Privacy Policy

New Island Capital Management, Inc.
Privacy Policy
Rev. April 2019

This Privacy Policy (this “Policy”) describes the ways in which New Island Capital Management, Inc., a Delaware corporation (“New Island Capital”) collects, uses, and discloses information about you in connection with your access to the website accessed via https://www.newislandcap.com (the “Website”). Throughout this Policy, “you” refers to the individual or entity that is visiting the Website. By accessing the Website, you consent to the use of your information as set forth in this Policy.

  1. This Policy.
    1. Scope. New Island Capital provides you access to the Website, subject to the Website’s Terms of Use. As further described in this Policy, in the course of providing access to the Website, New Island Capital may collect certain information that identifies you or that New Island Capital can link to you (“Personal Data”). New Island Capital does not collect any contact information and will not send you any direct communications.
    2. Changes to this Policy. New Island Capital reserves the right to update this Policy from time to time by posting a new Policy on this page. You are advised to consult this Policy regularly for any changes. Your continued use of the Website after such changes have been made constitutes acceptance of those changes. The last revision date is at the top of this page.
  2. Collection of Information.
    1. Automatically Collected Information. New Island Capital may automatically collect certain technical usage data from your computer or mobile device when you use the Website, such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the Website, and the pages you view immediately before and after you access the Website. This data allows New Island Capital to recognize you and personalize your experience if you return to the Website using the same computer or mobile device, and to improve the Website. New Island Capital may collect this data using “cookies,” which are small text files that the Website saves on your computer or mobile device, or similar technologies that collect web traffic data (“Cookies”). You have choices about how Cookies track your online activities. For further information, see “Cookie Policy” below.
    2. Cross-Site Tracking. New Island Capital does not utilize technical measures in the Website to track your activities across different websites or online services, whether you configure your browser’s Do Not Track feature or otherwise.
  3. Use and Disclosure of Information.
    1. Use. New Island Capital may collect, use, and otherwise process your Personal Data for a number of purposes, including, but not limited to understand how people interact with New Island Capital’s online presence, operate and improve New Island Capital’s online presence, engage third-party service providers (such as hosting providers and analytics and security providers) to assist in operating the Website, detect, prevent, and respond to actual or potential illegal activities, comply with New Island Capital’s legal obligations, respond to legal process or authorized requests for information, and protect New Island Capital’s, your, or others’ rights. The legal basis for New Island Capital’s use of your Personal Data is New Island Capital’s legitimate interests, such as New Island Capital’s interest in improving its services and online content, and/or to comply with a legal obligation, such as a government investigation.
    2. Disclosure. New Island Capital may disclose Personal Data to service providers, such as web hosting and analytics providers, email services, and information technology providers, for the purpose of performing those services on New Island Capital’s behalf. New Island Capital does not sell or rent Personal Data to outside parties for marketing purposes. New Island Capital discloses your Personal Data to third parties or public officials when New Island Capital is legally obliged to do so, and New Island Capital may share anonymized Personal Data as permitted by applicable law.
  4. Storage.
    1. Jurisdiction. Personal Data collected through the Website will be stored in, processed in, and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the Website, you consent to such transfer to, storage in and processing within the United States.
    2. Security. New Island Capital is committed to protecting your Personal Data from unauthorized access, use, or disclosure. The Website and its operators maintain administrative, technical, and physical safeguards designed to protect your Personal Data collected through the Website. However, no information or communication through the Website can be 100% secure, so New Island Capital cannot guarantee the absolute security of information.
    3. Retention. New Island Capital will not retain Personal Data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
  5. Cookie Policy.
    1. Cookies. New Island Capital uses Cookies to enhance your user experience, understand your usage of the Website, and to perform analytics. The provision of your data via Cookies is voluntary except for those Cookies that New Island Capital places on your device because it is necessary for the performance of the Website. For more information on New Island Capital’s general data privacy practices, please see the other sections of this Policy.
    2. Use. Cookies can contain your browser type, search preferences, data relating to which pages of the Website that you have visited, and the date and time of your use. New Island Capital uses Cookies to enable and support security features, prevent fraud, and protect your data from unauthorized access, and to analyze how you use the Website and to monitor site performance. These Cookies help us to identify and fix errors and monitor how you reached the Website.
    3. Third-Party Cookies. New Island Capital uses third-party Cookies from Google Analytics on the Website. Google Analytics tracks unique visitors to the Website, and provides analytics reports showing website usage and referral sources. It also helps determine whether visitors have arrived at the Website via Google marketing campaigns. See https://policies.google.com/privacy for details.
    4. Opting Out. You can control and/or delete cookies as you wish; for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work as intended by New Island Capital.
  6. Your Rights.
    Depending on the circumstances (including where you reside and any other legal obligations New Island Capital may have), your rights regarding your Personal Data may include the following:

    • The right to access your Personal Data, correct any inaccuracies, and request deletion of your Personal Data.
    • The right to object to or request restriction of the processing of your Personal Data.
    • The right to request transfer of your Personal Data to you or to another processor.
    • The right to withdraw any consent you have given to processing of your Personal Data.
    • If you reside in the European Economic Area (EEA), you have the right to make a complaint to the supervisory authority for data protection issues in your country of residence. However, we would appreciate it if you would contact us before involving the supervisory authority.
  7. Children’s Information.
    The Website is not directed to, nor does New Island Capital knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided information without your consent, please contact New Island Capital immediately using the contact information provided below.
  8. Contact Information.
    If you have any questions about this Policy or the collection or use of information about you, please write to New Island Capital at generalcounsel@newislandcap.com or 560 Commercial Street, Suite 400, San Francisco, CA 941111.