Crestmoor Capital Partners, LLC (“Crestmoor”) respects the privacy of others.  This PRIVACY POLICY (this “Privacy Policy”) is intended to explain Crestmoor’s privacy practices with respect to the CrestmoorCapital.com website (together with its pages, its features and any mobile versions of the foregoing, the “Site”).  This Privacy Policy is also intended to provide you (together with any person helping you visit, access, register with or use the Site, “you” or “your”) with an overview of the following:

• • the type of information about you Crestmoor collects through the Site;
• • how Crestmoor collects that information;
• • how Crestmoor uses that information;
• • who will have access to that information; and
• • Crestmoor’s security measures for protecting that information.

This Privacy Policy applies to information collected through the Site.  Carefully read this Privacy Policy in its entirety.

You are automatically accepting and agreeing to the most recent version of this Privacy Policy, as well as the Site’s Terms of Use, whenever you visit, access or use the Site or any products or services provided by Crestmoor on or through the Site; and your continuing visit, access or use of any of the forgoing reaffirms your acceptance and agreement in each instance.

As used herein, the term “personal information” means information (including personally identifiable information) that would allow someone to specifically identify you or contact you physically or online (e.g., your name, physical address, telephone number, email address); and the term “non-personal information” means any information other than personal information that Crestmoor may collect from you.

1. 1. A Special Note About Minors.

The Site is a general audience website intended for use by adults.  The Site is not designed or intended to attract, and is not directed to, children under eighteen (18) years of age, let alone children under thirteen (13) years of age.  Crestmoor does not collect personal information through the Site from any person it actually knows to be under thirteen (13) years of age.  If Crestmoor obtains actual knowledge that it has collected personal information through the Site from a person under thirteen (13) years of age, then it will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

Furthermore, if you are under eighteen (18) years of age, then you (or your parent or legal guardian) may at any time request that Crestmoor remove content or information about you that is posted on the Site.  Please submit any such request (“Request for Removal of Minor Information”) to admin@crestmooradvisors.com, with a subject line of “Removal of Minor Information.”

For each Request for Removal of Minor Information, please state “Removal of Minor Information” in the email or letter subject line, and clearly state the following in the body:

a. the nature of your request;

b. the identity of the content or information to be removed;

c. whether such content or information is found on the Site;

d. the location of content or information on the Site (e.g., providing the URL for the specific web page the content or information is found on);

e. that the request is related to the “Removal of Minor Information”;

f. your name, street address, city, state, zip code and email address; and

g. whether you prefer to receive a response to your request by mail or email.

Crestmoor is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled or incorrectly sent.

Please note that the aforementioned removal does not ensure complete or comprehensive removal of such content or information posted on the Site.

Also, please note that Crestmoor is not required to erase or otherwise eliminate, or to enable erasure or elimination of, such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires Crestmoor to maintain the content or information; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished or reposted by the third party); when Crestmoor anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of Crestmoor’s voluntary practices concerning the collection of personal information through the Site from certain minors, and is not intended to be an admission that Crestmoor is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

1. 2. Categories of Information Collected.

Crestmoor may collect personal and non-personal information about you through the Site.  The categories of such information might include, for example:

• Your name (first, last and/or middle);
• Your company name and/or title;
• Your home and/or business contact information (e.g., mailing address, email address, telephone number, facsimile number);
• Your profession;
• Your relevant work application information (e.g., name, contact information, resume, work experience, employment history, educational history, performance reviews, department name and location, rank, work address), as well as any additional work-related information that you voluntary disclose;
• Your electronic signature;
• Your transactional information (e.g., requests, orders, pricing, payments, purchaser information, comments, ratings, feedback, communications made on or through the Site);
• Your computer, mobile device and/or browser information (e.g., IP address, mobile device ID information, operating system, connection speed, bandwidth, browser type, referring/exit web pages, web page requests, cookie information, hardware attributes, software attributes);
• Information about, and/or information found on, your pages and accounts with third-party websites, networks, platforms, servers and applications (e.g., Facebook, Google Plus, LinkedIn);
• Usage activity concerning your interactions with the Site and/or third-party websites, networks, platforms, servers or applications accessed on or through the Site (e.g., how you accessed the Site, where you go when you leave the Site, number of clicks on a page or feature, amount of time spent on the Site or a page or feature, identity of third-party websites, networks, platforms, servers and applications accessed through the Site);
• Statements or content (e.g., comments, videos, photographs, images), and information about such statements or content, which you submit or publish on or through the Site, or which are accessed via your public or linked social media pages (e.g., Facebook, Google Plus, LinkedIn);
• Your geolocation;
• The name associated with your mobile device;
• The telephone number associated with your mobile device; and/or
• Your mobile device ID information.

1. 3. How Information Is Collected.

Crestmoor might collect personal and non-personal information from you when you visit, access or use the Site or any of its products or services; when you request, register for, order or purchase any products or services on, through or in relation to the Site; when you allow the Site to access, upload, download, import or export content found on or through, or to otherwise interact with, your computer or mobile device (or any other device you may use to visit, access, register with or use the Site) or online accounts with third-party websites, networks, platforms, servers or applications (e.g., your online social media accounts, your cloud drives and servers, your mobile device service provider); or whenever Crestmoor asks you for such information, such as, for example, when you fill out an online survey, questionnaire or contact form, or when you process a payment through the Site.

In addition, if you or a third party sends Crestmoor a comment, message or other communication (such as, by way of example only, email, instant message, letter, fax, phone call, or voice message) about or referencing you or your activities in relation to the Site, then Crestmoor may collect any personal or non-personal information provided therein or therewith.

Crestmoor might also use various tracking, data aggregation and/or data analysis technologies, including, for example, the following:

• Cookies, which are small data files (e.g., text files) stored on the browser or device you use to view a website or message.  They may help store user preferences and activity, and may allow a website to recognize a particular browser or device.  There are several types of cookies, including, for example, browser cookies, session cookies, and persistent cookies.  Cookies may record information you access on one page of a website to simplify subsequent interaction with that website, or to help streamline your transactions on related pages of that website.  Most major browsers are set up so that they will initially accept cookies, but you might be able to adjust your browser’s or device’s preferences to issue you an alert when a cookie is downloaded, or to block, reject, disable, delete or manage the use of some or all cookies on your browser or device.
• Flash cookies, which are cookies written using Adobe Flash, and which may be permanently stored on your device.  Like regular cookies, Flash cookies may help store user preferences and activity, and may allow a website to recognize a particular browser or device.  Flash cookies are not managed by the same browser settings that are used for regular cookies.
• Retargeting pixels, which are cookie-based technologies that might follow you across the web.
• Web beacons, which are pieces of code embedded in a website or email to monitor your activity on the website or your opening of the email, and which can pass along information such as the IP address of the computer or device you use to view the website or open the email, the URL page on which the web beacon is located, the type of browser that was used to access the website, and previously set cookie values.  Web beacons are sometimes used to collect advertising data, such as counting page views, promotion views or advertising responses.  Disabling your computer’s, device’s or browser’s cookies may prevent some web beacons from tracking or recording certain information about your activities.
• Scripts, which are pieces of code embedded in a website to define how the website behaves in response to certain key or click requests sent by the user.  Scripts are sometimes used to collect information about the user’s interactions with the website, such as the links the user clicks on.  Scripts are often times temporarily downloaded to the user’s computer or device from the website server, active only while the user is connected to the Site, and deactivated or deleted when the user disconnects from the Site.
• Analytic tools and services, which are sometimes offered by third parties, and which track, measure and/or generate information about a website’s or program’s traffic, sales, audience and similar information, and which may be used for various reasons, such as, for example, statistical research, marketing research, content ratings research, and conversion tracking.  Google Analytics, HubSpot and Facebook Pixel are examples of these types of technologies.
• Other third-party data tracking or analytic technologies (e.g., deep linking, eTags, device fingerprinting or cross-device tracking).

Please be advised that if you choose to block, reject, disable, delete or change the management settings for any or all of the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies, then certain areas of the Site might not function properly.

By visiting, accessing, registering with or using the Site, you acknowledge and agree in each instance that you are giving Crestmoor permission to monitor or otherwise track your activities on the Site, and that Crestmoor may use the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies.

1. 4. Use of Information Collected. 

Crestmoor may use the personal and/or non-personal information it collects from you through the Site in a variety of ways.  Examples of those uses might include, for example:

• Place, fulfill, process and/or track your requests;
• Facilitate and maintain your access and use of the Site and/or its products and services;
• Facilitate and maintain your movement throughout the Site;
• Facilitate and maintain your accounts and profiles with Crestmoor;
• Provide customer service;
• Operate the Site and its products and services;
• Send you communications like, for example, administrative emails, answers to your questions and updates about the Site;
• Provide you with information about Crestmoor, its parents, its subsidiaries, its affiliates and/or their respective businesses, products and services;
• Provide you with customized content and services, including advertising and promotional information (e.g., targeted ads, retargeted ads), recommendations for content you might like, and cross-app or cross-site functionality across multiple third-party websites and mobile apps;
• Provide you with information about third-party businesses, products and/or services;
• Improve the Site and/or its content, products and services;
• Improve the products, services, marketing and/or promotional efforts of Crestmoor, its parents, its subsidiaries and/or its affiliates;
• Create new products, services, marketing and/or promotions for Crestmoor, its parents, its subsidiaries and/or its affiliates;
• Market the businesses, products and/or services of Crestmoor, its parents, its subsidiaries and/or its affiliates;
• Help personalize user experiences with the Site and/or its products and services;
• Analyze traffic to and through the Site;
• Analyze user behavior and activity on or through the Site;
• Conduct research and measurement activities for purposes of product and service research and development, advertising claim substantiation, market research and other activities related to Crestmoor, its parents, its subsidiaries, its affiliates, the Site and/or its features, products and services;
• Monitor the activities of you and others on or through the Site;
• Create device fingerprints and profiles about the possible relationships among different browsers and devices;
• Create consumer profiles, which may combine your personal or non-personal information from the Site with your personal or non-personal information from another source or service;
• Protect or enforce Crestmoor’s rights and properties; and/or
• Protect or enforce the rights and properties of others (which may include you), assuming that Crestmoor believes it has an obligation to do so.

Crestmoor reserves the right to use your personal and non-personal information when:

• Required by applicable law, court order or other governmental authority (including, without limitation and by way of example only, in response to a subpoena or other legal process); and/or
• Crestmoor believes in good faith that such use is otherwise necessary or advisable (including, without limitation and by way of example only, to investigate, prevent, or take legal action against someone who may be causing injury to, interfering with, or threatening the rights, obligations or properties of Crestmoor, a user of the Site, which may include you, or anyone else who may be harmed by such activities or to further Crestmoor’s legitimate business interests).

1. 5. Sharing of Information Collected.

Crestmoor reserves the right, but not the obligation, to share your personal information with the following:

• • Crestmoor’s employees, independent contractors, agents and administrators;
• • Crestmoor’s accountants, financial advisors and legal advisors;
• • Crestmoor’s parents, subsidiaries and affiliates;
• • Service providers and other third parties who help Crestmoor provide, manage, administer, maintain, monitor, distribute, operate or facilitate the Site, who help Crestmoor develop, market or provide its products and services, or who help further Crestmoor’s business efforts (e.g., web hosting companies, website administrators, support services companies, data analysis companies, credit card or other payment processing companies, advertising partners), as needed in order for them to perform such services;
• • Law enforcement or other governmental entities in response to (a) what Crestmoor believes to be an allegation or suspicion of illegal activity; (b) a request relating to a civil or criminal investigation, an allegation or suspicion of illegal activity, a subpoena, or a court order; or (c) any other activity that may expose Crestmoor to liability if it does not act or comply; 
• • Any third parties who Crestmoor believes are necessary to help or allow Crestmoor to protect and enforce its rights and properties, including, without limitation, to enforce its rights under the Site’s Terms of Use or any other agreements it has with you, and to protect and enforce its intellectual property rights; and/or
• • Any third parties who Crestmoor believes are necessary to help or allow Crestmoor to protect the rights and properties of others (which may include you), assuming that Crestmoor believes it has an obligation to do so.

Crestmoor also reserves the right to share your personal information with third parties in connection with or as a result of any potential or actual merger, acquisition or other event involving a change in ownership or control of Crestmoor or Crestmoor’s business (whether by sale of assets, merger, stock purchase or otherwise).

Crestmoor does not limit the ways in which it might use or share non-personal information – and Crestmoor reserves the unencumbered right, but not the obligation, to use or share non-personal information – because non-personal information does not identify you.  For example, Crestmoor may freely share non-personal information with its parent, subsidiary and affiliated companies, its vendors, its representatives and its customers, as well as with other individuals, businesses and government entities.

1. 6. Data Retention.

Crestmoor may retain your personal information and non-personal information for as long as it believes necessary.  Crestmoor may dispose of or delete any such personal information or non-personal information at any time, except as set forth in any other agreement or document executed by both you and Crestmoor concerning the same or as required by law.

1. 7. Third Party Applications and Networks.

The Site and/or any communications sent through or as a function of the Site might contain links to third-party websites, networks, platforms, servers and/or applications.  Third-party websites, networks, platforms, servers and/or applications might also contain links to the Site.

In addition, you might have the opportunity to access the Site using your online user accounts with certain third-party websites, networks, platforms, servers or applications, which might be subject to separate privacy policies pertaining to those third-party websites, networks, platforms, servers or applications.  Crestmoor might also collect information from those third-party websites, networks, platforms, servers or applications (such as, for example, your name, gender, date of birth and personal interests, when you “like” or click links provided by or through those third-party websites, networks, platforms, servers, or applications and other information available through your online account or page with those third-party websites, networks, platforms, servers or applications).

Moreover, Crestmoor might permit third parties to use their own tracking, data aggregation and/or data analysis technologies like the ones described above (e.g., third-party cookies).

To the fullest extent permitted by law, Crestmoor is not responsible for, and you hereby release Crestmoor from any and all liability which may arise from, such third-party websites, networks, platforms, servers and applications (including, without limitation, the privacy policies and practices of such third-party websites, networks, platforms, servers and applications).  It is your responsibility, and your responsibility alone, to carefully read, accept and comply with any and all relevant terms of use, waivers, and privacy policies associated with those third-party websites, networks, platforms, servers and applications.

1. 8. Security.

Crestmoor will implement security measures to help protect any personal information Crestmoor may decide to collect through the Site.  For example, Crestmoor may implement measures to encrypt the transmission of information through the Site by using secure socket layer (SSL) technology.

Regardless of the foregoing, please observe that “perfect” or “100%” security does not exist on the Internet.  Therefore, your access and use of the Site, and your opening of any communications sent through or as a function of the Site, are done at your own risk.

To help maintain the security of your personal information, Crestmoor asks that you please notify it immediately of any unauthorized visit, access or use of the Site. 

1. 9. Retention, Review, and Change of Information Collected.

You may request at any time that Crestmoor provide you with an opportunity to review and change your personal information collected through the Site, if any, or to no longer use your personal information to provide you with any products or services.  Please submit any such request (“Request Concerning Personal Information”) to admin@crestmooradvisors.com, with a subject line of “Your Personal Information.”

For each Request Concerning Personal Information, please state “Your Personal Information” in the email or letter subject line, and clearly state the following in the body:

a. the nature of your request;

b. that the request is related to “Your Personal Information”;

c. your name, street address, city, state, zip code and email address; and

d. whether you prefer to receive a response to your request by mail or email.

Crestmoor is not responsible for any Request Concerning Personal Information that is incomplete, incorrectly labeled or incorrectly sent.  You are solely responsible for the accuracy and content of your personal information, and for keeping your personal information current and correct.

1. 10. Your California Privacy Rights.

If you are a resident of the State of California and Crestmoor has an established business relationship with you, then, pursuant to Section 1798.83 of the California Civil Code, you have the right to request the following at any time:  (a) information from Crestmoor free of charge regarding the manner in which Crestmoor shares certain personal information collected through the Site with third parties who use such information for direct marketing purposes; and (b) the discontinuation (or opt-out) of Crestmoor’s sharing of such information with such third parties.  Please submit any such request (“California Privacy Rights Request”) to  admin@crestmooradvisors.com, with a subject line of “Your California Privacy Rights.”

For each California Privacy Rights Request, please state “Your California Privacy Rights” in the email or letter subject line, and clearly state the following in the body:

a. the nature of your request;

b. that the request is related to “Your California Privacy Rights”;

c. your name, street address, city, state, zip code and email address; and

d. whether you prefer to receive a response to your request by mail or email.

Crestmoor is not responsible for a California Privacy Rights Request that is incomplete, incorrectly labeled or incorrectly sent.  You are solely responsible for the accuracy and content of your personal information, and for keeping your personal information current and correct.

Further, Crestmoor does not respond to “do not track” (DNT) signals.

Finally, as explained further above, Crestmoor does not authorize third parties to collect your personal information when you use the Site, except as expressly stated in this Privacy Policy.  To the fullest extent permitted by law, Crestmoor is not responsible for, and you hereby release Crestmoor from any and all liability which may arise from, such third parties’ unauthorized collection of your personal information.

1. 11. Modifications of this Privacy Policy.

Crestmoor may supplement, amend, or otherwise modify this Privacy Policy at any time without notice to you.  Such supplements, amendments and other modifications will be posted on this or a similar page of the Site, and shall be deemed effective as of their stated effective or modification date.  It is your responsibility to carefully review this Privacy Policy each time you visit, access, register with or use the Site.

Again, by visiting, accessing, registering with or using the Site, you are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as the most-recent version of the Site’s Terms of Use, and your continuing visit, access, registration with or use of the Site reaffirms your acceptance and agreement in each instance.

1. 12. Severability.

If any term or condition of this Privacy Policy is deemed invalid or unenforceable by a court of law with binding authority, then the remaining terms and conditions shall not be affected, and the court shall reform the invalidated or unenforceable term or condition to the maximum extent permitted under the law and consistent with the intent of this Privacy Policy.

1. 13. Contact Us.

Please direct any questions you may have about this Privacy Policy to admin@crestmooradvisors.com, with a subject line of “Privacy Policy.”  The foregoing contact information may change from time to time by supplementation, amendment, or modification of this Privacy Policy.

1. 14. International Users.

For any of the above purposes and in view of Crestmoor’s global operations, you agree that Crestmoor may transfer some or all of your personal information, your non-personal information and/or other data to countries outside your resident jurisdiction, and may process and/or store such information in the United States of America.  You agree and recognize that countries outside of your jurisdiction may not have as comprehensive data protection laws as those existing in your resident jurisdiction.  For more information please contact Crestmoor in the manner described in section 14 above.

1. 15. Effective Date.

This Privacy Policy is dated effective as of May 1, 2018.