CONSTITUTION CAPITAL PARTNERS PRIVACY POLICY
Last modified: May 24, 2018
Our Commitment to Your Privacy:
This Privacy Policy applies to Constitution Capital Partners, LLC (together with its affiliates, “CCP” or “we”). Your privacy is important to us and we are strongly committed to protecting your privacy. This privacy policy applies to information we may collect from you or that you may provide when you visit our web site www.concp.com (the “Web site”). This policy also applies to information we collect offline when you submit subscription documents to any of the CCP sponsored investment funds.
How We Use the Information We Collect:
We may use your personal information to process any transactions between you and us (i.e. where this is necessary for the performance of the contract); to administer and operate the Web site, to fulfill any other purpose for which you provide your personal information, to communicate with you, to provide you with notices about your investment account to maintain, for direct marketing purposes (providing information on products and services) (i.e. where this is necessary for the purposes of the legitimate interests of us or a third party and such legitimate interests are not overridden by your interests, fundamental rights or freedoms and provided that we are acting in a fair, transparent and accountable manner and have taken appropriate steps to prevent such activity having any unwarranted impact on you and also noting your right to object to such uses, as discussed below); and to respond to legal requests or requests from regulatory authorities (i.e. where this is necessary for compliance with a legal obligation to which we are subject).
How We Share the Information We Collect:
We may share information about you or which you provide us with our affiliates and service providers who we use to support our services and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
Furthermore, we may sell, transfer, assign, or otherwise share your personal information in conjunction with a merger, acquisition, reorganization, sale, transfer of assets, reorganization, or liquidation of all or part of CCP.
We may also share your personal information where disclosure is necessary to: (a) comply with legal process (such as a court order) or other legal requirements of any governmental authority; (b) protect our rights or property; (c) protect the interest of users of the Web site, other than you, or any other person; or (d) operate or conduct maintenance and repair of our services or equipment, as authorized by law.
International Use:
For visitors to CCP’s website who are based in the European Economic Area (the “EEA”), you should be aware that information which you provide to CCP may be transferred to countries (including the United States) which do not have data protection laws equivalent to those in force in the EEA.
Data Security:
The safety and security of your information also depends on you. We ask you not to share your password with anyone.
We apply appropriate information security measures designed to protect data in our possession from unauthorized access by third parties or any form of computer corruption.
No security program is impenetrable and criminals have proven adept at circumventing widely-adopted security safeguards, so we cannot guarantee the security of the personal information you transmit to us. Accordingly, you acknowledge that you do so at your own risk.
Tracking Technologies:
We and others may collect information about your activity on our sites and applications using tracking technologies such as cookies, Flash cookies and Web beacons. Examples of this type of information include information about your computer and Internet connection, such as your operating system and browser type, and details of your visits to our Web site, including traffic data, location data, logs and other communication data and the resources that you access and use on the Web site.
You may delete or disable cookies or other technologies to prevent us from collecting the above information. If you do, you may not be able to successfully participate in features of our Web site.
Links to Third-Party Websites:
The Web Site contains links to other web sites. We have no control over and are not responsible for the privacy policies or practices of such sites. Whenever you link to another web site, you may be asked to provide registration or other information. Please note that any information that you provide is going to a third party, and therefore you should familiarize yourself with that party’s privacy policy.
How You Can Access or Correct Your Information:
You may send us an e-mail at info@concp.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, require disproportionate technical effort, or jeopardize the privacy of others.
The Data Protection Measures We Take:
If the processing of your personal data by us is subject to the EU General Data Protection Regulation (GDPR), any transfer of personal data by us or our duly authorized delegates outside the EEA shall be with your consent, or in accordance with data transfer agreements in the form of the EU Commission approved model contractual clauses (as amended from time to time), or ad hoc versions thereof (the “Model Clauses”), binding corporate rules, or any other measures satisfying the requirements of the GDPR for such disclosure. In this respect, you, as a data subject, have a right to request copies of the relevant transfer documents for enabling the Personal Data transfer(s) towards such countries by writing to us. Personal data may also be transferred outside the EEA to countries benefiting from an adequacy decision of the European Commission.
We shall notify you of any personal data breach affecting you that is likely to result in a high risk to your rights and freedoms.
Your Data Protection Rights:
If the processing of your personal data by us is subject to the GDPR, you have certain rights regarding our use of your personal data, examples summarized below:
You also have the right to object to the processing of your data where we have considered this to be necessary for the purposes of our legitimate interests.
Our Retention of Your Personal Data:
We may retain your personal data for such a period as required by any applicable laws or regulations or for such a period as may be permitted in accordance with the lawful purposes or our legitimate interests outlined above. Thereafter, we will refrain from collecting any further personal data on you and shall take appropriate steps to dispose of any records containing your personal data to the extent this is operationally feasible and proportionate.
How to Contact Us About Privacy Matters:
If you would like to contact us for any reason concerning our privacy practices, please email us at info@concp.com.
We hope that we are able to resolve any complaint or concern you may have regarding the processing of your personal data, but if the processing of your personal data by us is subject to the GDPR, you are entitled to make a complaint directly to the supervisory authority in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
Changes to Our Privacy Policy:
We may update this Privacy Policy from time to time. We will notify users by posting the new policy on our Web Site and we will notify you of material changes with an alert on the Web site or a communication to you. Please check back here periodically to review our latest policy.
