Last Updated and Effective As Of: December 13, 2018
Personal Information We Collect
- Fill out a form on the Site;
- Sign-up to a feature that we offer on the Site and you provide your personal information in connection with that feature;
- Attend an event that we have organized;
- Communicate with us (for example, on a social media platform or by sending us an email;
- Provide personal information to us on Corridor Capital’s social media pages; or
- Voluntarily provide personal information to us through the Site.
We also may obtain personal information about you from third parties acting on our behalf, such as the frequency with which you visit our Site and the links you use, including in order to enhance the utility of our Site.
Personal Information We Obtain By Automated Means
Server Logs: We use server logs, which automatically record certain information from Site visitors, such as the number and frequency of visits, as well as IP addresses, time spent on the Site and pages viewed.
Cookies: Cookies are small text files that store information, such as your preferences and account settings, on the hard drive of your computer. Similar to many websites, if you have enabled cookies in your browser, Corridor Capital, independently and through enabled third-party tools and programs, has the ability to collect certain technical information, such as originating IP address, browser type, browser language, how a user got to the Site (i.e., the URL of the last website the user visited), the next website the user visits, what pages are visited, the length of each site visit, and the date and time of the user’s visit. This information helps us track trends and improve user experiences when visiting the Site. Internet browser settings may be modified to have your computer warn you each time a cookie is being sent, or you can choose to disable all cookies. If you choose to disable cookies, the Site may not work as it is intended. If you continue using the Site without changing your settings, we will assume that you have accepted receipt of all cookies on the Site.
Social Media Widgets: The Site includes, or may in the future include, social media functions, such as the Blog, Twitter, LinkedIn, and Facebook widgets. These widgets may collect information about which pages you visit on the Site and the IP address of the device you use to connect to the Internet. The widgets may also set a cookie to ensure the features are functioning properly.
Social media functions and widgets are hosted either by a third party or directly on the Site. Your interactions with the social media functions and widgets located on the Site are governed by the privacy policies of the companies that provide them. If you use any of the social media functions or widgets on our Site, we strongly suggest you review the privacy policies of the companies that provide those functions and features.
How We Use the Information We Collect
We may use personal information that you provide to us to respond to your inquiry, for example, to contact you about your request, ask a question, provide announcements about future events and opportunities, conduct surveys, and contact you for other reasons related to offering and improving our services.
In addition to the uses discussed above, we may also use the personal information you provide on our Site to:
- operate, evaluate, and improve our business;
- administer the Site;
- develop new products and services;
- perform market research;
- analyze our products, services, and websites;
We use the personal information for the purposes described above because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal information about you.
Disclosure of Information
We may share your personal information with our affiliates, portfolio companies and our advisors, for the purposes described in this Notice.
We may share personal information with third-party service providers to facilitate our services and perform functions on our behalf, such as sending postal mail and e-mail and providing us with technical, analytical and hosting functions for the Site. As required by applicable law, we do not permit them to use or disclose personal information only as necessary to perform services on our behalf or comply with applicable legal requirements.
In addition, we may disclose personal information about you (a) if we are required to do so by law or legal process, for example due to a request from a law enforcement authority, a subpoena, court order or discovery request; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) when we believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts and privacy) or may expose us to liability; (d) in connection with the investigation of suspected or actual fraudulent or other illegal activity; and (e) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
Protection of Personal Information
The security of your personal information is important to us. We employ technical, administrative and physical security measures to protect any personal information you provide through the Site from unauthorized access or use. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. You use the Site and send us such information at your own risk.
Other Websites, Links and Third-Party Technologies
Please be advised that the virtual data room portals that can be accessed through links on the Site by investors in funds managed by Corridor Capital are maintained by third-party service providers, whose privacy policies apply to those portals and to the personal information you provide in activating and using your account to access those portals; the third party service providers inform us of who has access to the portals they operate and each user’s usage of the portals. We encourage you to review those privacy policies.
Transfers of Your Personal Information
If you are located in the European Economic Area (“EEA”), we comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA and Switzerland. In all such cases, we will only transfer your personal information if:
- The country to which the personal information will be transferred has been granted a European Commission adequacy decision;
- The recipient of the personal information is located in the U.S. and has certified to the US-EU Privacy Shield Framework; or
- We have put in place appropriate safeguards in respect of the transfer, for example the EU Model Contracts.
If you are located in the EEA you also may request a copy of the safeguards that we have put in place in respect of transfers of personal information by contacting us as described in the How to Contact Us section below.
How Long We Keep Your Personal Information
The time period for which we keep personal information depends on the purpose for which we collected it. In all cases we keep it for as long as necessary to fulfil the purposes for which we collected it. We will then delete the personal information, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).
Subject to any applicable legal requirements, we typically retain personal information as follows:
- Personal information you provide to us through our Site: we keep this personal information for as long as necessary in order to fulfil the purpose for which you provided it to us, and for a short further period in case you send us further requests.
- Personal information you provide when you sign-up to receive direct marketing communications: we keep most of this personal information for the duration of our relationship with you until you opt-out or we do not have any contact with you for a long period of time.
- Personal information collected for analytics purposes: we keep this personal information for a short period of time necessary for us to carry out the analytics.
- Website logs: we keep Site audit logs, which may contain your personal information, for several months.
If you are located in the EEA or Switzerland, subject to applicable law, you may have the following rights in relation to personal information that we hold about you:
- To request confirmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
- To request that we rectify or update your personal information that is inaccurate, incomplete or outdated;
- To request that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent;
- To request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal information;
- Where you have given us consent to process your personal information, to withdraw your consent; and
- To request that we provide a copy of your personal information to you in a structured, commonly used and machine readable format in certain circumstances.
- To object to certain of our data processing, such as for direct marketing purposes.
If you are located in the EEA and you wish to exercise any of your data protection rights or if you consider that we have processed your personal information in violation of applicable law, please contact us as detailed in the “How to Contact Us” section below.
If you consider that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.
How to Contact Us