Effective as of November 3, 2023.

Introduction

This “Privacy Policy” describes the privacy practices of Vision Ridge Partners, LLC and our subsidiaries and affiliates (collectively, “VRP”, “we”, “us”, or “our”) in connection with the www.vision-ridge.com website, (collectively, the “Website”), and the rights and choices available to individuals with respect to their personal information. VRP may provide additional or supplemental privacy policies and/ or notices to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies and/ or notices will govern how we may process the information in the context of the specific product or service.

You do not need to take any action as a result of this Privacy Policy, but if you are located in the European Union (“EU”), European Economic Area (“EEA”) and United Kingdom (“UK”), you should also refer to our Notice to European and UK Users below, and if you are a resident of California please refer to our Notice to California Users below for additional rights specific to California residents.

Table of Contents

·         Personal Information We Collect
·         How We Use Your Personal Information
·         How We Share your Personal Information
·         Your Choices
·         Security practices
·         International data transfers
·         Children
·         Changes to this Privacy Policy
·         How to Contact Us
·         Notice to European Users
·         Cookie Policy

Personal Information We May Collect

Personal information you provide to us, or that we may collect from you, through the Website includes:

• Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional title and company name.
• Registration information, such as information that may be related to a service or an event you register for.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Demographic Information, such as your city, state, country of residence, and postal code.
• Usage information, such as information about how you use the Website and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Website.
• Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.

Cookies and Other Information Collected by Automated Means 
The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Website, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

 See our Cookie Policy for more information.

Why We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy:

To operate the Website. We may use your personal information to:

• provide, operate and improve the Website
• provide you with information about our products and services
• establish and maintain your user profile on the Website
• communicate with you about the Website, including by sending you announcements, updates, security alerts, and support and administrative messages
• communicate with you about events or contests in which you participate
• understand your needs and interests, and personalize your experience with the Website and our communications
• provide support and maintenance for the Website
• respond to your requests, questions and feedback

For research and development. We analyze use of the Website to analyze and improve the Website and to develop new products and services, including by studying user demographics and use of the Website.

To send you marketing and promotional communications. We may send you VRP-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Website; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. 

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Website and promote our business. 

How We Share your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Website providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Website (such as customer support, hosting, analytics, email delivery, marketing, database management services and other IT providers). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose. We also make sure that anyone who provides such a service to or for us enters into an agreement with us that meets our standard of data security.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above. 

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your Choices

In this section, we describe the rights and choices available to all users. Users who are located within the EU, EEA or UK can find additional information about their rights below. Users who are located within California can find additional information about their rights below.

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at compliance@vision-ridge.com. You may continue to receive service-related and other non-marketing emails.

Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Website and third party websites. For more details, see our Cookie Policy.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Website to you or perform our contract with you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will make you aware of this at the time of collection of your personal information or through other appropriate means.

Security Practices

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect from you, which includes procedures for managing any suspected or actual data breach or other data security incident. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Data Transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country. 

Users located in the EEA, EU or UK should read the important information provided below about transfer of personal information from the EEA, EU or UK to third countries.

Children 

The Website is not directed to, and we do not knowingly collect personal information from, anyone under the age of 13.  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Website. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Website.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Website (or as otherwise indicated at the time of posting). In all cases, your continued use of the Website after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to compliance@vision-ridge.com.

Notice to European and UK Users

The information provided in this “Notice to European and UK Users” section applies only if your provision, or our collection, of your personal information under this Notice to European and UK Users is subject to the General Data Protection Regulation (EU) 2016/679 (the “EU GDPR”) and the UK equivalent of the EU GDPR (the “UK GDPR”) (the “EU-UK Privacy Laws”).

If you have any questions regarding our use of your personal information, or this Notice to European and UK Users, please contact us at compliance@visionridge.com.

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by EU-UK Privacy Laws.

Controller. Vision Ridge Partners, LLC is the controller of your personal information covered by this Notice to European and UK Users for the purposes of EU-UK Privacy Laws. 

Personal information we collect. Please refer to the “Personal Information We May Collect” section in the Privacy Policy above for further details regarding the personal information we collect about you and how we collect it.  

Why we use your personal information and our legal bases. Our purposes for processing your personal information, and the legal bases we rely on for processing your personal information under this Notice to European and UK Users are described in the table below. Note that we may process your personal information on more than one legal basis depending on the specific purpose for which we are using your personal information.

Processing purpose (click link for details) Details regarding each processing purpose listed below are provided in the Privacy Policy in the section titled “Why We Use Your Personal Information”.	Legal basis
To operate the Website	Processing is necessary to perform our contract with you that governs our provision of the Website.    If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Website you access and request.
For research and development	We process your personal information for research and development purposes based on our legitimate interest in operating our business and our Website. We do not use your personal information for this activity where our legitimate interest is overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To send you marketing and promotional communications	We process your personal information for marketing and promotional purposes based on our legitimate interest in operating our business. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with law	We process your personal information to the extent necessary to comply with our legal obligations.
For compliance, fraud prevention and safety	We process your personal information for compliance, fraud prevention and safety purposes based on our legitimate interest in operating our business. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
With your consent	We process your personal information where we have your consent to do so. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Website.
To create anonymous, aggregated or de-identified data	We remove personal identifiers from your personal information to create anonymous, aggregate or de-identified data based on our legitimate interests in improving the Website, promoting our business and operating our business.

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where the new purpose is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Special categories of personal information. We do not deliberately collect or solicit any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we deliberately collect or solicit any personal information about criminal convictions and offences.

We ask that you not provide us with any special categories of personal information on or through the Website, or otherwise to us.

Choosing not to share your personal information. Please refer to the section titled “Choosing not to share your personal information” of our Privacy Policy.

Automated decision-making. No solely automated decision making, including profiling, is used when processing your personal information.

Marketing Communications. Please see the information on marketing included in the sections of our Privacy Policy titled, “Why We Use Your Personal Information” and “Your Choices”.

Security. Please see the section of our Privacy Policy, titled, “Security Practices”.

Retention. We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. 

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 your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Recipients of your personal information. We may disclose your personal information to the categories of third party recipients described in the section of our Privacy Policy titled, “How We Share Your Personal Information”.

Your rights
EU-UK Privacy Laws give you certain rights regarding your personal information. In summary, you may ask us to take the following actions in relation to your personal information that we hold:

• Access. You have the right to ask for a copy of the personal information that we hold and process about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the personal information you have requested.
• Correct. You have a right to request that we update or correct inaccuracies in your personal information that we hold and process about you.
• Delete. If you think that we shouldn’t be holding or processing your personal information any more, you may request that we delete your personal information. Please note that this may not always be possible due to our legal obligations.
• Portability. If you wish to transfer the personal information that we hold and process about you on the legal ground of contractual necessity to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
• Restrict. You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal information for the purposes for which it was collected, but you still need your personal information to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
• Object. You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
• Withdrawal of consent. If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose not specified in this Notice to European and UK Users, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

You may submit these requests by email to compliance@vision-ridge.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. 

If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction:

• the UK GDPR and/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us; or
•  the EU GDPR, please contact your local supervisory authority in particular in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint. You can find your data protection regulator here. 

Cross-border data transfer
If we transfer your personal information out of the EEA, EU and/or UK to a country not deemed by the European Commission or UK Secretary of State to provide an adequate level of protection to personal information, the transfer will be performed in accordance with EU-UK Privacy Laws, which may include:

• entering into the European Commission’s standard contractual clauses, the UK International Data Transfer Addendum to the European standard contractual clauses, the UK International Data Transfer Agreement, or Binding Corporate Rules, as applicable;
• Transferring your personal information pursuant to your consent; or
• As otherwise permitted by applicable EU-UK Privacy Laws.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA, EU and/ or UK.