EFFECTIVE AS OF NOVEMBER 15, 2020
Personal Information We Collect
Information You Give Us. Personal information you may provide through the Site or otherwise communicate to us includes information you provide to us when you request information or otherwise correspond with us. This information may include your first and last name, email address, mailing address, and phone number, or other information you choose to make available.
Information We Get From Others. We may obtain additional information about you from third party sources, such as service providers, vendors, social media sites, and advertising agencies to provide you with more relevant information about our services.
Statistical Analyses. We use Google Analytics to help us gather statistical information about the visitors to our Site and how they use the Site on an anonymous, aggregate basis. However, we will not associate this data with your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental request or to comply with law. We may use this information to gain a better understanding of the users of our Site, to improve our Site, and to improve our services. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google Analytics use. To understand how Google Analytics collects and processes data, please visit Google Privacy & Terms. We reserve the right to license or sell aggregate, de-identified information about the visitors to our Site, but this information will not contain your personal information or otherwise be individually identifiable.
Sensitive Personal Information. We do not intentionally collect sensitive personal information about you (e.g., social security numbers, information related to racial or ethnic origin, gender, and criminal background) through the Site and ask that you do not provide us with this information.
How We Use Your Personal Information
To Provide the Site and Communicate With You. We use your personal information:
to provide, maintain and improve the Site;
to better understand your needs and interests, and personalize your experience with the Site;
to respond to your requests, questions, comments, and feedback; and
to perform website analytics and database management services.
To Send You Marketing Communications. We may send you newsletters, promotions or other marketing communications, but you may opt out of receiving them as described in the Your Choices section below.
For Compliance, Fraud Prevention and Safety. We may use your personal information as we believe appropriate to: (a) investigate or prevent violation of the law or your agreements with us; (b) protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims); (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (e) where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our site for illegal reasons.
With Your Consent. In some cases we may ask for your consent to collect, use or share your personal information.
How We Share your Personal Information
We do not share your personal information with third parties without your consent, except in the following circumstances:
Service Providers. We may share your personal information with third party companies and individuals as needed for them to provide us with services that help us with our business activities and to promote our services to you. A list of our current service providers is available upon request.
Business Partners. We may share your personal information with our business partners who offer a service to you jointly with us. A list of our current business partners that have access to certain personal information we collect is available upon request.
Security, Compliance, Fraud Prevention, Safety; Compliance with Law. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties for the purposes described above under the following sections: For compliance, fraud prevention and safety and for compliance with law.
Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy.
Opt Out of Marketing Communications. You may opt out of marketing-related emails by changing the communication preferences in your account settings or by following the opt-out prompt in the email. To opt out of other forms of marketing communications, please contact us using the contact information provided at the end of this Policy.
What are Cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by the website are called “first party cookies”. Cookies set by parties other than the website are called “third party cookies”. Third party cookies enable third party features or functionality, such as advertising or website analytics, to be provided on or through the website. The parties that set these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.
How Can You Disable Cookies and Other Tracking Technology? Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
Some Internet browsers also may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
Other Important Privacy Information
Third Party Sites and Services. The Site may contain links to other websites and services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and we are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to learn more.
Security. The security of your personal information is important to us. We take a number of organizational, technical and physical measures that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your personal information.
International Data Use. We are located in the United States and have affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.
Verifying, Changing and Deleting Your Information. You can contact us as detailed in the “How to Contact Us” section below and ask us to change, update or fix your information in certain cases, particularly if it is inaccurate. You can also request that we erase or delete all or some of your personal information or otherwise object to, limit, or restrict the use of such information (if we have no legal right or legitimate business interest in retaining such information).
Children. The Site is not intended for use by anyone under the age of 13, nor do we knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, you should not attempt to use the Site or send any information about yourself to us.
Notice to California Residents
The following section applies to California residents.
Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes. To make a request contact us as detailed in the “How to Contact Us” section below and specify you are making a Shine the Light request.
California Consumer Privacy Act (“CCPA”). The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following information.
Personal Information We Collect. We collect your personal information when you interact with our Site or otherwise communicate with us. For the purposes of this Privacy Notice, “personal information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.
We have collected the following categories of personal information covered by the CCPA from consumers within the past 12 months, and have used it for the following business purposes:
Category of Personal Information Collected
Business Purpose of Collection
Identifiers, including real name, signature postal address, Internet Protocol address, email address, telephone numbers.
To market our services and communicate with you. In addition, we collect your IP address anonymously to provide you more relevant content, track original Site visits, and optimize your Site experience.
Internet or other electronic network activity information, including browsing history, search history, and information regarding an individual’s interaction with an internet Web site, application or advertisement.
To provide you more relevant content, track original Site visits, and optimize your Site experience.
To support website functionality and identify traffic patterns.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.
We do not sell your personal information. However, we disclose the following categories of personal information covered by the CCPA for a business purpose:
Category of Personal Information Disclosed
Category of Third Parties with Whom Information is Disclosed for our Business Purposes
Service providers, including our website service providers, email marketing automation and data analytics providers.
Internet or other electronic network activity information and Geolocation Data.
Service providers, including our data analytics providers, email marketing automation and marketing service providers.
Please note that we may collect, use and share additional personal information about you that is governed by laws other than the CCPA, such as the Gramm-Leach-Bliley Act, and that our activities related to such personal information are not disclosed here. Click here to learn more about our privacy practices related to such personal information.
Source of Personal Information. To read a more detailed disclosure of the personal information we collect, see the section entitled “Personal Information We Collect” above. More broadly, we obtain the categories of personal information that are listed above in the following ways:
Directly from You. We collect identifiers from you when you:
Provide your contact information to us.
Submit a request to us.
Interact with our social media pages.
Passively. We collect IP addresses, internet and other electronic activity information, and geolocation data from you when you:
Visit and navigate our Site on any device.
Click on sponsored links or third-party advertisements.
Receive or interact with our communications and website that may contain cookies.
From Third Parties. We may receive internet or other electronic network activity information about you from other sources. For example, we get information from:
Our business partners, including online advertising networks.
Social media platforms.
Data analytic providers.
Website service providers.
Email marketing and automation.
Your Rights. The CCPA gives you certain rights regarding your personal information:
Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.
Exercising Your Rights. To exercise your rights above, please submit a request to us by clicking here, by emailing us at CCPARequests@clarkstoncapital.com, or by calling us at 1 (888) 450-7620. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide your name and contact information. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request.
After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request. Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. We may not discriminate against you if you choose to exercise your rights.
Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable.
We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.
How to Contact Us
Clarkston Capital Partners, LLC
91 West Long Lake Road
Bloomfield Hills, MI 48304
United States of America
Phone: (248) 723-8000