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WEBSITE PRIVACY NOTICE

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Effective Date/Last Updated: January 1, 2023

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1. Our Commitment to Your Privacy

Cedar Park Capital Management, L.P. and its affiliates (together, “ Cedar Park Capital,” “our,” “us” or “we”) recognize and respect your right to privacy. We are providing this privacy notice (this “Privacy Notice”) to help you better understand the type of Personal Information we collect through our website and the websites of our affiliates (collectively the “Websites”) or when you call or email us to make a request for information. This Privacy Notice also describes how and why we collect or share this information and tells you about your rights and choices about the use of that Personal Information. If you do not agree with this Privacy Notice, please do not provide us with any Personal Information through our Websites.

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This Privacy Notice should be read in conjunction with other documents that we provide to you, including our Terms of Use.  This documentation may include sections relating to the use and disclosure of information. Where a conflict exists between the terms of this Privacy Notice and any other document in relation to data protection, the terms of this Privacy Notice will apply. The policies described in this Privacy Notice continues to apply even if your relationship with us ends.

This Privacy Notice does not apply to any information collected by Cedar Park Capital other than Personal Information collected from the sources discussed below. This Privacy Notice also does not apply to information about businesses or other non-individuals. Cedar Park Capital reserves the right to use and disclose aggregated and deidentified information for any commercially reasonable purpose.

 

2. Types of Personal Information We Collect

“Personal Information” is information that reasonably allows us to identify you or your household. We collect Personal Information you voluntarily provide, including when you contact us via phone or email. Such Personal Information may include your name, email, and any other information you voluntarily share with us in such interactions.

 

3. Sources of Personal Information

This policy applies to our collection of Personal Information about you from the following sources:

  1. Communications with you, including over the telephone, in voicemails, through written materials and via e-mail and other electronic communications; and

  2. Our Websites. 

 

4. Disclosure of Personal Information

We may disclose the Personal Information described above to certain third parties as authorized by you or as permitted or required by law or regulation. More specifically, we may share Personal Information where:

  1. It is necessary to comply with our contractual obligations or with your instructions;

  2. We have a public or legal duty to do so (for example, to assist with detecting and preventing fraud, tax evasion and financial crime or compliance with a court order);

  3. We are obligated to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;

  4. Necessary to protect our system, protect your security or the security of others and to prosecute those responsible for breaching it;

  5. Needed to allow us to provide you with necessary or useful services, for example sharing with affiliates and service providers, including administrators, hosting providers, governmental agencies, regulatory organizations, and consultants; and

  6. We have asked you if we can share it, and you gave consent.

 

5. Protection of Personal Information 

We have implemented security policies and other technical and organizational measures in an effort to protect the Personal Information that we process. These security measures are designed to prevent unauthorized access, improper use or disclosure, unauthorized modification, and unlawful destruction or accidental loss of your Personal Information. However, no method of protecting or processing data is 100% secure and Personal Information you provide to us may be subject to a breach. To the extent we provide your Personal Information to any third parties, we will request that they use reasonable security measures to protect your information.

 

6. Children’s Personal Information

Please note that we do not knowingly collect Personal Information relating to children. If we learn we have received Personal Information from a child under 13 without verified parental consent, we will endeavor to delete the information. 

 

7. Our Use of Cookies and Web Beacons

Cookies are small files that websites save to your hard disk or to your browser’s memory. Our Websites may use cookies to track the number of times you have visited the site, to track the number of visitors to the site, to determine and analyze visitors’ use of our site, to store data that you provide such as your preferences and e-mail address, and to store technical information related to your interactions with our site. We may also use session cookies (which are deleted when you close your browser) to facilitate your movement around our site and other information useful in administering the session.

Most internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer.    If you choose not to accept cookies, you may not be able to experience all of the features of our Websites. Internet browsers also enable you to delete existing cookies, although this means that your existing settings will be lost.

Our site also may contain electronic images known as web beacons – sometimes called single-pixel gifs – that allow us to count the number of users who have visited those pages. We may include web beacons in e-mail messages or newsletters in order to determine whether messages have been opened and acted upon (including whether the recipient clicked on a link in the email or forwarded the email to another person).

The Websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users navigate our site and what resources they access. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. Google will use the information on behalf of Cedar Park Capital for the purpose of evaluating use of the Websites, compiling reports on website activity for us, and providing us with other services relating to website activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. In addition to opting out of the use of cookies, you can also opt out of being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: https://tools.google.com/dlpage/gaoptout.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. Our Websites do not currently support Do Not Track requests.

 

8. Our Retention Policies 

Personal Information may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations, or where longer, such longer periods as are required or permitted by applicable legal or regulatory obligations. 

We may also be allowed to retain Personal Information for a longer period if you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

 

9. California Privacy Rights

If you are a California resident, then you also have the following rights under the California Consumer Privacy Act (“CCPA”) regarding your Personal Information. 

Right to Know

You have the right to know and see what Personal Information we have collected about you over the past 12 months, including:

  1. The categories of Personal Information we have collected about you;

  2. The categories of sources from which the Personal Information is collected;

  3. The business or commercial purpose for collecting your Personal Information;

  4. The categories of third parties with whom we have shared your Personal Information; and

  5. The specific pieces of Personal Information we have collected about you.

 

Right to Delete

You have the right to request that we delete the Personal Information we have collected from you. There are a number of exceptions, however, that include, but are not limited, to when the information is necessary for us or a third party to do any of the following:

  1. Complete your transaction;

  2. Provide you a good or service;

  3. Perform a contract between us and you;

  4. Protect your security and prosecute those responsible for breaching it;

  5. Fix our system in the case of a bug;

  6. Protect the free speech rights of you or other users;

  7. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);

  8. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;

  9. Comply with a legal obligation; or

  10. Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

 

Sale of Your Personal Information

We do not sell your Personal Information for money or other consideration of value.  We do not sell Personal Information of children of the ages of 13 through 15, nor of children under 13.

 

More information about your rights as a California consumer may be found on California’s Department of Justice website.

 

Cedar Park Capital Does Not Discriminate

We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

 

How to Exercise Your Rights

To exercise any of your California access or deletion request rights, please submit a verifiable consumer request to privacy@cedarparkcap.com. 

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. You may also designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with specific pieces of Personal Information if we cannot verify your identity and authority to make the request.

 

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request.  Please contact Cedar Park Capital at privacy@cedarparkcap.com with any questions about this Privacy Notice.

 

10. Third-Party Websites

Our Websites may contain links to other outside websites. Please be aware that we are not responsible for the content or privacy practices of such other websites. We encourage you to read the privacy statements of any other website that collects information of visitors.

 

11. Updates and Revisions

We may revise this Privacy Notice.  If we revise the Privacy Notice, we will post the updated policy on our website.  Please check this Privacy Notice at cedarparkcap.com frequently to ensure that you are familiar with its current contents.

 

12. How to Contact Us

For any questions or concerns about this Privacy Notice or to make a request regarding your Personal Information, please call contact us via email at privacy@cedarparkcap.com.

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