PRIVACY POLICY

CriticalPoint Partners, LLC Privacy Policy

Your privacy is important to CriticalPoint Partners, LLC (“CriticalPoint”).  To better protect your privacy, we are providing information explaining our online information practices.  This Privacy Policy governs the manner in which CriticalPoint collects, uses, shares, maintains, protects and discloses information collected from you or that you may provide when you interact with CriticalPoint through our website and our business. This Policy explains what information CriticalPoint collects, when and how CriticalPoint might use that information, how CriticalPoint protects the information, the choices you have with respect to your personal information and how you can contact CriticalPoint if you have any questions or concerns.  You consent to the use of information that is collected or submitted as described in this Privacy Policy. CriticalPoint may modify this Privacy Policy, so you are encouraged to regularly review it.

I.  Information You Provide to CriticalPoint.

The types of information CriticalPoint collects depends on your use of CriticalPoint’s website, the ways that you interact with CriticalPoint and its business and what information you choose to provide to CriticalPoint.  For example,

• You may submit information to CriticalPoint so that CriticalPoint can respond to inquiries and provide you with information you request regarding CriticalPoint services. The data that CriticalPoint collects in this regard may include personal information such as contact details including names, email addresses, home addresses, and phone numbers, as well as, information related to your commercial inquiry for our services.
• CriticalPoint collects information in connection with its financial advisory services and marketing related activities.  The data that CriticalPoint collects in this regard may include personal information.
• CriticalPoint collects pre-employment information (including personal information such as name, email address, telephone number and curriculum vitae) in connection with job opportunities you may apply for, as well as, employment information (including personal information related to employment authorization, tax identification, benefits and payroll) in connection with its employees and contractors.

II. CriticalPoint Automatic Collection of Information.

• CriticalPoint does not collect personal information through the use of cookies or any other automatic data collection tools on its website. 

III. CriticalPoint Collection of Information from Other Sources.

• CriticalPoint may obtain information about you from our current or future affiliates or subsidiaries.
• CriticalPoint may obtain information about you from publicly and/or commercially available sources, including but not limited to, third party publishers, social media, and third party networks.
• CriticalPoint may obtain information about you from third party investment opportunities.
• CriticalPoint may obtain information about you from third parties that we have a business relationship with and as permitted by law or agreement.

IV. CriticalPoint De-Identified Information.

CriticalPoint may collect information that is de-identified so that personal information is anonymized. CriticalPoint’s use and disclosure of such de-identified information that is anonymized of personal information is not subject to any restrictions under this Privacy Policy, and CriticalPoint may disclose it to others without restriction for any purpose.

V. CriticalPoint’s Use of Information.

CriticalPoint may use your information for our business purposes, including but not limited to the following:

• Improving our website and the services that we offer and notifying you about changes to our services.
• For the performance of CriticalPoint’s agreements with you. For example, fulfilling CriticalPoint’s merger and acquisition transactions and providing investment advisory and related services.
• Communicating with you including responding to your requests, questions, or comments that are submitted by you.
• Performing, managing, and administering CriticalPoint’s employment relationships with its employees.
• Detecting, investigating, and preventing fraudulent transactions, abuse, and other illegal activities.
• Protecting the rights, property, or safety of CriticalPoint and others.
• Complying with our Terms of Use policy; as well as complying with applicable law and government requests.
• Performing any other business activities as needed, or as described elsewhere in this policy or carrying out any other purposes described to you at the time that CriticalPoint collected the information.

VI. CriticalPoint’s Sharing of Information.

CriticalPoint may disclose information to:

• CriticalPoint’s third party service providers who help CriticalPoint to operate or improve our website or to assist with CriticalPoint’s business processes and/or as necessary to provide CriticalPoint’s services.  
• Third parties related to CriticalPoint investment advisory opportunities and due diligence.
• Comply with the law or to enforce or apply applicable terms and conditions and other agreements if CriticalPoint believes such disclosure is appropriate. CriticalPoint may also disclose information about you if CriticalPoint believes that your actions are inconsistent with CriticalPoint’s Terms of Use or related guidelines and policies, or if necessary, to protect the rights, property, or safety of, or prevent fraud or abuse of, CriticalPoint or others.
• An affiliate or successor entity or otherwise as part of a corporate business transaction.

CriticalPoint may also share information about you at your direction or request or when you otherwise consent.  CriticalPoint does not sell your personal information to a third party or share your personal information except as described in this Privacy Policy.

VII.  Your Choices.

Where CriticalPoint has collected and processed your personal information with your consent, you may withdraw your consent as provided for within this Privacy Policy and to the extent permitted by law.  Withdrawing your consent will not affect the lawfulness of any processing that CriticalPoint conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you wish to exercise any privacy right in relation to your personal information as set forth in this Privacy Policy or if you otherwise have any questions, comments or concerns about this Privacy Policy, please contact us by sending a written request via email to [email protected] or by writing us at CriticalPoint Partners, LLC, Attn: Compliance / Privacy Request, 2101 Rosecrans Avenue, Suite 4255, El Segundo, CA 90245. Please be aware that your request does not guarantee complete access or removal of your personal information as the law may not permit or require removal in certain circumstances.

VIII. Data Rights.

You may have the following consumer privacy rights in relation to your personal information collected or maintained by CriticalPoint depending on your jurisdiction:

• Right of Access: You may have the right to request and access information about how CriticalPoint processes personal information relevant to your request.
• Right to Portability: You may have the right to receive personal information relevant to your request, in a structured, commonly used, and machine-readable format and to have that information transmitted to another third-party in certain circumstances.
• Right to Rectification: You may have the right to request the update and correction in inaccuracies of personal information relevant to your request.
• Right to Deletion: You may have the right to request the deletion of personal information that CriticalPoint has collected relevant to your request under certain circumstances.
• Right to Restrict Processing: You may have the right to request CriticalPoint to restrict the processing of personal information relevant to your request under certain circumstances. For example, if you in good faith believe that personal information CriticalPoint processes about you is incorrect or unlawful.  
• Right to Object or Opt-Out.  You may have the right to object to and/or opt-out of the processing of personal information relevant to your request under certain circumstances or as otherwise set forth in this Privacy Policy.

These rights may be limited by applicable law. For example, CriticalPoint may need to retain or share certain personal information for legitimate business purposes, to complete transactions you have requested, to comply with our legal obligations, and for other purposes as required or permitted by law. You may exercise the rights by contacting us via email at [email protected] or write us at our mailing address at: CriticalPoint Partners, LLC, Attn: Compliance / Privacy Request, 2101 Rosecrans Avenue, Suite 4255, El Segundo, CA 90245  In addition, if you believe that CriticalPoint has not complied with your data protection rights, you have the right to file a complaint with the data protection authority of your home country.

IX. Miscellaneous.

Data Retention. CriticalPoint may retain information for legitimate business needs including, but not limited to, detecting and preventing abuse of our website, illegal activities, breaches of our Terms of Use, complying with applicable legal, tax or accounting requirements, and performing, maintaining and administering our agreements. When CriticalPoint has no legitimate business need to retain your information, we will either delete it consistent with CriticalPoint’s data retention and deletion policy or take reasonable steps to de-identify or anonymize it in accordance with applicable law.

Security. CriticalPoint employs industry standard technical and organizational measures designed to protect your personal information that is under CriticalPoint’s control and that CriticalPoint processes on your behalf from unauthorized access, collection, use, disclosure, copying, modification, or disposal, both during transmission and once CriticalPoint receives it.  Despite the foregoing, CriticalPoint cannot guaranty the security of information and information you provide is at your own risk.

Third Party Websites. This Privacy Policy does not apply to information that you have provided or made accessible to third parties.  Disclosure of information to these third parties is subject to the relevant third party’s privacy policy. CriticalPoint is not responsible for the third party’s use of your information.

Children’s Personal Information.  CriticalPoint’s website is directed to adults and is not intended for children i.e. individuals under 18 years of age. CriticalPoint does not knowingly collect personal information online from children under the age of 13 or equivalent minimum age in the applicable jurisdiction. No one under age 13 may provide any personal information to CriticalPoint on its website. If CriticalPoint learns we have collected or received personal information from a child under 13 on its website, CriticalPoint will take reasonable steps to delete that information as soon as practicable.

Contact.  If you have any questions or concerns about this Privacy Policy, please contact us via email at [email protected] or write us at our mailing address at: CriticalPoint Partners, LLC, Attn: Compliance / Privacy Request, 2101 Rosecrans Avenue, Suite 4255, El Segundo, CA 90245.

Changes.  CriticalPoint may update this Privacy Policy from time to time to keep it current with applicable law and industry standards. When CriticalPoint makes changes to this Privacy Policy, CriticalPoint will publish the changes and the effective date of such changes on its website.

This document is effective on September 3, 2020 (“Effective Date”).

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