Links to Third Party Websites and Advertisers
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.
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
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 also disclose Personal Information in the following circumstances:
- In response to subpoenas, or other government request, or as otherwise required to comply with applicable law, court order, judicial or arbitral process;
- To protect and defend the rights or property of 1315 Capital, the visitors to our Sites, or of third-parties; and/or
- 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
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 firstname.lastname@example.org 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.
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 email@example.com.
Changes to this Statement
How to Contact Us
or write to us at
1315 Capital LLC
2929 Walnut Street, Philadelphia, PA 19104