Privacy Policy
Last Updated: June 30, 2021
1. Important information and who we are
Purpose of this privacy notice
This privacy notice describes how Delticus Group (“we,” “us,” or “our”) collects, uses, safeguards, and shares the personal information we collect through your use of www.delticusgroup.com website, and explains the choices you may have regarding the collection and use of your personal information. This privacy notice is not intended to override any other privacy notice we provide you in specific circumstances. If you have any questions about this privacy notice or how we treat your personal information, please contact us at:
PersonalData@delticusgroup.com, Delticus Holdco LP, The Corporation Trust Company, Corporation Trust Center, 1209 Orange St, Wilmington, DE 19801, U.S.A.
2. What personal information do we collect?
The term “personal information” when used in this privacy notice means, in each case, information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
We may collect, use, store, transfer, and share different kinds of personal information about you through our website, such as:
Personal information you provide us when getting in touch with us through the Contact Us form. This may include your name, email address, phone number, company, and any other information you provide in the comments.
Information that is passively or automatically collected from you, including your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and platform on the devices you use to access this website.
Usage information, namely, information about how you use our website including how long you spend on it, which pages you visit, and we can determine links that led you to our website.
We also may collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information but does not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific website feature.
The chart included below provides additional detail on the categories of personal information we collect and the purposes for which we use that personal information.
| Categories of Personal Information Collected | Business Purposes for Collection |
|---|---|
| Personal information you provide to us (e.g., name, email address, phone number) | • Marketing (including customer acquisition and lead generation and web traffic analytics) • Legal compliance |
| Information that is passively or automatically collected from you, including cookies, your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and platform on the devices you use to access this website | • Marketing (including web traffic analytics) • Operational purposes (including site functionality, anti-fraud and security of our website) |
| Usage information (e.g. information about how you use our website including how long you spend on it, which pages you visit, and we can determine links that led you to our website.) | • Marketing (including web traffic analytics) |
3. How is your personal information collected?
When you use or access our website we collect, or a service provider, such as our web host, on our behalf collects your personal information via the following means:
Voluntarily provided personal information. We collect personal information that you voluntarily provide when using our website, such as when you communicate with us via the Contact Us form.
Automated technologies or interactions. As you interact with our website, we or a service provider on our behalf, may automatically collect technical information about your equipment and browsing (such as IP address information). Further, we may use cookies technology (see Section 4) and other similar tracking technologies or web analytics tools to collect such information.
4. Cookies
We use web analytics tools (cookies) ensure functionality and security of the website. We also use cookies for analytics purposes, to better understand traffic to our website.
When you visit our website, you will have the opportunity to accept or reject certain cookies. You can also set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Some web browsers may transmit “do-not-track” (DNT) signals. We currently do not respond to DNT settings in your web browser.
We use cookies for administering the website and ensuring website security.If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
5. How do we use your personal information?
We may share your personal information with certain third parties as described below:
To service providers: We may share your personal information with service providers such as (i) our web hosting provider; (ii) third-party data centers and storage providers; and (iii) analytics providers (e.g., Google Analytics). All personal information you provide to such service providers is subject to the privacy policy or notice of such service providers.
To business partners: We may share your personal information with a limited number of business partners.
As required by law or to protect our clients and services. We may disclose your personal information to third parties such as law enforcement if we believe disclosure is necessary under applicable law or appropriate to prevent harm or loss, or in connection with an investigation of suspected or actual illegal activity.
As part of certain business transfers. We may disclose your personal information in connection with a corporate business transaction, such as a potential or consummated merger, acquisition, or joint venture, or for the financing or sale of our assets and could be transferred to another party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy, or receivership.
We do not sell personal information.
6. How long do we use your personal information for?
We will only retain your personal data for as long as necessary to fulfill any lawful purposes we collected it for. In most cases, this will mean that we keep personal information about you for the period of three years.
7. How do we secure your personal information?
We use reasonable technical, administrative and physical security measures to protect your personal information. We of course cannot guarantee that any information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from unauthorized access or use. You use the website at your own risk.
8. Children’s privacy
Our services are not directed at individuals under the age of 18. We do not knowingly collect information from children under the age of 18.
9. Third-party links
This website may include links to third-party websites controlled and maintained by other third parties and subject to their own privacy notices. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites, and we assume no liability or responsibility for such websites, the content contained thereon or the manner in which any information collected on such websites are used. This privacy notice does not govern the use of information collected on such third-party websites. Your use of such websites is governed by the privacy notices available on any such third-party websites and we encourage you to read those privacy notices carefully.
10. Changes to this privacy notice
We may change this privacy notice from time to time and will make it available on this website. If we make material changes, we will post the updated policy on this page and change the date at the top of this privacy notice.
11. Information Collected from Individuals in the European Union and European Economic Area and the United Kingdom
Purposes for which we will use your personal information
The table below describes how we may use your personal information and on what basis. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information on more than one basis depending on the purpose for which we are using your information. Please contact us if you have questions or would like further information.
| Purpose/Activity | Type of Information | Legal Basis for Processing |
|---|---|---|
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Technical & Usage | Your consent and necessity for our legitimate interests of running and safeguarding our business, providing administration and IT services, ensuring network security, and preventing fraud (Art. 6/1/a and Art. 6/1/f GDPR) |
| To use data analytics to improve our website, products/services, marketing, investor relationships and experiences | Technical & Usage | Consent and necessity for our legitimate interests to keep our website secure, functional, updated, and relevant (Art. 6/1/a and Art. 6/1/f GDPR). |
Your legal rights
You have various rights under the EU General Data Protection Regulation (2016/679) (“GDPR”), the United Kingdom’s Data Protection Act 2018, and the GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 in relation to the personal information we hold about you. These include:
the right to request access to your personal information and obtain a copy of the information we hold about you;
the right to correct your personal information that we hold where it is incomplete or inaccurate;
the right to have your personal information erased where there is no good reason for us continuing to use or retain it;
the right to request that your personal information is used only for restricted purposes;
if the lawful basis for processing your personal information is either our or a third party’s legitimate interests, the right to object to your personal information being processed;
the right to require certain of your personal information to be transferred to you or a third party; and
the right to lodge a complaint with the relevant data protection authority in your jurisdiction (to find your local Data Protection Board please click HERE, the UK residents please click ICO - make a complaint).
If you wish to exercise any of these rights, please contact PersonalData@delticusgroup.com.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or detailed. In this case, we will notify you and keep you updated.
12. Information Collected from Individuals in California
Your legal rights
Under the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.) (“CCPA”), if you are an individual who is a resident of California and whose personal information we collect and process, you may have certain legal rights with respect to such personal information. These include:
The right to request access to any of your personal information that we collect dating back one year before the access request is made. Specifically, you have the right to ask that we disclose:
(i) the categories of your personal information we have collected;
(ii) the categories of sources from which we collect your personal information;
(iii) the business or commercial purpose for collecting your personal information;
(iv) the categories of third parties with whom we share personal information;
(v) the specific pieces of your personal information we have collected; and
(vi) if we disclosed your personal information for a business purpose, a list of the categories of personal information we have disclosed in the prior 12 months.
The right to request that we delete your personal information. We will not delete personal information if we need it in order to fulfill our obligations to you, to protect the security or functionality of our operations, to comply with legal and regulatory obligations, or for certain other reasons.
If you wish to exercise any of these rights, please contact PersonalData@delticusgroup.com or call us at toll free number 1-866-803-3661 between 9:00 a.m. and 6:00 p.m. Eastern Time. You must provide enough information that we can verify who you are and that you are a California resident. We will respond to your requests within the applicable time periods and in the manner prescribed by the CCPA.
Only you, or a person registered with the California Secretary of State that is authorized by you to act on your behalf, may submit a request for access to, or deletion of, personal information.
We will not deny services, charge different prices, offer a different quality of service or otherwise discriminate against an individual for exercising the rights afforded to such individual under the CCPA.