Privacy Policy

PRIVACY POLICY

This Privacy Policy describes how 1315 Capital LLC, together with its affiliate companies and managed investment funds (“1315 Capital,” “we” or “us”), collects, uses, and discloses information it collects through our sites (which include https://www.1315capital.com and https://1315capital.altareturn.com) (collectively, our “Sites”). This Privacy Policy also explains your rights related to our collection and retention of your Personal Information. “Personal Information” is information that can be used to identify a person, such as names, addresses, and email addresses. We do not collect any Personal Information from visitors of the Sites except as described in this Privacy Policy.

By visiting the Sites, you acknowledge and accept the practices and policies outlined in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you should not use the Sites.

Links to Third Party Websites and Advertisers

The Site contains links to third party websites. If you follow those links you will leave the Sites. The privacy practices of third party websites are not covered by this Privacy Policy and 1315 Capital is not responsible for the privacy practices or content of other third party websites, including, without limitation, their use of tracking technologies or handling of your Personal Information.

Personal Information We Collect and Use

Information You Provide
We collect information including Personal Information that you affirmatively provide to us through the Sites (including by emailing us). In addition, in order to access certain features of our Sites, such as the Investor Portal, you may be required to login and provide certain personal data and information about yourself (for example, your username, name and password). Such information is considered Personal Information.

Information We Collect Automatically
As you use the Sites, certain information, including Personal Information, may be collected passively, such as your Internet protocol (IP) address and information provided by the browser that you use to visit the Sites. 1315 Capital may also use “cookies,” “pixel tags” and other tracking technologies to enable or enhance functionality on our Sites. 1315 Capital may use ‘session’ cookies (which expire once you close your web browser) and ‘persistent’ cookies (which stay on your computer until you delete them), as well as other similar technologies, for a variety of tasks, for instance, to enhance your browsing experience. Pixel tags in our emails may be used to track your interactions with those messages, such as when you receive, open, or click a link in an email message from us. These technologies also may be used to collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with our Sites and our online ads.

You have the option to set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. Generally, you have the option to disable cookies. However, if you do so certain parts of the Sites may not function as effectively or at all.

How We Use Your Personal Information
We use your Personal Information collected from the Sites for our internal business purposes, including to analyze the performance of the Sites and our business.

We use your Personal Information as necessary to enable us to deliver and support the Sites, to respond to requests that you make, including requests for the performance of technical support or the exercise of your rights, and for quality improvement activities.

We may also use your Personal Information to provide you with notifications related to your use of the Sites as well as newsletters, promotional communications or other similar messaging sent to the email addresses you provide to us. As described below, you may opt-out of receiving promotional communications.

We may create deidentified or anonymized information from Personal Information by excluding information that makes the information personally identifiable to you. We may use this anonymized information for internal business purposes, such as analyzing the usage patterns of our Sites so that we may enhance the Sites and our business. We also reserve the right to use and disclose such anonymized information at our discretion.

Retention
We may retain your Personal Information for as long as we have a business purpose or legal basis to do so.

Disclosure of Personal Information
Except as otherwise stated in this Privacy Policy, we do not disclose to or share your Personal Information collected through the Sites with third-parties, unless you ask or authorize us to do so.

We may provide your Personal Information to third-party service providers and suppliers who work with us or on our behalf to provide you with the Sites and to help us communicate with you.

We may share some or all of your Personal Information collected through the Sites with any parent company, subsidiaries, or other companies under a common control with 1315 Capital LLC (collectively, “Affiliates”) in which case we will require our Affiliates to honor this Privacy Policy.

We may also disclose Personal Information in the following circumstances:

1. In response to subpoenas, or other government request, or as otherwise required to comply with applicable law, court order, judicial or arbitral process;
2. To protect and defend the rights or property of 1315 Capital, the visitors to our Sites, or of third-parties; and/or
3. When 1315 Capital believes such disclosure is necessary to protect our interests or we believe in good faith that the law requires the sharing of your Personal Information.

We do not sell Personal Information, and have not done so for the 12 months prior to the effective date of this policy.

Information Collected from Minors
The Sites are directed to individuals over the age of 18. If you are under the age of 18, you should not provide us with Personal Information. We do not knowingly collect Personal Information from children under the age of 18. If we learn that Personal Information of persons under the age of 18 has been collected via the Sites, we will take appropriate steps to delete such information.

SEC Regulations S-P, S-AM and the Gramm-Leach-Bliley Act
Some government authorities such as the Securities and Exchange Commission and the Federal Trade Commission have adopted rules that require financial institutions, like 1315 Capital, to provide privacy policy notices to their clients. If you are a natural person who invests with us, that notice will govern how we use the Personal Information collected pursuant to such notice.

Security Safeguards
1315 Capital has put in place commercially reasonable and appropriate physical, electronic, and managerial procedures to safeguard and secure the information it collects pursuant to this Privacy Policy. However, no company, including 1315 Capital, can fully eliminate security risks associated with Personal Information. Your use of the Sites is at your own risk.

Your Rights Under this Privacy Policy
You may access your Personal Information that we hold by contacting us at the address provided below. If you believe the Personal Information we have about you is incorrect, you may request to have it corrected. You may also ask us to restrict or suspend the processing of your Personal Information in certain circumstances. Please note that any Personal Information that we have copied may remain in back-up storage for some period of time after your request, and that if you delete certain information you may not be able to use our services in the future without re-submitting such information. Also, please note that we will maintain Personal Information in our database whenever we are required to do so by law or regulation. If you wish to raise a complaint about how we have handled your Personal Information, or if you would like to have your Personal Information transferred, or if you have any other questions about this Privacy Policy, you may contact us at the address provided below.

California Residents
The California Consumer Protection Act (“CCPA”) provides California residents with specific rights regarding their personal information. This section of the Privacy Policy describes those CCPA rights and explains how to exercise those rights if you are a resident of the state of California. The categories of personal information that we collect from you can be found in the “Personal Information We Collect and Use” section above.
The business or commercial purposes for which we use the categories of Personal Information we collect can be found in the “How We Use Your Personal Information” section above.

Your California Rights under CCPA
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (“Right to Know”). You have the Right to Know (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting that personal information; (iv) the categories of third parties with whom we share that personal information; and (v) the specific pieces of personal information we collected about you.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (“Right to Delete”). Once we receive and confirm your verifiable request, we will delete your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us to: (i) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another party to exercise their free speech rights, or exercise another right provided for by law; (v) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (vi) comply with a legal obligation; or (vii) make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights
To exercise your Right to Know or Right to Delete, please submit a verifiable request to us by sending an email to ir@1315capital.com or call 215-662-1315.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Information. The verifiable request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or that you have been authorized to act as the authorized representative of the person whose Personal Information we have collected; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We may need to contact you to request additional information in order to verify you are the person about whom we collected personal information or that you are an authorized representative. We will not use any information provided as part of a request, including any contact information you provide or that we request in order to respond to or verify a request, for any purpose other than to respond to or verify your request.

We will make an effort to respond to your verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing either by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period before our receipt of the verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it 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 before completing your request.

Sale of personal information
Pursuant to the definition of “sell” under the CCPA and current guidance, we do not engage in such activity and have not engaged in such activity in the past twelve months.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights by (i) denying you service; (ii) charging you a different price or rates for services; or (iii) providing you a different level of quality of service.
For additional information regarding your rights under the CCPA, or how to exercise them, you may contact us at ir@1315capital.com.

Changes to this Statement
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we may notify you here, by email, by means of a notice on our home page, or by another method we so choose.

Feedback
If you provide feedback about the Sites to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy.

How to Contact Us
To contact us for any purpose listed in this Privacy Policy, including to exercise any of your rights, please contact us at:

ir@1315capital.com

or write to us at

1315 Capital LLC
2929 Walnut Street, Philadelphia, PA 19104
Attention: Compliance

This privacy policy was last updated April 20, 2020.