PRIVACY POLICY
This privacy policy (this “Policy”) describes how Painswick Capital Management LP (“Painswick,” “we,” “our,” “us”) maintains, uses, discloses, processes and protects any information that we may collect pertaining to you (“Personal Data”) when you use our website at www.PainswickCapital.com (this “Site”).
By accessing this Site, you affirm your agreement to this Policy. We may modify this Policy from time to time, and your continued use of this Site after we post such modifications will confirm your acceptance of this Policy, as modified. If you do not agree with any provision of this Policy, you are not permitted to access or use the Site.
What We Collect
The Site is primarily for informational purposes. We do not request or require, or provide opportunities for you to submit, Personal Data on the Site, nor do we collect Personal Data by means of the Site, other than as set forth below.
We may record details of visits to the Site, such as traffic data, IP addresses, location data, weblog information about the device you use to interact with the Site, the type of operating system and browser you use, access times, pages viewed, URLs clicked on, and the pages visited before navigating to the Site, using cookies or other technologies, as set forth below.
Cookies are small text files stored by your browser on your computer when you visit websites, which allow for the collection of certain information about your use of the websites. Some of these cookies are essential, but you have the choice to refuse the use of all non-essential cookies through your browser settings or by clicking on the options on the Site. To find out more about cookies please visit: www.allaboutcookies.org or www.youronlinechoices.eu.
We use cookies and similar technologies to enhance your browsing experience, analyze site traffic, and support the functionality of this Site, e.g.: to help us understand how visitors interact with this Site by collecting anonymous data such as page views, session duration, and traffic source; to deliver custom fonts and monitor font usage for licensing compliance and page consistency; to ensure reliable delivery of web fonts to enhance design and improve load performance; and to delivers essential site assets such as scripts and stylesheets efficiently and securely.
Why We Collect and Process Personal Data
We may process the Personal Data described in this Policy for the following purposes:
to provide service and support relating to the Site;
to monitor, improve and safeguard use of the Site;
where you give us consent;
in connection with legal claims, and to comply with applicable laws, regulations, subpoenas, legal process, governmental investigations, regulatory requests or inquiries, including cooperating with government or law enforcement authorities conducting an investigation; and
as otherwise described in this Policy.
How and With Whom Do We Share Personal Data
We may share your Personal Data as set forth below:
among our affiliated organizations;
with service providers, suppliers and subcontractors for the purpose of providing the Site;
with analytics and search engine providers, such as Google Analytics, that use such information to help improve and optimize the Site (to learn more about Google Analytics and how Google collects and processes data, see www.google.com/policies/privacy/partners);
if we sell or buy any businesses or assets or merge any business or operations into or with those of another person or entity, in which case we may disclose your Personal Data to the prospective counterparty in such transaction and such data may be one of the assets transferred in such transaction;
to comply with applicable laws, regulations, subpoenas, legal process, governmental investigations, regulatory requests or inquiries, to cooperate with law enforcement, to assert or defend against legal claims, to protect our and others’ rights, property, or safety, and for the purposes of crime and fraud prevention and remediation;
as required to conduct our business and pursue our legitimate interests; or
to any other party with your consent.
Security
We are committed to maintaining the security of Personal Data. In order to minimize the risk of unauthorized access or disclosure, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Links
This Site may contain links to websites operated by other parties. Painswick does not control or endorse the content of such websites. Any such links are provided for your reference only. Any third party sites are governed by their own privacy policies, which we recommend that you review.
Your Rights
You may have various rights with respect to our use, processing and sharing of your Personal Data, as described below, under applicable laws. We make these rights available to all users. There may be exceptions to these rights under applicable law. If you wish to contact us to exercise any of these rights, please contact us using the information below.
We will not deny you services, charge you a different price, provide a different level or quality of services or otherwise discriminate against you just because you exercised any of these rights; however, if you decline to provide your personal information or ask us to delete it or stop disclosing it, we may be unable to provide you with certain services.
Only you, or a person whom you authorize to act on your behalf, may make a request related to your Personal Data. The request must:
provide sufficient information for us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative of such person; and
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Data if you do not take the foregoing actions. Making a request does not require you to create an account with us. We will use Personal Data provided in a request only to verify your identity or authority to make the request.
· Access: You may request a copy of the Personal Data that we have collected, used, or shared about you, and why we collected, used or shared that Personal Data, including the categories of Personal Data collected, the specific items of Personal Data collected, the categories of sources from which we collected Personal Data, the purposes for which we use the Personal Data, the categories of third parties with whom we share the Personal Data, and the categories of information that we disclose to third parties.
· Accuracy: We aim to keep your Personal Data accurate, current, and complete. We encourage you to contact us to let us know if any of your Personal Data is not accurate or changes.
· Objecting/Deletion: You may object to processing of your Personal Data and ask us to block, delete or restrict your Personal Data, subject to certain exceptions. Once we receive your request and verify your identity, we will delete your Personal Data from our records and direct our service providers to delete your Personal Data from their records, unless an exception applies under applicable law.
· Portability: You have the right to request that your Personal Data be provided to you, or to another data controller, in a commonly used, machine-readable format.
· Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority.
How Long We Keep Your Personal Data
We will retain Personal Data for as long as required to provide the services to you.
Do Not Track
We do not track visitors to the Site over time or across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) browser settings.
Contacting Us
If you wish to communicate with us regarding this Policy or your Personal Data, please contact us at:
Painswick Capital Management LP
520 Madison Avenue, 40th FL
New York, NY 10022
Email: info@painswickcapital.com
Tel: 1-646-580-6960