Last Updated: August 15, 2019
This Privacy Policy (the “Policy”) describes how we at SteeleHarbour Capital Partners (“SteeleHarbour”) collect, use, share and store information relating to users of the SteeleHarbour website, http://www.steeleharbour.com (the “Site”). Please read this entire Policy before using or submitting information to any of the Site. By using the Site, you are deemed to agree to the terms of this Policy, so please do not use the Site if you do not agree with these terms.
We may update this Privacy Policy at any time. Any changes to the Policy will become effective upon the date of our posting of the revised Policy on the Site. If you visit a Site following the effective date of the revised Policy, you will be deemed to have accepted the Policy’s updated terms.
The information we collect from you as a user of the Site includes both information you actively provide and information you passively provide through the connection between your computer or other device that accesses the Site.
Currently, the information you may actively provide consists of the information we require in order for you to send us a message through the “Contact Us” form on the Site. To send such a message, you must provide your first and last name and your email address. We collect that information as well as the information you include in the message you submit. In the future, we will have an Investor Portal and, to the extent you are an investor with SteeleHarbour or any of its affiliates to which such Investor Portal applies, to access that portal, you will need to create an online account, which will involve your providing additional information. We will update or supplement this Privacy Policy to address our policies with respect to that additional information when the Investor Portal becomes active.
The information you provide passively when you access the Site includes your IP (Internet Protocol) address and certain Site browsing information that is collected through our use of Google Analytics (described more fully in Section V below). This information is combined with that of other users to give us information about the Site’s usefulness and usability so that we may work to improve the Site and our services.
We may use the information you provide to us for any or all of the following purposes:
A. Respond to Your Inquiries. We will use your email address to respond to your inquiries, whether you submit them through our “Contact Us” page or send them to us by email.
B. Send You Information. We may use your email address to send you various types of information about us and our services, including SteeleHarbour updates, new services, and other related items of potential interest. You may unsubscribe to our commercial emails by using the “unsubscribe” function in any of those emails.
C. Improving Our Service and Outreach. We may use quality-related information you provide, such as your feedback and comments about our Site and our services, to make our communications with you more relevant, including by requesting further feedback, and for related internal purposes such as data analysis, audits, identifying usage trends, and enhancing our services.
D. Tracking Information. As noted in Section I above, we use the information Google Analytics collects to help us improve the Site and our services by taking into account your and other Site users’ online preferences and usage patterns.
A. Third Party Service Providers. We share the information we collect from you through the site with unaffiliated third parties who provide us with services, such as data storage and technology.
B. Acquirers or Assignees. In the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of SteeleHarbour or its assets, we may transfer any and all information that we collect from Site users to the acquiring party or assignee.
C. Entities Entitled Under Law. We may disclose site user information as we believe to be appropriate in the following circumstances: (i) when required by applicable law, including laws outside your country of residence; (ii) to comply with legal process (iii) to respond to requests from public and government authorities; (iv) to enforce the terms and conditions for use of the Site, including this Policy; (v) to protect and defend our rights and property; (vi) to protect the interests of SteeleHarbour or others; and (vii) to permit us to pursue available remedies or limit the damages that we may sustain. We have no obligation to notify you of such disclosures, except as required by applicable law.
We do not share Site users’ information with unaffiliated third parties for those parties’ own marketing purposes.
A. Security. We will take reasonable steps to protect information as you transmit it from your computer or mobile device(s) to our Site, and to protect it once obtained from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. SSL encryption is enforced on traffic to and from the Site; however, you should be aware that no Internet transmission is ever fully secure or error-free. You should therefore take special care in deciding what information you send to us via e-mail.
B. Data Retention. We will retain the information we collect from you for the period necessary to fulfill the purposes outlined in this Policy.
A. As explained in Section I above, we use Google Analytics to collect information on your and others’ use of the Site. To learn more about how Google Analytics collects such information, please visit https://developers.google.com/analytics/resources/concepts/gaConceptsTrackingOverview. If you wish to opt out of Google Analytics tracking, you can use this tool to do so: https://tools.google.com/dlpage/gaoptout.
B. The Site may contain links to websites operated by parties not affiliated with SteeleHarbour. These linked websites are not under SteeleHarbour’s control and we are not responsible for the privacy practices or the contents of any such unaffiliated parties or their websites. If you provide information through any such third-party website, that information will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Policy.
The Site is not directed to children under the age of thirteen (13), and we do not knowingly collect information online from any children under age 13. If you are under age 13, please do not submit any information to us online.
The Site is operated in the United States. By using the Site, you are deemed to understand and unambiguously consent to the collection and processing in the United States of the information we collect from you online, with the awareness that the laws of the United States may not provide as much protection for that information as the laws of certain other countries or territories.
If you have any questions or concerns related to this Privacy Policy or the information practices of the Site, please contact us either through the Site’s “Contact Us” page; by email at info@steeleharbour.com; or by mail at:
SteeleHarbour Capital Partners
1775 Tysons Boulevard, 5th Floor
Tysons, VA 22102