This Privacy Policy & Rights applies only to the information Boundary Street Capital, LP and its respective subsidiaries and affiliates (collectively, “Boundary Street,” “we,” or “us,” or “our”) collect through the websites, mobile-optimized websites, mobile applications, electronic devices, social media pages, software, ticket readers, kiosks, and all other interactive services we provide, and all of the associated content, functionalities, and advertising (collectively the “Services”).

We use information about you to improve and personalize the services we offer you to make your experience with us as rewarding as possible. This Privacy Policy (“Privacy Policy”) describes how we handle Personal Information collected online via our Services.

 

What information is collected through our Services?

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“Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information. We collect different categories of Personal Information from different sources, including user-provided information and site usage information. We also collect Personal Information from social networking and blogging.

 

User-Provided Information

We collect Personal Information such as your name; Company name; e-mail addresses; telephone numbers; ISP account addresses (including text message addresses); and site browsing history. For example, we may collect Personal Information such as your e-mail address, or any other information you may choose to provide, when you submit a comment or question to us.

 

Sites Usage Information

As is the case with many websites, our servers automatically collect your IP address when you use applicable Services, and we may associate that with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your usage. Clickstream data includes, for example, information about your computer or device, Web browser and operating system and their settings, the referring page that linked you to the Services, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next website you visit when you leave the Services, and any search terms you have entered on the Services.

Among other things, this information enables us to generate analytics reports on the usage of our Services. To opt-out of your Services usage being included in our Google Analytics reports, you may follow these instructions: https://tools.google.com/dlpage/gaoptout

In addition, we may deploy various tracking technologies on our Services to collect additional information about your visits. For example:

• Cookies are small data files stored on your computer or device at the request of a Web site. A cookie assigns a unique numerical identifier to your Web browser, and may enable us to recognize you as the same user who was at our Services in the past, and relate your use of the Services to other information about you, such as your Services usage information and Personal Information. Cookies may also be used to enhance your experience on the Services (for example, by storing your username so you can log in easily, keeping you logged into the Site after you have provided your password, and storing the contents of your shopping cart as you browse) or to collect general usage and aggregated statistical information and detect and prevent fraud. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of the Services.

• A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Web pages.

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number or identifier to you, and relate your site usage information to other information about you, including your Personal Information. These technologies also enable us to recognize you when you access our Site using different Web browsers and different computers or devices.

 

Social Networking

Insofar as we maintain a presence on social networking and blogging platforms, this Policy applies to our use of information you submit to us there, but it does not apply to what those third party platforms do with your information. Those platforms have their own privacy policies, and we encourage you to read them.

 

How is your information used?

We or our service providers may use the Personal Information we collect from and about you, including User-Provided Information, Site Usage Information and/or any information collected through Social Networking sites, to perform the following business functions:

 

• enabling users to use our Services and its features

• administering the Services and your account with us, including verifying approved access to the Restricted Website

• responding to your requests, questions, and concerns

• market research and better understanding our audience

• developing new features and offerings on the Services

• increasing the functionality and user-friendliness of the Services

• protecting our rights and property

• recovering debt and preventing fraud

• other purposes disclosed when Personal Information is submitted to us

To perform the above functions, we may match information collected from you through different means or at different times, including both Personal Information and Site Usage Information, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Services, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.

 

Do we share Personal Information and Site Usage Information with others?

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Yes. We may share the information we collect on the Services with others for a variety of reasons. In addition to the kinds of information sharing you might expect, such as sharing with third parties who need your information in order to provide services to us (or on our behalf), we may share your information:

• when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law,

• in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business. In addition, we may share non-personally identifiable Site Usage Information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.

 

Do Not Track Disclosures

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Some web browsers may transmit “do-not-track” (DNT) signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not change our tracking practices (which are explained in more detail under “SITE Usage Information” above) in response to DNT settings in your web browser.

Our third party partners, such as Google Analytics, collect information about your online activities over time and across our Services and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. We utilize Google Analytics for our web analytics and you can opt out of your Services usage data being included in our Google Analytics reports by visiting https://tools.google.com/dlpage/gaoptout

 

Security

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While we endeavor to protect the security and integrity of sensitive Personal Information collected via the Services, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely error-free or safe from intrusion by others, such as hackers. We do not warrant or represent that any Service’s level of security meets or exceeds any particular standard, and any information you submit via the Services is at your own risk.

If you correspond with us by e-mail, text message, or using Web forms like a “contact us” feature on our Services, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

If at any time during or after our relationship we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you. We will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us. 

 

“Linked-To” Web Sites

The Services may contain links, banners, widgets or advertisements that lead to other Web sites. We are not responsible for these other sites, and so their posted privacy policies (not this Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of each Web site visited after leaving the Services to learn about how your information is treated by others.

 

Data Subject Rights Under European Law

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If you are a natural person (a “Data Subject”), you may have certain rights in addition to those described elsewhere in this Policy. These rights are in relation to your Personal Information, and include the right to be informed about the collection and use of your Personal Information, as outlined in this Policy.

Such rights may also include, where certain conditions are met:

• the right to request access to the Personal Information we hold about you,

• the right to have inaccurate information about you amended or updated,

• the right to object to processing of Personal Information about you,

• the right to withdraw consent at any time (where relevant),

• the right to have Personal Information about you erased or to restrict processing in certain limited situations,

• the right to data portability and to request the transmission of Personal Information about you to another organization,

• the right to object to automated decision making that materially impacts you, direct marketing, and processing for research or statistical purposes, and

• the right to lodge complaints with applicable data supervisory authorities.

As a Data Subject, you should use the contact information below to get more information and/or to make a formal request. We will endeavor to keep the Personal Information we store about you reasonably accurate and up-to-date by enabling you to correct it by request.

You should notify us if any of your Personal Information changes or if you become aware of any inaccuracies in the Personal Information we hold about you.

 

Legal Basis for Processing Personal Information

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We use the Personal Information collected from Data Subjects where it is necessary for us to perform under an agreement with you (if we have one with you) and for our legitimate interests where your interests and fundamental rights as a Data Subject do not override those interests. For example, in order for us to operate our website, it is necessary for us to collect certain data about you to improve your user experience and manage the Services. In addition, we use this Personal Information to send informational messages to you to the extent allowed by applicable law.

Disclosure & Retention of Data Subjects’ Personal Information

We will take reasonably necessary steps to ensure that where Personal Information of Data Subjects is shared with third parties, it is treated securely and in accordance with this Policy and applicable laws.

We will endeavor not to keep Personal Information in a form that allows a Data Subject to be identified for any longer than is reasonably necessary for achieving the permitted purposes. At the end of the applicable retention period, we may destroy, erase from our systems, or anonymize Personal Information as part of such efforts. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Data Subject’s Personal Information, the purposes for which we process the Data Subject’s Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

Storage & Transfer of Data Subjects’ Personal Information

 

We maintain physical, electronic and procedural safeguards designed to protect Data Subjects’ Personal Information, prevent unlawful or unauthorised processing of Personal Information, and prevent unauthorized disclosure of, or accidental loss of, or damage to, such information.

We may process Personal Information in, and transfer Personal Information to, countries that may not guarantee the same level of protection for Personal Information as the country in which Data Subjects reside.

Personal Information will also be processed by staff who work for us and operate outside the European Economic Area. This includes staff engaged in, among other things, the provision of administration and support services. All such staff are subject to reasonably appropriate confidentiality and security obligations.

We restrict access to non-public Personal Information about Data Subjects to those of our employees and agents who need to know the information to enable us to provide services.

We will only transfer Personal Information to third party service providers if they agree to comply with the physical, electronic and procedural safeguards described above, or if they put in place adequate measures themselves.

 

Changes to this Privacy Policy

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We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page with a new “Effective Date.” In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. In some cases, we may request your consent to the changes.

 

Contact Us

If you have any questions or comments regarding our privacy practices, you may contact us at:

Email: privacy@boundarystreetcapital.com

 

Telephone: 703-837-6026

 

Mailing address:

204 South Union Street

Alexandria, VA 22314

 

Effective Date: January 1, 2024