Cornucopian Capital
Privacy Policy
Effective Date: February 25, 2022
This Privacy Policy (this “Policy”) is designed to inform you about how the Cornucopian Capital family of companies, including Cornucopian Capital Management LLC, Cornucopian Investments LLC and Cornucopian Capital, L.P. (“Cornucopian”) collects, uses, and shares information about you when you visit or interact with our website and its subdomains, and all other websites, products, and services that Cornucopian owns or controls and link to this Policy (collectively, the “Services”). From time to time, we may supplement this Policy with additional information about our privacy practices related to a particular activity Cornucopian undertakes.
Please use the links below to jump to the sections of the Policy:
Information We Collect
How We Use Your Information
How We Share Your Information
Security of Your Information
Children’s Privacy
Do Not Track
California Shine the Light
Notice to Residents of Nevada
International Visitors
Third-Party Links
Updates to this Policy
Contact Us
Information We Collect
When you interact with the Services, we may collect certain information directly from you or automatically from the devices you use to access our Services. Depending on how you use the Services, we may collect the following types of information from or about you:
- Direct identifiers, such as your name, email address, phone number, and other contact information;
- Usage information, such as your IP address; the location from which your device accesses the Services; the type of Internet browser you are using; the dates and times on which you access the Services, and other information about how you navigate and interact with the Services;
- Other information you may choose to provide, such as the content of your messages to us when you send us a message, contact us with questions, or provide information about your organization.
We may collect this information from:
- Our direct interactions with you, such as when you interact with our Services, fill out our online forms, participate in surveys or questionnaires, inquire about strategic partnership or collaboration opportunities, subscribe to our electronic communications, or in any way engage with the Services;
- Our use of cookies and automated technologies when you interact with our Services.
A cookie is a small text file that is sent to or accessed from your web browser or your computer’s hard drive that may contain information about your computer, browsing history, and activities performed while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies, please visit www.allaboutcookies.org.
You have the ability to accept or decline cookies. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, this may impact your experience using our website.
Our website uses Google Analytics to help us analyze how users use the website and target users with appropriate advertisements. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google. Read about Google’s privacy practices.
You can use the methods linked to below to manage cookies. You must take these steps on each browser or device that you use. If you replace, change or upgrade your browser or device, or delete your cookies, you may need to use these opt-out tools again.
If the browser you use is not listed above, please refer to your browser’s help menu for information on how to manage cookies.
How We Use Your Information:
We may use your information for the following purposes:
- Conduct our business and provide our Services to you;
- Respond to your messages and to otherwise communicate with you;
- Provide, maintain, improve, and personalize the Services and enhance the user experience;
- Monitor, research, and analyze trends, use, activities, and feedback related to the Services;
- Detect, investigate, and prevent fraudulent and other illegal activities, and protect the rights and property of Cornucopian and others;
- Maintain records for internal business purposes;
- Create profiles based on information we collect from you;
- Send you important notices, updates, security alerts, support, and other administrative messages; and
- Carry out any other purpose described to you at the time we collect your information.
In addition to the uses identified above, Cornucopian may use the information to comply with our legal obligations. For example, if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- Vendors, consultants, and over service providers who need access to your information to carry out work or perform services on our behalf;
- Other third parties as necessary to:
- comply with laws applicable to Cornucopian, a request from law enforcement or a government agency, or other legal process;
- protect the legitimate rights, privacy, property, interests or safety of Cornucopian, our customers, business partners, personnel, or the general public;
- pursue available remedies or limit damages;
- enforce our Terms of Use;
- respond to an emergency; or
- explore or complete a merger, sale, acquisition, divesture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control of Cornucopian or its assets (whether in whole or in part).
- Third-party analytics. We use selected third parties to collect data about how you interact with the ISBA website and our services. This information may be used to, among other things, improve the functionality of our website and services.
We also may disclose your information to other third parties if you have given us specific consent to do so.
Security of your Information
We take reasonable steps to protect the security of the information about you. Please understand, however, that no data transmitted over the Internet can be guaranteed to be secure. Accordingly, please be thoughtful about what information you send through the Services.
Children’s Privacy
Our Services are not intended for children under 16 years of age, and we do not knowingly collect or use any personal data from children under the age of 16. No one under the age of 16 may provide any information to or through our Services. If we learn we have collected or received personal data from a child under the age of 16, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact us at privacy@cornucopiancapital.com.
Do Not Track
Certain web browsers and other devices you may use to access the Services may permit you to submit your preference that you do not wish to be “tracked” online. We do not currently commit to responding to “do not track” requests, in part, because no common industry standard for “do not track” has been adopted by industry groups, technology companies, or regulators.
Notice to Residents of California
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. Cornucopian does not share your information with third parties for direct marketing purposes. However, if you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
As of the date of this privacy policy, the California Consumer Privacy Act of 2018 (“CCPA”) does not apply to Cornucopian. If that were to change in the future, we will update this privacy policy.
Notice to Residents of Nevada
If you are a Nevada resident, you have the right to opt out of the sale of certain personal information, including your name and mailing address, to third parties. Cornucopian does not sell your personal information. If that were to change in the future, we will provide Nevada residents with a method to opt-out of those transactions.
International Visitors
Our Services are intended for residents of the United States. However, if you are located outside of the United States, please be aware that information we collect through our website and services will be transferred to and processed in the United States. By using the website and services or by voluntarily providing your information to us, you consent to the transfer, processing, and storage of your information in the United States.
Third-Party Links
The Services may contain links to other websites or services that are not controlled by Cornucopian. Your use of a third-party website or any of its informational content is subject to and governed by the privacy policies, terms, and conditions of that website. We are not responsible for the privacy practices of any third-party websites.
Updates to this Policy
We may update our privacy practices from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. If we make any material changes to the ways in which we process your information, then we will take reasonable efforts to notify you of these changes. The updated Policy will supersede all previous versions. Your continued use of the Services after the Effective Date of the updated Policy constitutes your acceptance of the updated Policy.
Contact Us
If you have any questions, comments, or requests related to our privacy practices or this Policy, please contact Cornucopian at: privacy@cornucopiancapital.com.