Privacy Policy

COMCAP LLC PRIVACY POLICY

The privacy of your personal data is important to ComCap LLC. This Privacy Policy (the “Policy”) describes ComCap LLC’s privacy policy as it pertains to www.comcapllc.com (the “Website”) and its digital marketing programs (such as the firm’s e-newsletters).

INFORMATION WE COLLECT

ComCap LLC asks for and collects from you personally identifiable information, in particular name, personal contact information such as email address, preference information, and the ComCap LLC newsletters you click on. However, with respect to users inside the EU, only limited Personal Information is processed – please see section “The Website and EU websites” below.

PURPOSES OF THE PROCESSING

The purposes for which we process and store your Personal Information are:

  • To administer, monitor, understand e-newsletter performance and use, and to improve the user experience
  • Where you have requested it or in accordance with applicable privacy laws, to provide you (by email) with marketing, promotional, or other information that we think may be of interest to you
  • To execute events and other programs in which you participate;
  • To enable us to comply with our legal and regulatory obligations.
  • Any promotional correspondence to you will provide you with the ability to opt-out of receiving future promotional material from us and you may contact us at any time and at no cost to tell us that you do not want to receive marketing information from us by emailing us at this email address: research@comcapllc.com.

LEGAL BASIS FOR THE PROCESSING

The processing of your Personal Information is permitted by applicable data protection laws. In the EU, the legal basis for the processing are, with respect to most purposes set out above, our legitimate business interests in providing and improving the Website and any services provided on the Website, including our newsletter and marketing activities, or in defending our legal rights (see Art. 6(1)(f) of the General Data Protection Regulation – “GDPR”).

HOW WE COLLECT INFORMATION

ComCap LLC directly collects from you Personal Information, either during the course of business or from our online sign-up forms. (We also collect Personal Information through our service providers such as LinkedIn). ComCap LLC may combine this information with the Personal Information you give us and other information it collects.

INFORMATION SHARING

ComCap LLC will not disclose your Personal Information to any third party. Unless you direct us to do so, or if we are required or authorized by law or if we reasonably believe that the disclosure is necessary in order to (a) fulfill a government request; (b) conform with the requirements of law or to comply with legal process served on us; or (c) protect or defend our legal rights or property or third party licensors of any material on the Website, or (v) for other purposes disclosed at or before the time the information is collected.

UPDATING YOUR PERSONAL INFORMATION

To ensure that you have as much control over your Personal Information as possible, you may update your Personal Information by contacting us at research@comcapllc.com. We will use reasonable efforts to process any change you make.

THE WEBSITE AND EU WEBSITES

Certain Personal Information, such as name, email and company, may be collected for EU and non-EU residents or nationals when it is shared by website visitors directly, such as to opt into our e-newsletter program and provide consent. The Website includes all web pages accessible by the public.

Please note that this Policy does not apply to other organizations to which we link. We are not responsible for their privacy policies or practices of any other third-party websites and you should make your own inquiries regarding them.

ACCESS TO YOUR INFORMATION AND OTHER RIGHTS

If we process your Personal Information, you have the right to access your Personal Information and to request a copy of the Personal Information that we hold about you. If you wish to request access to such personal information, please email us at research@comcapllc.com. We reserve the right to charge you a small fee for this service if you request more than one copy of the Personal Information. If you discover any inaccuracy, please let us know so that we can make whatever corrections are appropriate.

You also have the following rights:

  1. The erasure of your Personal Information
  2. To restrict the processing of your Personal Information
  3. To tell us that you do not wish to receive marketing information
  4. Furthermore, you have the right to object to us processing your Personal Information at any time (i) in case of direct marketing or (ii) on grounds relating to your particular situation, in case we process your Personal Information for the purposes of our legitimate interests. As to such purposes, you will find more information above (“Purposes of the processing”)

To the extent our processing of your Personal Information is based on your consent, you also have the right to withdraw your consent, without affecting the lawfulness of our processing based on your consent before its withdrawal. You may also ask us to remove your name from our marketing databases and if you do that we will comply as soon as practicable.

CONTACT US

To make use of your rights listed above, or should you feel that your privacy or security is being compromised, wish to make a request for access to any personal data we may hold about you or to have inaccuracies in your information corrected (as described further on the “Access To Your Information” section above), or have any questions on this policy, please contact us at ComCap LLC, 1031 Franklin Street, San Francisco, CA 94109 or email research@comcapllc.com.

POLICY CHANGES

We reserve the right to change our Privacy Policy at any time.

Date of last update or revision: May 25, 2018

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