Privacy Policy
WEBSITE PRIVACY POLICY
OUR COMMITMENT TO PRIVACY
Your privacy is important to Shorehill Capital LLC and its affiliates (together, “Shorehill,” “our,” “us,” “we” or “company”). To better protect your privacy and comply with our legal obligations, we are providing information explaining our online information practices.
This website privacy policy (this “Privacy Policy”) describes how we gather and use personal information about visitors of this website (the “Website”). For simplicity, we use the terms “personal information”, “personally identifiable information” and “personal data” in this Privacy Policy (and any additional jurisdiction-specific privacy notices) interchangeably. Please read this Privacy Policy carefully. To the extent permitted by applicable data protection and privacy laws, this Privacy Policy constitutes a legally binding agreement between Shorehill and you, the user of this Website and by entering and using this Website, you acknowledge your acceptance of, and agree to be bound by, the Privacy Policy stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Privacy Policy, please do not access or use this Website.
This Privacy Policy applies solely to your interactions with us through our Website. If you provide personal information to use through another means (e.g., as an investor or an employee seeking employment) you will receive a separate privacy notice and that notice will govern that personal information.
JURISDICTION-SPECIFIC INFORMATION
This Privacy Policy complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that may apply to you, including as set forth in our additional jurisdiction-specific privacy notices.
Visitors that are residents of California should also refer to our California Website Privacy Policy supplement.
THE INFORMATION WE COLLECT
We track information related to your use of our website.
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we take reasonable steps to protect your personal data – and in this regard, we maintain physical, electronic and procedural safeguards to prevent unauthorized access to your personal data and to protect the integrity of our systems - we cannot guarantee the security of any information or data transmitted to or through our Website; any transmission of information or data by you to or through this Website is at your sole risk.
SOURCES OF NON-PUBLIC INFORMATION
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
- Information from your communications with us in connection with this Website, including any update notices provided by you.
- Information captured on our Website, including any information captured via cookies.
We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
HOW WE USE YOUR PERSONAL INFORMATION
We will use your personal information for one or more of the following business or commercial purposes:
- To present the Website and its contents to you and to allow you to interact with the Website
- To provide, support, personalize, develop and improve our Website and the products and services that we offer and notify you about changes to our Website or our products and services
- To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website
- To provide advertising and marketing services
- To conduct ongoing operations, administrative, and other processes
- To audit and verify the quality and effectiveness of our services and compliance
- To maintain the safety, security and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity
- As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations
- For any other purpose that has been notified to you, or agreed by you, in writing
DISCLOSURE OF PERSONAL INFORMATION
We may disclose personal information collected in connection with this Website for a business purpose to the categories of third parties indicated below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
- Identifiers: Administrators, governmental agencies or pursuant to legal process.
- Other Identifying Information: Administrators, governmental agencies or pursuant to legal process.
- Information Related to Internet Activity: Administrators, governmental agencies or pursuant to legal process.
CAPACITY
You represent to Shorehill that you have the authority to visit this Website according to the Terms of Use. This Website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this Website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
RETENTION OF PERSONAL INFORMATION
We retain your personal information for as long as reasonably necessary and proportionate to achieve the purposes and uses set out in this Privacy Policy, as authorized by law, and to meet legal, risk management or business requirements. We may retain personal information for longer where required by our regulatory obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others. Your personal information may be deleted when it is no longer relevant or when you withdraw consent (pursuant to the rights detailed directly in this may be exercised by using the contact information contained at the end of this Privacy Policy) within the parameters of applicable law.
COOKIES
Information regarding how you access this Website (e.g., browser type, access times and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve Website performance and for our business purposes, including to help provide you with a better experience when you browse our Website. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this Website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.
Subject to your consent, the Website may place the cookies listed below:
| Cookie Name | Purpose / Description | Duration |
|---|---|---|
| Cookie Preferences | This cookie is used to store the user’s cookie consent preferences. | 30 days |
| cf_use_ob | The cf_use_ob cookie informs Cloudflare to fetch the requested resource from the Always Online cache on the designated port. Applicable values are: 0, 80, and 443. The cf_ob_info and cf_use_ob cookies are persistent cookies that expire after 30 seconds. | Session |
| __cfwaitingroom | The __cfwaitingroom cookie is only used to track visitors that access a waiting room enabled host and path combination for a zone. Visitors using a browser that does not accept cookies cannot visit the host and path combination while the waiting room is active. | Session |
| cf_chl_rc_i | These cookies are for internal use which allows Cloudflare to identify production issues on clients. | Session |
| cf_chl_rc_ni | These cookies are for internal use which allows Cloudflare to identify production issues on clients. | Session |
| cf_chl_rc_m | These cookies are for internal use which allows Cloudflare to identify production issues on clients. | Session |
| __cfruid | Used by the content network, Cloudflare, to identify trusted web traffic. | Session |
| __cf_bm | Cloudflare’s bot products identify and mitigate automated traffic to protect your site from bad bots. Cloudflare places the __cf_bm cookie on End User devices that access Customer sites that are protected by Bot Management or Bot Fight Mode. The __cf_bm cookie is necessary for the proper functioning of these bot solutions. | Session |
| __cflb | When enabling session affinity with Cloudflare Load Balancer, Cloudflare sets a __cflb cookie with a unique value on the first response to the requesting client. Cloudflare routes future requests to the same origin, optimizing network resource usage. In the event of a failover, Cloudflare sets a new __cflb cookie to direct future requests to the failover pool. | Session |
| _cfuvid | The _cfuvid cookie is only set when a site uses this option in a Rate Limiting Rule, and is only used to allow the Cloudflare WAF to distinguish individual users who share the same IP address. | Session |
| cf_clearance | Whether a CAPTCHA or Javascript challenge has been solved. | Session |
| __cfseq | Sequence rules uses cookies to track the order of requests a user has made and the time between requests and makes them available via Cloudflare Rules. This allows you to write rules that match valid or invalid sequences. The specific cookies used to validate sequences are called sequence cookies. | Session |
| cf_ob_info | The cf_ob_info cookie provides information on: The HTTP Status Code returned by the origin web server. The Ray ID of the original failed request. The data center serving the traffic | Session |
| comment_author | Used to track the user across multiple sessions. | Session |
| comment_author_email | Used to track the user across multiple sessions. | Session |
| comment_author_url | Used to track the user across multiple sessions. | Session |
| _gac_ | Contains information related to marketing campaigns of the user. These are shared with Google AdWords / Google Ads when the Google Ads and Google Analytics accounts are linked together. | 90 days |
| __utma | ID used to identify users and sessions | 2 years after last activity |
| __utmt | Used to monitor number of Google Analytics server requests | 10 minutes |
| __utmb | Used to distinguish new sessions and visits. This cookie is set when the GA.js javascript library is loaded and there is no existing __utmb cookie. The cookie is updated every time data is sent to the Google Analytics server. | 30 minutes after last activity |
| __utmc | Used only with old Urchin versions of Google Analytics and not with GA.js. Was used to distinguish between new sessions and visits at the end of a session. | End of session (browser) |
| __utmz | Contains information about the traffic source or campaign that directed user to the website. The cookie is set when the GA.js javascript is loaded and updated when data is sent to the Google Anaytics server | 6 months after last activity |
| __utmv | Contains custom information set by the web developer via the _setCustomVar method in Google Analytics. This cookie is updated every time new data is sent to the Google Analytics server. | 2 years after last activity |
| __utmx | Used to determine whether a user is included in an A / B or Multivariate test. | 18 months |
| _ga | ID used to identify users | 2 years |
| _gali | Used by Google Analytics to determine which links on a page are being clicked | 30 seconds |
| _ga_ | ID used to identify users | 2 years |
| _gid | ID used to identify users for 24 hours after last activity | 24 hours |
| _gat | Used to monitor number of Google Analytics server requests when using Google Tag Manager | 1 minute |
| cookiePreferences | Registers cookie preferences of a user | 2 years |
| td | Registers statistical data on users’ behaviour on the website. Used for internal analytics by the website operator. | Session |
| _hjSession_ | A cookie that holds the current session data. This ensues that subsequent requests within the session window will be attributed to the same Hotjar session. | 30 minutes |
| _hjSessionUser_ | Hotjar cookie that is set when a user first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID. | 365 days |
| _hjSessionTooLarge | Causes Hotjar to stop collecting data if a session becomes too large. This is determined automatically by a signal from the WebSocket server if the session size exceeds the limit. | Session |
| _hjSessionRejected | If present, this cookie will be set to 1 for the duration of a user’s session, if Hotjar rejected the session from connecting to our WebSocket due to server overload. This cookie is only applied in extremely rare situations to prevent severe performance issues. | Session |
| _hjSessionResumed | A cookie that is set when a session/recording is reconnected to Hotjar servers after a break in connection. | Session |
| hjViewportId | This cookie stores user viewport details such as size and dimensions. | Session |
| _hjSessionStorageTest | This cookie checks if the Hotjar Tracking Code can use Session Storage. If it can, a value of 1 is set. | Session |
| _hjTLDTest | When the Hotjar script executes we try to determine the most generic cookie path we should use, instead of the page hostname. This is done so that cookies can be shared across subdomains (where applicable). To determine this, we try to store the _hjTLDTest cookie for different URL substring alternatives until it fails. After this check, the cookie is removed. | Session |
| _hjCookieTest | This cookie checks to see if the Hotjar Tracking Code can use cookies. If it can, a value of 1 is set. | Session |
| _hjUserAttributesHash | User Attributes sent through the Hotjar Identify API are cached for the duration of the session in order to know when an attribute has changed and needs to be updated. | Session |
| _hjCachedUserAttributes | This cookie stores User Attributes which are sent through the Hotjar Identify API, whenever the user is not in the sample. These attributes will only be saved if the user interacts with a Hotjar Feedback tool. | Session |
| _hjLocalStorageTest | This cookie is used to check if the Hotjar Tracking Script can use local storage. If it can, a value of 1 is set in this cookie. The data stored in_hjLocalStorageTest has no expiration time, but it is deleted immediately after creating it so the expected storage time is under 100ms. | - |
| _hjHasCachedUserAttributes | This cookie sets when a user first lands on a page. Persists the Hotjar User ID which is unique to that site. Hotjar does not track users across different sites. Ensures data from subsequent visits to the same site are attributed to the same user ID. | 365 days |
| _hjid | Hotjar cookie. This cookie is set when the customer first lands on a page with the Hotjar script. It is used to persist the random user ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID. | 365 days |
| hj_visitor | Hotjar uses cookies to enhance the user’s experience on our website, for example to complete forms, navigating the site, and identify returning users and offer related content. Users can control the use of cookies at the individual browser level. | Session |
| _hjIncludedInSample | Hotjar cookie. This session cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate funnels. | 365 days |
| _hjClosedSurveyInvites | Hotjar cookie. This cookie is set once a visitor interacts with a Survey invitation modal popup. It is used to ensure that the same invite does not re-appear if it has already been shown. | 365 days |
| _hjDonePolls | Hotjar cookie. This cookie is set once a visitor completes a poll using the Feedback Poll widget. It is used to ensure that the same poll does not re-appear if it has already been filled in. | 365 days |
| _hjMinimizedPolls | Hotjar cookie. This cookie is set once a visitor minimizes a Feedback Poll widget. It is used to ensure that the widget stays minimizes when the visitor navigates through your site. | 365 days |
| _hjDoneTestersWidgets | Hotjar cookie. This cookie is set once a visitor submits their information in the Recruit User Testers widget. It is used to ensure that the same form does not re-appear if it has already been filled in. | 365 days |
| _hjMinimizedTestersWidgets | Hotjar cookie. This cookie is set once a visitor minimizes a Recruit User Testers widget. It is used to ensure that the widget stays minimizes when the visitor navigates through your site. | 365 days |
You may access any personally identifiable information we have about you by contacting Sean McCarthy, Chief Compliance Officer of Shorehill Capital LLC, at smccarthy@shorehillcapital.com.
NOTIFICATION OF CHANGES
We reserve the right to amend this Privacy Policy (and any jurisdiction-specific privacy notices) from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy (and any jurisdiction-specific privacy notices). Accordingly, users are strongly encouraged to review our Privacy Policy (and any applicable jurisdiction-specific privacy notices) regularly. If we decide to change our Privacy Policy (and any jurisdiction-specific privacy notices), we will post those changes on the Website so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Policy (and any applicable jurisdiction-specific privacy notices) under which the information was collected. Your continued access or use of this Website following the posting of changes to this Privacy Policy (and any applicable jurisdiction-specific privacy notices) means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy (and any applicable jurisdiction-specific privacy notices), please stop accessing this Website. Please check this page frequently and review any changes to this Privacy Policy (and any applicable jurisdiction-specific privacy notices) carefully so you are aware of any changes, as they are binding on you.
MISCELLANEOUS
The provisions in our Terms of Use are hereby incorporated by reference.
CONTACT US
If you have any questions or concerns about this Privacy Policy, or if you wish to appeal any of our decisions, exercise any of your rights hereunder or request to view this Privacy Policy in an alternate format, please contact Sean McCarthy, Chief Compliance Officer of Shorehill Capital LLC, at smccarthy@shorehillcapital.com.
CALIFORNIA WEBSITE PRIVACY POLICY
This California Website Privacy Policy supplements the Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
What does this California Website Privacy Policy apply to?
This California Website Privacy Policy applies solely to your interactions with us through our Website. If you provide personal information to use through another means (e.g., as an investor or an employee seeking employment) you will receive a separate privacy notice and that notice will govern that personal information.
What information do we collect about you?
The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
| Category | Examples | Collected |
|---|---|---|
| Internet or other similar network activity | Use of our website, (e.g., cookies), as well as information you provide to us when you correspond with us in relation to inquiries. | YES |
We do not knowingly collect or solicit personal information from anyone under the age of 18.
We do not collect or use sensitive personal information other than:
- To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
- As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
- As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
- For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
- To perform services on behalf of our business;
- To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
How do we use your personal information?
We collect personal information for the business or commercial purposes and from the sources set forth in “How we Use Your Information” and “Sources of Non-Public Information” respectively, in the Privacy Policy above. We retain the categories of personal information set forth above in the “What information do we collect about you?” section of this California Website Privacy Policy only as long as is reasonably necessary for those purposes set forth above in “How we Use Your Information”, except as may be required under applicable law, court order or government regulations.
Who do we disclose your personal information to?
We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
How do we keep your personal information secure?
We consider the protection of personal information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:
- the categories of personal information we collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties to whom we disclose the personal information;
- the specific pieces of personal information we have collected about you; and
- whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the “Contact us” section below.
Contact us
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
Call us using the following toll-free number: (312) 876-8632
Email us at the following email address: smccarthy@shorehillcapital.com
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent's authority to make requests on your behalf, and we may verify such authorized person's identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.
Please contact Sean McCarthy, Chief Compliance Officer of Shorehill Capital LLC, at smccarthy@shorehillcapital.com with any questions about this California Website Privacy Policy.
