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting http://youronlinechoices.eu/.
3. How We Use Your Personal Information
Our primary purpose for collecting personal information is to provide you with a secure and smooth experience on our Sites. We may use your personal information in the following ways:
- To Provide You With Our Sites. We may use your information to complete the transactions you request, to perform our contractual obligations with you, to provide you with requested information or materials, or to ensure that our Services function properly.
- To Maintain Legal and Regulatory Compliance. Our business is subject to certain laws and regulations which may require us to process your personal information. Without processing your personal information for such purposes, we cannot provide our services in accordance with our legal and regulatory requirements.
- To Enforce Compliance with Our Terms, Agreements, and Policies. When you access our Sites, you are bound to our Terms. To ensure you comply with them, we may process your personal information by actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, illicit or illegal activities on our Sites. Subject to the applicable law, we may also process your personal information to investigate, prevent or mitigate violations of our agreements and internal policies, or enforce our agreements with third parties and business partners.
- To Detect and Prevent Fraud and Security Risks. We may process your personal information to help monitor, prevent and detect fraud activities in our Sites, monitor and verify your identity so that unauthorized users do not gain access to your accounts, enhance system security, and combat spam, malware, malicious activities or other security risks that might result in financial loss.
- To Provide Support or Respond to You. We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of our services.
- To Research and Develop of Our Sites. We may process your personal information and derive analytical and statistical data to better understand the way you interact with our Sites to help us maintain, improve and develop our Sites. Please see our Cookies and Other Similar Tracking Technologies section for more information.
- To Personalize Your Experience. We may process your information to personalize your experience. By personalization, we enable you to more easily interact with our Sites. Please see our Cookies and Other Similar Tracking Technologies section for more information.
- To Facilitate Corporate Acquisitions, Mergers, and Transactions. We may process information regarding your account and your use of our Sites as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
- With Your Consent. We may process your information for any other purpose to which you consent.
4. How We Share Your Personal Information
We may share your personal information listed above with third parties and service providers when necessary for business purposes. The categories of third parties with whom we may share your personal information include:
- As Required by Law. We may access, preserve, and disclose information about you if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) comply with requests from auditors, examiners or other regulators; (c) respond to your requests; or (d) protect your, our, our clients’ and investors’, or others’ rights, property or safety.
- Our Affiliates and Subsidiaries. We may share your personal information between and among Blue Wolf subsidiaries and affiliates for management, analysis, client, and investor support.
- Our Service Providers. We may share your personal information with service providers performing necessary business functions for us, such as secure website hosting, information technology maintenance, and analytics.
- Authorized Third Parties. We may disclose your information to third parties that you authorize us to disclose personal information in connection with the services we (or they) provide you.
- During Business Transaction or Other Asset Transfers. We may disclose and transfer information about you to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the advisors, potential transactional partners or other third parties of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets. By engaging with us or using our services, you understand and agree to our assignment or transfer of rights to your personal information. In the event of any such change in ownership or control of your personal information, we will notify you of such changes to the extent required under applicable law.
- With Your Consent. We may disclose your personal information for any purpose with your consent.
5. How We Protect Your Personal Information
We maintain advisors, potential transactional partners, or other third parties designed to guard and prevent misuse of your personal information. Our security measures include generally accepted physical, technical and administrative measures to prevent unauthorized access to or disclosure of your personal information, to maintain data accuracy and ensure the appropriate use of your personal information, and otherwise safeguard your personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email. If you have any questions about the security of your interaction with us (if, for example, you feel that the security of any account you might have with us has been compromised), please reach out immediately via the method listed in the “Contact Us” section below.
6. Retention of Your Personal Information
We will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. We will cease to retain your personal information or remove the means by which the data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes.
7. Access To Other Websites From Our Sites
During your visit to our Sites, you may have the opportunity to link to other websites. Please be aware that we do not have any access, control, input, or authorization over any of the materials or content contained on these websites. Additionally, we are not liable or responsible for the privacy practices, content, or policies of any of these other websites.
8. How We Handle Children’s Information
Our Sites are not directed to, and we do not knowingly collect personal information from, children under the age of 16 (or other age as required by local law). If you are under 16, please do not send any personal information about yourself to us. If we become aware that a child under 16 (or other age as required by local law) has provided us with personal information contrary to our instruction, we will take steps to delete such information from our filesystems, unless we have a legal obligation to keep it.
9. International Transfers
When you access our Sites or submit information to us, your personal information may be transferred to, processed, maintained, and used on computers, servers and systems located where the data protection laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we may transfer your personal information to the United States for further processing. We will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws.
10. Your Privacy Rights
Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in providing you with those rights. Please refer to the “What Rights Apply” section to determine the rights applicable to you.
Please note, your rights in relation to your personal information are not absolute. Depending on the applicable law, access to your rights under the applicable law may be denied: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or unrealistic. If you would like to exercise your rights under applicable laws, please contact us at email@example.com. In your request, please make clear which right you would like to exercise. Upon receiving your rights request. we may seek to verify your identity to ensure the security of your personal information.
- Right to know/access. You may have the right to obtain a copy of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.
- Right to correct/rectification. You may have the right to correct any of your personal information in our files.
- Right to delete/erasure. Under certain circumstances, you may have the right to the erasure of the personal information that we hold about you. This right is not absolute, and we may refuse your right to erasure if it is reasonably necessary for us to provide a service requested by you; to perform a contract between us; to maintain functionality and ensure security of our systems; to enable solely expected internal uses of your personal information; to exercise a right provided by law; to comply with a legal obligation; or if there are compelling legitimate grounds for keeping your personal information.
- Right to restrict processing. You have the right to request that we restrict our processing of your personal information in certain circumstances. For instance, this right may be available if you contest the accuracy of the personal information.
- Right to object to processing. You may have the right to object to our processing of your personal information at any time and as permitted under applicable law if we process your personal information on the legal bases of consent or legitimate interests. However, we may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted under applicable laws.
- Right not to provide consent or to withdraw consent. We may seek to rely on your consent in order to process certain personal information. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
- Right to portability. Under certain circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another controller.
- Right to object to Automated Decision-Making. We do not make any decisions based on algorithms or other automated processing that significantly affect you.
- Right against discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.
What Rights Apply
To determine which rights you have, please refer to the table below that references the rights as described above. U.S. States not listed either do not have a law providing such rights, or it does not apply to our operations.
|European Economic Area, United Kingdom and Switzerland
(for individuals located in these jurisdictions when their personal information is collected)
|(a) Right to know/access; (b) Right to correct/rectification; (c) Right to delete/erasure; (d) Right to restrict processing; (e) Right to object to processing; (f) Right not to provide consent or to withdraw consent; (g) Right to portability; and (h) Right to object to Automated Decision-Making.|
|California Residents||(a) Right to know/access; (b) Right to correct/rectification; (c) Right to delete/erasure; (g) Right to portability; (h)
Right to object to Automated Decision-Making (upon issuance of regulations by the California Privacy Protection Agency);
and (i) Right against discrimination.
11. Additional Notice to Individuals in the European Economic Area, the United Kingdom, and Switzerland
This section only applies to individuals located in the European Economic Area, the United Kingdom, or Switzerland (collectively, the “European Countries”), at the time we collect their personal information collection. References to personal information in this section have the same meaning as “personal data” as the terms is defined under the European Union and United Kingdom’s General Data Protection Regulation (“GDPR”).
We may rely on your IP address to identify which country you are located in. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals whose personal information is collected while they are located in a European Country.
Legal Bases for Processing Your Personal Information
Our legal bases for processing your information under the GDPR will depend on the personal information at issue, the specific context in which the personal information is collected and the purposes for which it is used. Below is a list of how we use and share your personal information, as described above in Section 3 and Section 4, with the corresponding legal bases for processing.
|Section & Purpose of Processing||Legal Bases for Processing|
Section 3(b) To Maintain Legal and Regulatory Compliance.
Section 3(d) To Detect and Prevent Fraud and Security Risks.
Section 4(a) As required by Law
|Based on our legal obligations. Article 6(1) lit.(c) GDPR.|
Section 3(a) To Provide You With Our Sites.
Section 3(c) To Enforce Compliance with Our Terms, Agreements and Policies.
Section 3(e) To Provide Client Support or Respond to You.
Section 3(f) To Provide You with Service-Related Communications.
Section 4(b) Our Affiliates and Subsidiaries
Section 4(c) Our Service Providers
Section 4(d) Authorized Third Parties.
|Based on our contract with you or to take steps at your request prior to entering a contract. Article 6(1) lit.(b) GDPR.|
Section 3(g) To Research and Develop Our Sites.
Section 3(h) To Personalize Your Experience.
Section 3(i) To Facilitate Corporate Acquisitions, Mergers and Transactions.
Section 4(e) During Business Transaction or Other Asset Transfers
|Based on our legitimate interest to operate our business and not overridden by your data protection interests or fundamental rights and freedom. Article 6(1) lit.(f) GDPR.|
Section 3(j) With Your Consent.
Section 4(f) With Your Consent
|Based on your consent. Article 6(1) lit.(a) GDPR.|
Right to Lodge a Complaint to Your Local Data Protection Authority
If you reside in certain territories (such as the European Economic Area, Switzerland, the United Kingdom), you may have the right to lodge a complaint with your national data protection authority or equivalent regulatory body. You can find details of EEA Supervisory Authorities here: https://edpb.europa.eu/about-edpb/board/members_en. The Supervisory Authority in the UK is the Information Commissioner’s Office (ICO).
International Transfer of Your Personal Information
We rely primarily on the European Commission’s Standard Contractual Clauses and the United Kingdom’s International Data Transfer Agreement to facilitate the international and onward transfer of personal information collected in the European Economic Area (“EEA”), the United Kingdom and Switzerland (collectively “European Personal Information”), to the extent the recipients of the European Personal Information are located in a country that the European Countries consider to not provide an adequate level of data protection. We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.
12. Additional Notice to California Residents
Categories of Personal Information Collected, Used, and Disclosed
In the preceding 12 months, depending how you interact with our Services, we may have collect the following categories of personal information (as defined under Cal. Civ. Code §1798.140(v)(1)):
- Identifiers, such as your name, unique personal identifier, email, phone number, or similar identifiers.
- Characteristics protected under state and federal law, such as your age, gender and other demographic information.
- Commercial information, such as your transaction records.
- Internet or other electronic network activity information, such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and information about your visit, including your browsing history, the webpage visited before you came to our Site, length of visit and number of page views, and system configuration information.
For more information about the personal information we collect and how we collect it, please refer to Section 1 above, “Personal Information We Collect.“
For more information about the business purposes for which we collect your personal information, please refer to Section 3 above, “How We Use Your Personal Information.”
To learn the categories of third parties with whom we may share your personal information, please refer to Section 4 above, “How We Share Your Personal Information.“
Right to Opt Out of Sale and Sharing
Right to Limit Use of Sensitive Information
If you are a California resident, to the extent your sensitive personal information (as that term is defined under California privacy law) is used to infer characteristic about you, you have the right to direct us to stop such processing of your sensitive personal information for such purposes. We do not process any sensitive personal information to infer characteristics about you without your consent.
Exercise Your Privacy Rights
Please see Section 10 to understand how to exercise applicable privacy rights under California Privacy Laws. Please note, if you use an authorized agent to submit requests on your behalf, we will require you to directly verify your identity with us, or have you directly confirm with us that the authorized agent has been authorized to act on your behalf.
Do Not Track Signals
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.