Effective as of: September 1, 2022
INFORMATION WE COLLECT
Gauge collects both personal and non-personal information in the course of its business activities. “Personal Information” is any factual or subjective information about an identifiable individual. Personal Information can directly or indirectly identify you as an individual and may include, but is not limited to, your name, email address, telephone number, postal address, online digital identifiers, your browser and device information, and information collected through digital tracking technologies. Gauge collects Personal Information from you through our website and through our interactions with you.
Your Personal Information will be stored and processed in the United States, which may have data protection rules that are different from those of your country.
We use Google Analytics on our Website to collect and analyze the information discussed above, and to engage in auditing, research and/or reporting. The information (including your IP address) collected will be disclosed to evaluate your use of the Site, including by noting the third-party website from which you arrive, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
USE OF INFORMATION WE COLLECT
Gauge uses your Personal Information in order to conduct its legitimate business activities which include, but are not limited to, fulfilling information and other requests, marketing, promotion, recruiting, internal research and reporting, providing and improving products and services, enforcing our Website Terms and Conditions of Use which can be found here: [TERMS URL] (the “Terms”) and personalizing content that you view on our Website. Gauge may aggregate and de-identify Personal Information and we may use such aggregated and de-identified data and share it with third parties for any purpose including, but not limited to, research and marketing purposes.
Gauge may use the Personal Information you provide us to send you messages regarding our products and services including, but not limited to, physical and virtual newsletters and brochures. Gauge will also use your Personal Information to provide you with information and/or offers tailored to your interests, or to communicate with you directly.
Gauge may also use your Personal Information to manage its contractual relationship with you, if such exists, by responding to your inquiries, providing technical support and providing other business support activities.
Finally, Gauge may use your Personal Information to improve its products and services or improve the operation of its Website. For example, Gauge will determine which types of products, services or Website content get the most engagement from our customers. Gauge will also use your Personal Information to better understand you, so that we can personalize our business transactions.
DISCLOSURE OF PERSONAL INFORMATION
Gauge does not sell any Personal Information to third parties. We may, however, disclose Personal Information to our vendors, service providers and marketing partners in order to conduct our legitimate business activities. Gauge may also need to disclose your Personal Information as required by law or to protect its legal rights.
Gauge’s business activities may include, but are not limited to, the provision of investment-related services, Website hosting, data analysis, the provision of information technology services and related infrastructure, customer service, email delivery, auditing, and other services we provide to our customers. Gauge may also share your Personal Information with its marketing partners, to permit them to send you marketing communications.
Gauge may disclose or transfer your Personal Information pursuant to a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
It may become necessary for Gauge to share your Personal Information for legal reasons. These can include a need to comply with applicable law inside or outside the United States and/or to respond to requests from public and government authorities, including law enforcement authorities. Gauge may also need to disclose your personal information in order to enforce our Terms, participate in a judicial or regulatory proceeding, or to protect and defend our rights or the rights of others. Finally, Gauge may need to disclose your Personal Information in order to prevent fraud, support auditing, compliance and corporate governance functions, or to protect the vital interests of a person.
RETENTION OF PERSONAL INFORMATION
Your Personal Information, and any other information we gather, may be held by Gauge indefinitely, or for as long as is necessary so that we may maintain a business relationship with you, to protect ourselves against legal claims, or for record-keeping purposes.
You may request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us. If you would like to request information about how your Personal Information has been collected or disclosed, you may contact us by sending a notice via email with your name and contact information to: firstname.lastname@example.org. We will respond to your request consistent with applicable law.
If you request that we delete your Personal Information, Gauge will make reasonable attempts to delete all instances of your Personal Information in its entirety. To request such deletion, please send the request via email with your name and contact information to: email@example.com.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Gauge processes Personal Information in accordance with the law at all times. The legal grounds under which Gauge processes Personal Information include:
Gauge has implemented generally accepted physical, technical and organizational security measures to protect against the loss, misuse, disclosure, alteration or destruction of the Personal Information we gather, including storage in a controlled, secure environment protected from unauthorized access. However, no electronic data transmission can be guaranteed to be completely secure. Though we utilize such measures, we cannot guarantee against the loss, misuse, or alteration of your Personal Information. Gauge cannot guarantee that unauthorized individuals will not obtain access to your Personal Information, and you provide us your Personal Information at your own risk.
Though Gauge gathers and retains Personal Information as described above, you may opt out of receiving marketing emails from us by either following the opt-out instructions in those emails or by sending an opt-out request via email to: firstname.lastname@example.org.
You may also opt-out of receiving other types of communications from us, including but not limited to phone calls and mailings, by sending such a request via email to: email@example.com.
Gauge will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related communications from us, we may still send messages to you pursuant to an existing business relationship which we may have with you.
INDIVIDUALS LOCATED IN THE EEA
If you are located in the European Economic Area (“EEA”), and you are sending us your Personal Information, you acknowledge and understand that it will be stored in the United States. Subject to limitations under local law, you may have additional rights with regard to your Personal Information including, but not limited to, (i) the right to access/change delete it, (ii) the right to request a restriction on the way in which it is processed, and (iii) the right to object to it being processed. You may lodge a complaint with the data protection authority in your country or region or where an alleged infringement of applicable data protection law occurs.
CALIFORNIA CONSUMER PRIVACY ACT
Under the California Consumer Privacy Act (“CCPA”), California residents have additional privacy rights available to them. These include the right to be notified at or before the point at which Personal Information is collected, the right to opt out of the sale of Personal Information, the right to request deletion of Personal Information, the right to receive copies of or information about the Personal Information we collect, the right to be free from discriminatory treatment for the exercise of the privacy rights conferred by the CCPA, and the right to receive information about financial incentives we may offer you, if any. California residents also have the right to designate an authorized agent to make a request under the CCPA on the resident’s behalf.
© 2022 Gauge Capital LLC
Latest Revision: September 1, 2022</p>