Effective: January 1, 2023
This Privacy Policy describes how Gallant Capital Partners, LLC (“Gallant,” “us,” “we,” or “our”) collects, uses, discloses and otherwise processes your personal information, including in connection with this website (the “Website”), our social media pages, the services that we provide, and other online or offline interactions (the foregoing collectively referred to as “Services”).
IMPORTANT NOTE: By accessing or using the Services, you expressly consent to our collection, use and disclosure of your personal information in accordance with the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms of Use (“Terms”), available here.
- Collection of Information
What is Personal Information? This Privacy Policy applies solely to the collection and use of personal information. Personal information is any information that identifies or relates to an identifiable natural person. This includes information such as name, mailing address, email address and telephone number. Personal information does not include aggregated or anonymized data.
Information You Provide Directly to Us. When you access certain parts of the Website or engage our Services, you may directly provide personal information to Gallant, including contact information such as name, email, mailing address and phone number. For example, you may provide us with this information when registering for an event, subscribing to a newsletter or other publication that we offer. If you are an investor, you may also provide us personal information when registering for an Account. [Account information may contain contact information (such as name, email, mailing address and phone number), as well as financial information. In some cases, we may have direct or indirect access to certain tax and financial information of our investors, as required for regulatory, compliance or financial reporting purposes. This includes information that is available on various IRS forms (including name, mailing address and social security number), as well as “know your customer” information” that is reported to various regulatory bodies or financial institutions (including name, mailing address, date of birth, passport number and driver’s license number).
Information Collected Automatically. When you access and use the Website or engage with our emails, Gallant may use various analytics tools and cookies to automatically collect usage information such as IP address, web browser information, mobile device unique number, mobile software and hardware information, pages or areas visited within the Website, what time said pages and areas are visited and email links opened. Please see our Cookies Notice here for more information on our use of cookies.
Recruiting Information. If you apply for a job with Gallant, including through any careers page of the Website, discuss a potential job opportunity with us or attend one of our recruiting events or interviews, we may collect information such as name, phone number, email address, educational background and job history (or other curriculum vitae information). This information may be collected in a variety of ways, including directly from you or via a third party such as a recruiting agency, educational institution, prior employer, professional reference or credentialing and licensing organization.
Social Media. When you engage with one of our social media pages, such as on LinkedIn, we may collect information about you, including from tracking pixels. These pixels provide non-identifiable and anonymous data (e.g., demographic information) regarding how users interact with such pages. You may opt out of this tracking in some cases by changing the privacy settings on your social media account. For information on LinkedIn’s privacy settings, see https://www.linkedin.com/psettings/.
Information from Public Sources. We may collect your personal information from publicly available sources such as public governmental databases or company registries. Note that if you post personal information to a publicly available portion of the Website or via our social media pages, you understand and acknowledge that such information may be made available to other users or the general public. We may combine personal information collected from public sources with other personal information we receive or collect.
Information from Private Sources. We may collect your personal information from various private sources outside of Gallant, including parties involved in transactions in which Gallant participates, financial institutions, governmental entities or regulators. We may combine personal information collected from private sources with other personal information we receive or collect.
- Use of Information
We and our service providers may use your personal information for a variety of purposes permitted under applicable law, including the following business purposes:
- To provide you with Services and otherwise respond to your inquiries and requests.
- To provide you with marketing materials, newsletters, publications, events and seminars that you have requested, enrolled in or opted into.
- To perform a contract between you and Gallant, such as if you are an investor.
- To improve or modify the Services.
- To analyze the effectiveness of our Services and our marketing efforts.
- To meet legal and regulatory requirements and to respond to legal orders.
- To keep records of our interactions with you.
- For auditing purposes.
- To monitor for fraud.
- To monitor for and debug technical issues.
- To monitor for security events (including cybersecurity issues).
- For any other purpose with your consent.
In each case, we will use your personal information only to the extent: (i) we have your consent to use such information for a given purpose; (ii) it is necessary to perform a contract between you and Gallant; (iii) it is necessary to comply with a legal obligation; and/or (iv) it is necessary for the purpose of Gallant’s or a third party’s legitimate business interests (provided that such interests are not in conflict with your rights under applicable law).
- Disclosure of Information
We do not sell or rent your personal information to third parties for monetary or other valuable consideration and have not done so in the prior twelve (12) months since the effective date of this privacy policy. We disclose personal information within Gallant, with service providers who enable us to provide Services, in connection with a Transaction (defined below) or if otherwise required to do so under applicable law or legal process. Our service providers may include:
- Website providers or hosts
- Cloud service providers (or other data storage providers)
- Various information technology (IT) support vendors
- Marketing firms
- Insurance agencies
- Forensic firms
- Accounting firms
- Consulting firms
- Law firms
- Business partners (e.g., event sponsors)
We may disclose your personal information if we have a legal obligation to do so, including if needed to:
- Comply with applicable law.
- Respond to or cooperate with requests from governmental entities or law enforcement.
- Enforce the Terms or this Privacy Policy.
- Protect the rights, property or safety of Gallant, our users (including clients) or the public.
- Transaction
If Gallant merges with another entity, if Gallant sells its assets, business or equity to another entity, or if Gallant undergoes an insolvency proceeding (each referred to as a “Transaction”), we may disclose your personal information to an acquiring entity (or potential acquiring entity) and its advisors. While Gallant will use commercially reasonable efforts to ensure that such acquiring entity (or potential acquiring entity) treats such personal information in accordance with this Privacy Policy at the time of the Transaction, Gallant makes no guarantees as to whether such entity will treat your information in accordance with the Terms (including the Privacy Policy), and Gallant therefore disclaims any liability arising out of such entity’s failure to do so.
- Google Analytics
This Website may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) that uses cookies to track how users navigate the Website. Please see our Cookies Notice here for more information on our use of cookies. This service may also collect information regarding your use of other websites and applications. You may refuse the use of these cookies via the settings in your browser. You also can opt out of being tracked by Google Analytics by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: https://tools.google.com/dlpage/gaoptout.
- Do Not Track
Your browser may offer you a “Do Not Track” option, which allows you to signal that you do not want them to track your online activities. The Website does not currently support Do Not Track requests.
- Storage and Retention of Information
We retain personal information for as long as necessary for the purposes that such information was obtained. We use the following criteria to determine the length of the retention period: the duration of our relationship with you (including if you are an investor), whether there are legal requirements to retain the information (such as any financial or regulatory reporting requirements) and whether we deem retention necessary in connection with potential legal claims or positions.
- Protection of Information
Gallant takes commercially reasonable steps designed to protect personal information that you provide us by employing appropriate physical, technical and administrative security measures. Despite the security procedures we employ, you should be aware that it is impossible to guarantee the security of information that you transmit to us via the Internet. Your transmission of your personal information to us via the Website is done entirely at your own risk.
- Third-party Websites
This Website and other Services may contain links to other websites that are not maintained or controlled by Gallant. Gallant is not responsible for the privacy practices (if any) of such other websites, and you are encouraged to review their privacy policies (if any). The fact that a link to a third-party website exists on the Website or other Services does not mean that the third-party site operates under the same or similar privacy practices as set forth in this Privacy Policy. The policies and procedures that Gallant describes here do not apply to third-party websites. If you access a third-party website using a link, then you do so at your own risk. You acknowledge that your access of any links to social media features on the Website and other Services (e.g., links to LinkedIn, etc.) is governed by the terms of use and privacy policies of the companies providing such social media features.
- International Transfers and EEA Rights
Please note that Gallant is a private investment fund headquartered and located solely within the United States. As of the effective date of this Privacy Policy, Gallant does not operate any offices outside of the United States, including any offices in the European Economic Area (EEA). If you are a visitor to this Website, and you reside outside of the United States (including in the EEA), please note that in providing any personal information to us via the Website or other Services, you may be providing information to a jurisdiction (the United States) whose laws may not provide the same level of protection for personal information as that provided in your home country. If you do not wish to have your personal information made available to Gallant personnel outside your home jurisdiction, please do not provide it to us via the Website or any other means.
- Minors
We do not promote, market or direct Services to minors. As a result, Gallant does not knowingly collect or solicit personal information from anyone under the age of 18. By using our Website or by providing us your personal information, you represent that you are not under 18 years of age.
- Notification of Changes
Gallant reserves the right to revise this Privacy Policy at any time. If we make substantial changes to this Privacy Policy, we will endeavor to notify you of such changes (e.g., by email or an alert on the Website for a period of time). However, regularly reviewing this page is the best method to ensure you are always aware of the information Gallant collects, how it is used and under what circumstances.
- Opt-Out; Contact Us
You may stop or opt out of email messages and other promotional mailing us via e-mail at privacy@gallantcapital.com or via regular mail at 1800 Avenue of the Stars, Suite 1450, Los Angeles, CA 90067. You may also contact us via email or regular mail to change information you previously provided, or to request information or ask questions concerning this Privacy Policy, the Terms or any other notice posted on our Website.