Effective Date: September 2, 2022
If you are one of our investors, our Regulation S-P Privacy, which governs how we collect, use and share your nonpublic personal information, is available within our Investor Login portal on the website home page.
COLLECTION OF PERSONAL INFORMATION
Information you provide. We may obtain information that you provide directly to us on the Site and through events, phone conversations, and email communications. For example, when you contact us online or communicate with us in person.
This information may include personal information, which is information that can be used to identify you individually, such as your: name, email address, phone number, or company information.
If you submit to us someone else’s personal information (e.g., their contact information), you represent that you have the proper consent or authorization to provide this information to us. Please note if someone provides information to us on your behalf, we will not verify their authorization to do so.
Information collected automatically. In addition to the information you submit through the Site, we may collect certain information using automated tools, such as cookies and web beacons. “Cookies” are small data files stored by your web browser on your device. Cookies may allow a website to recognize a user’s device, record user preferences, track the pages a user clicks on while visiting the website, and identify the website visited immediately beforehand. Most web browsers accept cookies by default, but you may be able to adjust your browser settings to remove or reject cookies. Please note that blocking cookies may affect the availability and functionality of the Site and other websites or invalidate opt-outs that rely on cookies to function. “Web beacon” (also called pixel tags) are small graphic images or code (that you typically cannot see) on a website or in an email message which may be used for measuring click-throughs or tracking the performance of email marketing campaigns.
The types of information we collect automatically when you visit the Site may include:
- IP addresses
- Device identifiers or other unique identifiers
- Browser characteristics
- Operating system details
- Language preferences
- Referring URLs
- Length of visits
- Anonymous traffic data
- Pages viewed
We may combine certain automatically-collected information with other information we obtain about you, which may include data we obtain from third parties.
We or third parties may collect personal information about your online activities over time and across different devices and online services when you use the Site.
DATA ANALYTICS AND ADVERTISING
We may use third-party technology to collect and use data in connection with interest-based advertising. These third-party ad technology companies and advertisers may use, store, or access cookies, web beacons, and other storage technologies to collect or receive information from the Site and elsewhere on the Internet and use that information to provide advertising services to us, including interest-based advertising or advertisements targeted to your interests.
We may also use certain third-party web analytics services to help us understand and analyze how visitors use the Site and serve ads on our behalf across the Internet. We and third-party vendors may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to track demographics and improve user experience. To find out more about how these third-party analytics services manage the privacy of information in conjunction with delivering ads online, and how to opt-out of information collection by these networks, please visit: http://www.youradchoices.com, http://www.aboutads.info/appchoices, https://thenai.org/.
For more information on how Google Analytics uses data collected through the Site, visit: http://www.google.com/policies/privacy/partners/. To opt-out of Google Analytics cookies, visit: http://www.google.com/settings/ads and https://tools.google.com/dlpage/gaoptout/.
Your web browser may have settings that allow you to transmit a “DO NOT TRACK” signal when you visit various websites or use online services. Like many websites, the Site is not designed to respond to “DO NOT TRACK” signals received from browsers. To learn more about “DO NOT TRACK” signals, visit http://www.allaboutdnt.com/.
USE OF INFORMATION
We may use personal information we collect through the Site to:
- Respond to your requests;
- Monitor and analyze trends, usage, and activities of visitors and users of the Site;
- Communicate or market to you, including about any other product or services that we think may be of interest to you;
- Comply with applicable laws, regulations, or legal process as well as industry standards and our company policies;
- Prevent, investigate, identify, or take any other action with regard to any, suspected or actual, fraudulent or illegal activity or any activity that violates our policies; or
- For any other purpose, with your consent.
SHARING OF PERSONAL INFORMATION
We may share your information, including your personal information, with affiliates, business partners, and vendors. For example, we may use service providers to help us operate our business and the Site or administer activities on our behalf, such as sending emails and providing customer service. Information, including personal information, may also be shared:
- As permitted by law;
- In the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction, including negotiations of such transactions);
- Where we determine that disclosure of specific information is necessary or appropriate to comply with a law enforcement or regulatory agency request, or other legal process; or
- To enforce our policies or to protect legal rights, property, or safety.
LINKS AND THIRD PARTIES’ PRIVACY PRACTICES
The Site may permit you to interact with another website or online service, such as enabling you to “follow” Cyprium on another site or “share” content from the Site with other sites (a “Social Feature”). If you choose to “like” or “share” content or post information using Social Feature, that information may be publicly displayed, and the other party may have access to certain information about you and your use of the Site. Similarly, if you interact with us through Social Features, we may have access to information about you (for example, if you “like” or “follow” our page on another website). Please note that if you mention or comment about Cyprium or our Site in your post to another platform, that platform may allow us to publish your post on our Site.
In addition, we may receive information about you if a user of another website gives us access to their profile and you are one of their “connections”, or information about you is otherwise accessible through that other user.
We offer choices about the types of information you receive from us. If you no longer wish to receive our emails, you may unsubscribe using the link provided at the bottom of the email or by sending us an email at email@example.com.
Our Site is not intended for, nor targeted to, children under 13, and we do not knowingly request or collect personal information from any person under 13 years of age through the Site. If we learn that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with applicable law.
Cyprium is not a “business” subject to the California Consumer Privacy Act; however, California residents may contact us at firstname.lastname@example.org for more information regarding our data collection practices.
We take reasonable measures to protect your personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and we cannot guarantee the security of your information collected through the Site.
INFORMATION FOR USERS OUTSIDE THE UNITED STATES
INFORMATION FOR VISITORS FROM THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM
In accordance with the EU’s General Data Protection Regulation and the UK’s General Data Protection Regulation (collectively, the “GDPR”), our processing of your personal data is carried out under the following legal bases:
- The processing is necessary for us to provide you with the services you request or to respond to your inquiries.
- We have a legal obligation to process your personal data, such as compliance with applicable tax laws or other government regulations or compliance with a court order or binding law enforcement request.
- We have a legitimate interest in processing your personal data. In particular, we have a legitimate interest in the following instances:
- To analyze and improve the safety and security of our Site and services, including by implementing and enhancing security measures and safeguards and protecting against fraud, spam, and other abuse;
- To maintain and improve our Site and services; and
- To operate our Site and provide you with information and communications about our services that are tailored to, and in accordance with, your preferences.
- You have consented to our processing of your personal data. When you consent, you may change your mind and withdraw your consent at any time.
YOUR RIGHTS UNDER THE GDPR
The GDPR provides individuals with certain rights regarding their Personal Data. You may ask us to take the following actions in relation to your personal data:
- Provide you with information about our processing of your personal data and give you access to your personal data.
- Update or correct inaccuracies in your personal data
- Delete your personal data.
- Transfer a copy of your personal data to you or a third party of your choice.
- Restrict the processing of your personal data.
- Object to our processing of your personal data for direct marketing purposes.
- Object to our reliance on legitimate interests as the basis for processing your personal data.
You may submit these requests by email to email@example.com. We may request specific information from you to help us verify your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to any legal restrictions on providing this information.
If you would like to submit a complaint about our use of your personal data or our response to your request regarding your personal data, you may contact us at firstname.lastname@example.org or submit a complaint directly to the data protection authority in your jurisdiction. If you reside in the EEA, you can find information about your data protection authority here. If you reside in the United Kingdom, you may file complaints with the Information Commissioner’s Office here.
OUR RETENTION OF YOUR PERSONAL DATA
We will keep your personal data for no longer than is necessary to achieve the purposes for which the personal data was collected, or as may be permitted or required under applicable law. To determine the appropriate retention period, we will consider the scope and sensitivity of the personal data; the potential risk of harm from unauthorized access to, use, or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period, we will securely destroy your personal data or take appropriate anonymization steps.