LAST UPDATED: OCTOBER 12, 2022
A. THE TYPES OF INFORMATION WE COLLECT
In order to access certain services provided via the Website or to request certain information from us via the Website, you may be required to provide information such as your name, postal address, e-mail address, telephone number, or other information about yourself. You may also be required to provide a username and password to access certain features. If you choose to not provide us with information, you might not be able to access to certain information and services on the Website.
We may also collect information about you automatically. For example, when you visit the Website, we may collect your IP address, your browser type, your operating system, the pages you view on the Website, the pages you view immediately before and after you access the Website, and the search terms you enter on the Website.
We collect this information using cookies. (Cookies are small files that a website sends to your computer or device while you are viewing the website.) A more detailed description of cookies, is described in Section C below.
The Website may also use other technical methods to track visitor usage, including web beacons. (“Web beacons” are small pieces of data that are embedded in images on the pages of a website.) We use these technical methods to analyze the traffic patterns on the Website, such as the frequency with which our users visit various parts of the Website. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send visitors to the Websites to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails.
3. Personal Information
“Personal Information” means information, regardless of the media in which it is contained, that is or can be uniquely associated with an identified or identifiable individual, such as name, email address or phone number, account number or account information.
Lafayette Square will collect Personal Information about you through our Website or other means when you submit such information (through our website, information request, or the Contact Us page). For example, you may provide your name, company name, address, institution, city, state, zip/postal code, country, email address, phone number, fax number, and any other information that you choose to provide to us in your subject line and message.
4. Additional Information Collection Practices
The Website may contain links to websites operated by third parties. Should you choose to visit any of these third-party sites, you should review those sites’ privacy policies to ensure you understand and are comfortable with their practices concerning your information. We disclaim any responsibility for the privacy policies and information practices of any third-party website (whether or not such site is linked on or to the e Website). These links are provided to you for convenience purposes only, and you access them at your own risk.
We may link the information that we collect automatically with the information you provide us. And we may combine the information we collect online with information we collect offline or that is collected by third parties.
5. Investor Information
Registered investors and representatives of investors access investor portals, directly through third party links and not through our Website.
Where you sign up to receive email notifications from us on our Website, we will send the communications that you have requested (including information about corporate events, press releases, presentations and company documents). You can opt-out of receiving such communications at any time by contacting us as detailed under Section 10 below.
B. HOW WE USE THE INFORMATION WE COLLECT
Gathering And Use of Technical Usage and Personal Information
Like most website operators, we gather technical usage information that web browsers, depending on their settings, make available. As it is in our legitimate interest to be responsive to you and to ensure the proper functioning of our products and organization, we will use the information collected from our users to:
- personalize our Website for you to ensure content from the Website is presented in the most effective manner for you and your device;
- allow the user to navigate or browse through the Website quickly and efficiently;
- monitor and analyze trends, usage and activity in connection with our Website and services to improve the Website;
- administer the Website and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
- protect our rights, your rights and the rights of others;
- investigate and respond to any complaints,
- comply with legal obligations;
- measure and understand the effectiveness of the content we serve to you and others, including developing reports regarding pages visited. In this case, Personal Information is used in aggregate form, and does not reveal the Personal Information of a particular user;
- verify the user’s eligibility to access any restricted areas of our Website; and
- provide users with customer support.
- We may use information that does not reasonably identify you for any purpose. For example, for research purposes we may prepare aggregated reports about how visitors to the Website tend to interact with the Website.
We also collect information relating to whether you have accessed this Website before and the time of your last visit. We accomplish this through cookies placed on your computer.
1. What are cookies?
A cookie is a piece of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website using that browser.
When you access our Website, we place cookies on your computer. A cookie allows us to determine that a visit has occurred within our site, as well as which pages were viewed. Through cookies, we may collect your Internet Protocol (“IP”) address, operating system and browser type, and the locations of the web pages you view right before arriving at, while navigating and immediately after leaving the Website.
2. How can I manage cookies?
You can decide if and how your computer will accept cookies by configuring the preferences option within your web browser, using the instructions provided in your browser. If you choose to decline cookies, however, some of the functionality of our Website might be impaired.
We use the information collected through cookies for statistical information about Website visits to better understand our audience and its interests, and to increase the functionality and user- friendliness of our site. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/.
D. LAFAYETTE SQUARE’S SHARING OF INFORMATION WITH THIRD PARTY PROVIDERS
1. Service Providers
2. Analytics Providers
For example, we use Google Analytics, which is a web analytics tool that helps us understand how users engage with our Website. Like many analytic services providers, it tracks your movement through our Website (i.e. the pages you have seen and the links you have clicked on) and helps us measure how you interact with the content we provide. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting your use of our site. For more information on opting out of Google Analytics across all websites you use, you can visit this Google page: https://tools.google.com/dlpage/gaoptout.
3. Disclosure of Personal Information to Selected Third Parties
We may share your information with selected recipients. These categories of recipients include:
- Recruitment providers i to assist us in candidate recruitment; and
- Where you have asked to be notified of corporate events we may useemail management service companies
- Service providers to perform certain services on our behalf such as:
- to process and store data, including your Personal Information;
- to track, analyze, and modify our Website;
- for marketing, advertising, and distribution;
- for co-sponsoring or co-branding certain services, promotions or events;
- to assist us in providing you with customer support; and
- to support our IT and security efforts.
4. Other Sharing Practices
We may share your information with our affiliates and subsidiaries, and may also provide information to our attorneys, banks, auditors, and other service providers.
We may disclose information when we believe in good faith that such disclosures:
- are required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency’s request;
- will support our detection, prevention, or response to fraud or intellectual property infringement;
- will help protect your safety or security, including the safety and security of property that belongs to you; and
- will protect the safety and security of our Website and/or third parties, including the safety and security of tangible and/or intangible property that belongs to us or to third parties.
We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.
Additionally, we reserve the right to share information with third-parties that does not reasonably identify you.
E. SECURITY MEASURES WE TAKE TO SAFEGUARD INFORMATION
1. The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive.
From time to time, we review and consider updates for our security procedures. Please be aware though that, despite our ongoing efforts, no security measures are perfect or impenetrable. This means that we cannot ensure or warrant the security of any information we collect about you, and therefore your visit to our Website is at your own risk.
2. How Do We Protect Information Collected on This Site?
We consider the Personal Information we collect to be confidential. If you submit your e-mail address or other Personal Information to us via our Website while requesting information , we will use this information only to the extent necessary to respond to your request(s) and as discussed below.
We have established certain reasonable electronic and administrative safeguards and take reasonable precautions to protect the Personal Information in our possession from loss, misuse, and unauthorized access, disclosure, alteration and destruction. Lafayette Square does not warrant or represent that this level of security meets or exceeds any particular standard. You should keep in mind that no Internet transmission is ever 100% secure or error- free due to the inherent nature of the Internet as an open global communications vehicle and we cannot guarantee that information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from unauthorized intrusion by third parties, such as hackers.
3. Fraud Prevention
We may disclose user information when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity; to protect the safety, rights, or property of Lafayette Square, and its users, or others; or to exercise or protect legal rights or defend against legal claims.
4. Law Enforcement and Litigation
To the extent permitted by law, any information collected over our Website or concerning its use may be disclosed to government authorities or third parties pursuant to a legal or regulatory request, subpoena, or other legal process. We may also use or disclose your information as permitted by law to protect the rights or property of Lafayette Square, our customers, our Website, its users, or third parties, or when we otherwise believe in good faith that the law requires it.
5. Change in Corporate Control
If Lafayette Square incurs a corporate change in control resulting from, a sale to, or merger with, another entity, or if all or a portion of its assets are sold, Lafayette Square reserves the right to transfer your Personal Information to the new party in control or the party acquiring assets.
F. CHILDREN’S INFORMATION.
The Website is intended for use by those over 16.,. We do not knowingly solicit or collect personal information from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted Personal Information through the Website, we will take reasonable measures to delete all such information and shall only use such information where necessary to protect the safety of the child or others as required by law
G. OPTING OUT OF COMMUNICATIONS.
You may “opt-out,” or unsubscribe, from our newsletters or other marketing communications by following the unsubscribe instructions in any email or other communication you receive from us or contacting us as set forth in the How to Contact Us section below.
After doing so, you will not receive future promotional emails unless you open a new account or re-sign up to receive newsletters or emails. Please note that even after unsubscribing we may still disclose information as permitted or required by law including, but not limited to, service-related announcements, state required notices, and other non-marketing communications about your account or transactions that you have made. Please note that once you request removal, it may take up to two weeks to stop receiving email from us.
Unless you ask us not to in accordance with the provisions above, by using our Website and/or services, you agree that we may contact you via phone, email, push notification, and promotions via the Website.
I. HOW CAN YOU CONTACT US?
If you would like to contact us about this policy or our Website, please reach out to us via the Contact page. You can also write to our privacy lead at firstname.lastname@example.org.
CALIFORNIA RESIDENTS’ PRIVACY STATEMENT
Note that based on the provisions of the California Consumer Privacy Act (“CCPA”) and its accompanying regulations, our Company is not within the definition of a “Covered Business” and thus is not subject to the provisions of the CCPA. This statement addresses the general requirements of California law applicable to the owners of websites that are accessible by California residents and applies solely to California residents who access the Company’s website.
1. Personal Information Collected
Under California Law, California residents have the right to opt-out of the sale of personal information about them or their household, such as their name, postal or email address, and other personal identifying information. The right is subject to certain exceptions. For example, it does not apply to information that we share with certain third-party service providers so they can perform business functions for us or on our behalf. You may opt out by emailing email@example.com
In the preceding twelve months, we have not sold Personal Information. Our policy is that we do not and will not sell your Personal Information, unless you give us your consent or direct us to do so.
2. California Residents’ Privacy Rights
Under California Law, California residents have the following rights (“Rights”). Your Rights to Disclosure & Access and Deletion Rights are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us, or the security of our systems.
- Disclosure & Access Rights: California residents have the right to request that we disclose to them (i) the categories of Personal Information we have collected about them, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual.
- Deletion Rights: California residents have the right to have their Personal Information deleted, unless the Personal Information is necessary for the business or service provider to:
- complete a transaction for which the Personal Information was collected, provide a good or service requested by the residents or otherwise perform a contract between the business and the residents;
- detect security incidents;
- protect against malicious, deceptive, fraudulent or illegal activity (or prosecute those responsible);
- debug to identify and repair functionality errors;
- exercise or ensure the right of another to exercise free speech or another legal right;
- comply with the California Electronic Communications Privacy Act, which compels the production of or access to electronic communication information or electronic device information with a search warrant;
- engage in research in the public interest (if the individual has provided informed consent);
- to enable solely internal uses aligned with the individual's expectations given their relationship with the Company;
- comply with a legal obligation;
- otherwise use the information internally in a lawful manner compatible with the context in which the individual provided it.
California residents can exercise their privacy rights by contacting us at firstname.lastname@example.org.
3. Response Time
We will address any requests to exercise the rights described above under Applicable Laws in California. When a request is made, we may verify your identity to protect your privacy and security. We will respond to written rights requests within 45 days following receipt at the email or mailing address stated above. Please note that we are only required to respond to an individual twice per 12-month period.
NOTICE TO EUROPEAN RESIDENTS:
1. GDPR: Lafayette’s Website is hosted in the United States but some companies and contractors who process your Personal Information may be located in European countries. These countries may provide a different level of privacy protection for your information and in these circumstances, Lafayette may make a transfer of Personal Information via either (1) a contract incorporating standard data protection clauses recognized or issued in accordance with the GDPR; or (2) use of the European Commission’s model contracts for the transfer of Personal Information to third countries (i.e., the standard contractual clauses).
2. Where the GDPR applies, you have the following rights in respect of your personal information:
a. Data rights. In certain circumstances, you have the right to access and receive a copy of information we hold about you, to rectify any Personal Information that is inaccurate and to request the deletion of Personal Information held about you. You can exercise your rights by contacting us at email@example.com and referencing GDPR Data Rights. When a request is made, we may verify your identity to protect your privacy and security. We will respond to your request within 30 days following receipt at the email address stated above.
Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you.
b. Marketing. You have the right to ask us not to process your Personal Information for marketing purposes. To exercise this right, please contact us at firstname.lastname@example.org and reference GDPR. Note that we can only exercise this request to the extent a marketing campaign is not already publicly distributed.
c. Complaints. If you wish to advise us of a complaint regarding the way we process your Personal Information, please contact us at email@example.com and we will endeavor to deal with your request as soon as possible. You may also contact a supervisory authority.