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Cruz Capital Management LP  |  Privacy Policy

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PAR# 44.23.2020

 

 

Unless otherwise agreed to in writing by Cruz Capital, by using the website and portals of Cruz Capital, you agree to the following Terms and Conditions of Use Policy without limitation or qualification. Please read these terms and conditions carefully before using Cruz Capital’s website or portals. If you do not agree with the Terms and Conditions of Use Policy, you are not granted permission to use Cruz Capital’s website and portals.

 

All references in this Terms and Conditions of Use Policy to “we,” “us,” or “our” shall refer to Cruz Capital and its subsidiaries. All references in this Terms and Conditions of Use Policy to “you” or “your” shall refer to the users of Cruz Capital’s website and portals.

SECTION D.

D1. Cruz Capital (or its affiliates, subsidiaries or divisions) committed to preserving the confidentiality of all individually identifiable and proprietary information about our clients, potential clients, and employment candidates. By visiting or submitting data through this “Website” you are accepting and consenting to the provisions set forth in this Privacy Policy. If you do not agree to this Privacy Policy, you are instructed not to use this “Website”.

 

D2. Scope

 

This Privacy Policy covers only data collected through the “Website” ("Data") and not any other data collection or processing, including, without limitation, data collection practices of other webpages to which we link or data that we or our affiliates collect offline or through web pages that do not display a direct link to this Privacy Policy.

 

D3. Types of Data and Collection Methods

 

A. Passively Tracked Data: During your use of this “Website” Cruz Capital (or its affiliates, subsidiaries or divisions), itself or through a third party vendor, passively collect technical and usage Data from you, the User, pertaining to your computer and/or Internet connection. Such Data may include the number and frequency of your visits to this “Website” information regarding websites accessed immediately before and after your visit to this “Website” your Internet browser type, your preferences on our “Website” and IP address. The technical and usage Data may be used by Cruz Capital (or its affiliates, subsidiaries or divisions) keep you informed about software compatibility issues and upgrades, to assist Cruz Capital´s web design team in maintaining and improving this ““Website”, and to enhance and/or personalize your visits to this “Website”. 


B. This technical and usage Data may be collected using "cookies", which is technology commonly used on other “websites”, or other similar means. In some instances, we use cookies to collect Data in connection with future visits from the “Website” to recognize you as a previous visitor and to track your activity on the “Website”. You do not need to have cookies turned on to visit our “Website” and can refuse cookies by turning them off on your browser. However, it is possible that you may not be able to utilize all the Website's features if you choose to do so.

 

D4. Actively Tracked Data

 

Cruz Capital (or its affiliates, subsidiaries or divisions) also collect and store Data, or engage a third party vendor to collect and store Data, voluntarily provided by you, the User, while visiting this “Website”. User-provided Data may include client login data, contact information, information related to the business you represent, information related to the financial information services you have requested, or information provided while seeking employment at Cruz Capital, (or its affiliates, subsidiaries or divisions) including but not limited to your resume or other personal information. In each such instance, you will know what data we collect through the “Website”, because you actively submit it to us.

 

D5. Combinations

 

Unless you also actively submit personal information, such as your name or address, passively tracked Data does not typically allow us to identify you personally. To the extent permitted by applicable law, we reserve the right to combine passively tracked Data with personal Data that you actively submit.

 

D6. Accessing and updating your personal information

 

A. Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes.

 

B. When updating your personal information, we may ask you to verify your identity before we can act on your request. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).

 

C. Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction.

 

Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

 

D7. When this Privacy Policy applies

 

Our Privacy Policy applies to all of the services offered by Cruz Capital (or its affiliates, subsidiaries or divisions), including services offered on other sites (such as our advertising services), but excludes services that have separate privacy policies that do not incorporate this Privacy Policy. Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include Google services, or other sites linked from our services.

 

Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

PART 2

D8. Changes

 

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

 

D9. Opt-Out

 

In connection with promotions or other projects, we may ask you specifically whether you have objections against a certain kind of Data use or sharing. If you opt-out under such circumstances, we will respect your decision.

 

D10. Security

 

A. Transmissions over the Internet are never 100% secure or error-free. However, with respect to our internal security procedures, Cruz Capital takes reasonable steps to maintain physical, electronic, and procedural safeguards in order to protect your personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Cruz Capital also requires third party companies that we hire and to whom we disclose data to keep such information confidential and to use it only to perform the services for which we hire them and only under our instructions. It is your responsibility to safeguard any password and User ID you use to access the “Website” and to notify us at accounts ‘at’ cruz.capital or contact your account manager if you ever suspect that this password or User ID has been compromised. 

 

You are solely responsible for any unauthorized use of the “Website” conducted via your password and User ID at our main website www.cruz.capital 

 

B. We work hard to protect Cruz Capital and our clients from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:

 

  • We encrypt many of our services using SSL. [Opus Login]

  • We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.

  • We restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

 

D11. Collection Purposes and Use of Data

 

We generally collect Data for purposes of administering, protecting and improving our “Website” and our systems, to better understand the preferences of our “Website” visitors, to identify server problems, to compile aggregated statistics about Website usage, to help personalize your experience of our “Website” and to respond to your particular requests or submissions, e.g., an application for employment that you submit. When an individual representative of a Cruz Capital client or potential client submits Data in connection with the use of Cruz Capital products or services, we collect and process the Data as a data processing agent. In other words, we collect and process the Data only for the client's benefit, and for the purpose(s) for which you originally sent us the Data (e.g., to provide the services or products you requested).

 

D12. Disclosures of Personal Information

 

A. Cruz Capital (or its affiliates, subsidiaries or divisions) not sell or rent your personal and/or proprietary Data to anyone. 


B. We may share your Data as required by law or in the interest of protecting or exercising our or others' legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings.


C. We may share or transfer your Data in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business. Also, we reserve the right to fully use and disclose any Data collected via the “Website” that is not in personally identifiable form.

 

B13. Access

 

If personal Data you have submitted through the “Website” is no longer accurate, current, or complete, and you wish to update it, please send an e-mail to accounts ‘at’ cruz.capital.

 

Upon appropriate request we will usually be glad to update or amend your information, but we reserve the right to use Data previously obtained to verify your identity or take other actions that we believe are appropriate.

 

D14. Compliance and cooperation with regulatory authorities

 

We regularly review our compliance with our Privacy Policy. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities to resolve any complaints regarding the transfer of personal data that we cannot resolve with our clients directly.

https://www.cruz.capital/

CRUZ CAPITAL MANAGEMENT LP

CRUZ CAPITAL

The information on this site is provided by Cruz Capital Management L.P.  as general information and is intended for institutional and qualified accredited investors, as well as professional clients (as defined by local laws and regulation),  it should not be considered a comprehensive statement on any matter and should not be relied upon as such.

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