LDR Capital Management, LLC (“LDR”) website (“Site”). This Site is offered as a service to our investor community. LDR values your business, loyalty, and confidence in our services. We are committed to the protection of personal privacy. To better protect your privacy, LDR provides this notice explaining our information practices and the choices you can make about the way your information is collected and used.
PERSONAL INFORMATION COLLECTION
LDR may collect personal information like name, telephone number, email address, date of birth, home or business mailing address when you register for services or provide your contact information on this Site.At other times, LDR may collect information that cannot be used to identify you. For example, we may aggregate non-personal information about visitors to our Site. Aggregated information will not contain any information that can be linked directly back to you.
HOW LDR COLLECTS PERSONAL INFORMATION
LDR may use any number of tools to collect information about you, your computer access points, and the web browser that you use to connect to our Site. For example, cookies are tiny text files that we place on your computer’s hard drive when you visit our Site. You do not have to accept our cookies and you may delete them after they have been placed on your hard drive. If you do not accept or if you delete our cookies, some areas of our Site that you access may take more time to work, or may not function properly.LDR may also collect additional information from your web browser each time you visit our Site. We may collect information on the pages that you visit and other actions that you take while using our Site. This information may include your Internet Protocol (“IP”) address, the type of browser, the time that your browser was used to access our Site, and the referring website address.Our Internet Service Providers (defined below) may also use other standard web-based technologies to analyze your movements while accessing our Site. The technologies include web “beacons,” “pixel tags,” and “clear gifs.” These technologies help us rate the effectiveness of our product and service programs, allow us to customize the services offered on or through our Site, and help determine the best use for Site content. Some of this information, including the IP address, may be stored on our Internet service provider’s server logs, and may be available for extended periods of time.
OUR USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
LDR uses the services of independent companies to provide certain services to you, including, for example, website hosting services (“Internet Service Providers”). LDR may share your personal information with the Internet Service Providers as appropriate. We will not share or sell personally identifiable information with outside third parties without your consent, except to the extent necessary to complete your request for services offered through this Site.LDR may use your personal information to contact you via mail, email, or telephone in order to give you updates about our services. We also use return email addresses to answer the email we receive from you. Your email address will not be used for any other purpose or shared with outside third parties for their direct marketing purposes. We may also use your IP address to help protect LDR and our Internet Service Providers from fraud.Additional uses of your non-personal and personal information will allow us to tailor Site content and other services that are specific to your needs, to help organize and manage our relationships and business, to conduct business, to provide you with customer support, to perform functions that are described to you at the time of collection, and to enforce our Site’s Terms and Conditions of Use.We may also use non-personal aggregate information to improve our Site. For example, our Internet Service Providers may report to us that there were a particular number of visitors to certain areas of our Site, or that there were a particular number of visitors from a certain geographic region. Such information may be used to analyze the effectiveness of our business models.LDR may also disclose your personal information as is necessary to: (a) comply with a subpoena or court order; (b) cooperate with law enforcement or other government agency; (c) establish or exercise our legal rights; (d) protect the property or safety of our company and employees, contractors, vendors, and suppliers; (e) defend against legal claims; (f) help with internal and external investigations; or (g) as otherwise required by law or permitted by law. We may disclose your information in connection with the sale or merger of LDR or any transaction that involves the sale or assignment of some or all of our assets.
DATA STORAGE AND SECURITY
LDR makes reasonable efforts to ensure that our Internet Service Providers have implemented physical, electronic, and procedural security measures to assist with safeguarding your personal information, and to help protect against unauthorized access and disclosure. Only our authorized personnel and our Internet Service Providers, who perform legitimate business functions for LDR are authorized to access your personal information. Notwithstanding our efforts, the Internet has inherent security risks. LDR cannot promise, and you should not expect, that your personal information transmitted via the Internet, Internet searches, and other Internet communications will always remain secure.
CHILDREN AND DATA COLLECTION
LDR’s Site is a general information website. LDR’s content is neither directed toward minors, or anyone under the age of majority in an individual’s state of residence. We do not knowingly collect personal information from minors, or any one under the age of majority. If LDR or its Internet Service Providers become aware that a minor or individual under the age of majority has provided us with personal information, that information will be deleted from our databases.
YOUR CALIFORNIA PRIVACY RIGHTS
LDR will not share any personal information about you with outside third-parties for their direct marketing purposes to the extent prohibited by California law, unless you agree otherwise as authorized by your prior written consent.California residents have the right to request information from LDR regarding the manner that we may share personal information with affiliated companies and third parties for their direct marketing purposes. To find out what and how we share such information, you may send us an e-mail request at info@ldrcapitalmgmt.com or mail a request to: Controller, LDR, Carol Hutchings, and receive the following information:
The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year, if any.
The names and addresses of the third parties who received information for their direct marketing purposes; and
Examples of the products and services subject to the third-parties’ direct marketing programs, if the nature of the third parties’ business cannot be determined from their names.
HOW YOU MAY ACCESS AND CHANGE THE INFORMATION THAT LDR COLLECTS
The first time that you provide us with registration information through our Site, you may be offered the opportunity to subscribe to and receive additional information about our products and services. After your first use, you can change your initial choices by contacting customer service email at info@ldrcapitalmgmt.com. Each commercial email that we send to you, will offer you the opportunity to opt-out of continuing to receive such messages. We may take up to 10 business days to process your opt-out requests. In some instances, we may have already shared your information with one of our authorized third parties before you changed your information preferences. In those cases, you may have to directly contact those third parties to opt-out of receiving their communications. FTC email compliance guidance allows us to send you transactional and relationship email without offering you the opportunity to opt-out of receiving those types of email.
GENERAL INFORMATION AND PRIVACY SUPPORT CONTACT
LDR may update this privacy policy from time to time, and you should take the time to review it each time that you visit our Site. If you require additional information about LDR’s privacy commitment, please contact us at info@ldrcapitalmgmt.com.