Weathergage Capital knows that your privacy is important to you, and we want you to know that it is
important to us too.  We created this Policy to explain the types of information we collect through our Web sites on which it is posted and the various social networking platforms that we use (each, a “Site”), how we will use, disclose and protect this information once it is collected, and how you can opt-out of some of our uses and disclosures of your information.

Here are a few general principles to keep in mind as you read through this Policy:

• The Site is owned and operated by Weathergage Capital, LLC and its affiliates (referred to collectively in this policy as “we,” “us,” “our” and other similar pronouns).
• As our business evolves, this Policy may change, so check back to this page periodically to make sure you understand how your personal information will be treated.

• This Policy does not apply to:
• Information that you may provide, or that we may obtain, through your account hosted by Intralinks, Inc. that you may be able to access by following a hyperlink on the Site.  Such information is subject to the Intralinks Privacy Policy available on its website, which we encourage you to read to learn about the treatment of such information.
• “Nonpublic personal information” (as defined by the Gramm-Leach-Bliley Act) about individuals who have obtained a financial product or service from us that is to be used primarily for personal, family or household purposes. Such information is subject to the privacy notices that we provide to such individuals pursuant to the Gramm-Leach Bliley Act and applicable regulations promulgated thereunder.
• Information that you may provide to us, or that we may obtain, other than through the Site, such as over the phone, by mail, or in person.

• Advertisements displayed to you online may be customized to your interests and preferences based on your personally identifiable information and Web site usage Information collected through the Site unless you opt out by following the instructions that can be found here (Network Advertising Initiative) or here (AboutAds).  (You have to opt-out using each of your Web browsing applications and devices separately.)  However, if you opt-out we may still suggest offerings to you on the Site based on your history at the Site.

You may have the right to opt in to or opt out of certain of our uses and disclosures of your Personal Information.  For example, when you are asked to provide Personal Information on the Site, you may have the opportunity to elect to, or not to, receive our promotional messages by sending us your name, address, e-mail and phone number to: contactus@weathergagecapital.com. Please indicate whether you are writing to request that you no longer receive a particular media notification from us.  You can also opt-out of our promotional emails by clicking on the opt-out link within the e-mail you receive.  Please understand that it may take us a few days to process any opt out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.  To stop receiving promotional messages from third parties, including Intralinks, Inc., please contact them directly.

“Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information.  We may collect Personal Information such as your name; Company name; postal addresses; e-mail addresses; telephone numbers; site browsing and transaction history; and information about your interests or activities that you provide to us.  For example, we collect Personal Information when you sign up for our newsletters; or submit a comment or question to us using a “contact us” or similar feature on the Site.

As is the case with many Web sites, our servers automatically collect your IP address when you visit the Site, and we may associate that with your domain name or that of your Internet access provider.  We may also capture certain “clickstream data” pertaining to your Site usage.  Clickstream data includes, for example, information about your computer or device, Web browser and operating system and their settings, the referring page that linked you to the Site, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next Web site you visit when you leave the Site, and any search terms you have entered on the Site or a referral site.

Among other things, this information enables us to generate analytics reports on the usage of the Site.  We utilize Google Analytics, Woopra, and Pardot (a Salesforce service) for our web analytics.  We encourage you to read the privacy policies of our web analytics service providers for information about their practices.  To opt-out of your Site Usage Information being included in our Google Analytics reports, you may follow the instructions available at tools.google.com/dlpage/gaoptout.

In addition, we may deploy various tracking technologies on the Site to collect additional information about your Site visits. For example:

• Cookies are small data files stored on your computer or device at the request of a Web site.  A cookie assigns a unique numerical identifier to your Web browser, and may enable us to recognize you as the same user who was at the Site in the past, and relate your use of the Site to other information about you, such as your Site Usage Information and Personal Information.  Cookies may also be used to enhance your experience on the Site (for example, by storing your username so you can log in easily, keeping you logged into the Site after you have provided your password, and storing the contents of your shopping cart as you browse) or to collect general usage and aggregated statistical information and detect and prevent fraud.  Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of the Site or its features.  To learn more about the use of cookies, including how to manage or delete them, visit allaboutcookies.org/.
• A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Web pages.

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number to you, and relate your Site Usage Information to other information about you, including your Personal Information. These technologies may also enable us and/or our service providers or partners to recognize you when you access the Site using different Web browsers and different computers or devices.

By using our Web Site, you consent to our use of these tracking technologies as described above.

We or our service providers may use the information we collect from and about you to perform the following business functions:

• enabling users to use the Site and its features
• processing and fulfilling your transactions
• administering the Site and your account with us
• responding to your requests, questions, and concerns
• market research
• improving and developing new features and offerings
• sending you marketing and other communications, including information about products, services, and events, of ours and of others, that we think might interest you. You may opt out of receiving such notices from us by following the instructions in the Opt In and Opt Out section above.
• protecting our rights and property
• recovering debt and preventing fraud
• customizing the Site to your interests and history with us
• tailoring ads displayed to you online to your interests and history with us
• other purposes disclosed when personal information is submitted to us

To perform the above functions, we may match information collected from you through different means or at different times, including both Personal Information and Site Usage Information, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information.  We or our service providers may also use your information to assess the level of interest in, and use of, the Site, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.

We maintain presence on several social networking and blogging platforms, such as Twitter, Facebook and LinkedIn, and we may also incorporate some third party social networking features onto the Site.  Through these platforms and features, we may receive some Personal Information and some Site Usage Information about you, and this Policy applies to that information as well.  In addition, third party social networking platforms and blogging platforms have their own privacy policies which explain how the third parties that provide them will use and protect your information.  In accordance with those policies (and your privacy settings within your social networking accounts), you may be able to use tools on the Site to share and/or publicly post content or information from the Site to your profile on a third party social network.

Yes.  We may share the information we collect on the Site with others for a variety of reasons.  In addition to the kinds of information sharing you might expect, such as sharing with third parties who need your information in order to provide services to us (or on our behalf) or administer your account with us, we may share your information:

• when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law
• in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business

In addition, we may share non-personally identifiable Site Usage Information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.

We may use third-party advertising companies to serve ads when you visit certain online properties.  These companies may use information about your visits to this and other Web sites, the region of the country or world where your IP address indicates you are located, as well as other information about you in order to provide advertisements about goods and services of interest to you.  These advertisements may appear on the Site and on other Web sites.  These companies may employ cookies, clear GIFs and other tracking technologies to cause relevant ads to be displayed to you.  We encourage you to read these businesses’ privacy policies to learn about how they treat your information.  For more information about third-party advertisers and how to prevent them from using your information, visit the NAI’s consumer Web site at networkadvertising.org/choices/ or Aboutads.info at aboutads.info/choices/.

Some web browsers may transmit “do-not-track” (DNT) signals to the websites with which the user communicates.  Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them.  We currently do not change our tracking practices (which are explained in more detail under “Site Usage Information” above) in response to DNT settings in your web browser.

Our third party partners, such as web analytics companies and third party ad networks, may collect information about your online activities over time and across the Site and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. We utilize Google Analytics, Woopra, and Pardot (a Salesforce service) for our web analytics.  You can opt out of your Site usage data being included in our Google Analytics reports by visiting tools.google.com/dlpage/gaoptout.

Weathergage Capital knows that your privacy is important to you, and we want you to know that it is
You may review, update or modify certain of the Personal Information by contacting us using the “Contact Us” information below.  We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information.  Your right to delete your information is subject to our records retention policies.

While we endeavor to protect the security and integrity of sensitive Personal Information collected via the Site, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

If you correspond with us or our service providers or partners by e-mail, using Web forms like a “contact us” feature on the Site or other electronic means, you should be aware that your transmission might not be secure.  A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

If at any time during or after our relationship we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you of that development.  If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances.  If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us.  Please keep your e-mail address in our records up to date.  You can change that e-mail address by contacting us using the “Contact Us” information below.  If you receive a notice from us, you can print it to retain a copy of it.  To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification.  If you prefer for us to use the U.S. Postal Service to notify you in this situation, please contact us using the “Contact Us” information below.  You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request.  You may also contact us using the “Contact Us” information below to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.

The Site may contain links, banners, widgets or advertisements that lead to other Web sites, including to your account, if applicable, with Intralinks, Inc. or another third party.  We are not responsible for these other sites, and so their posted privacy policies (not this Policy) will govern the collection and use of your information on them.  We encourage you to read the privacy statements of each Web site visited after leaving the Site to learn about how your information is treated by others.

We may change this Policy from time to time.  When we do, we will let you know by posting the changed Policy on this page with a new “Effective Date.”  In some cases (for example, if we materially expand our use or sharing of your Personal Information),  we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you.   In some cases, we may request your consent to the changes.

If you have any questions or comments regarding our privacy practices, you may contact us using the form available at: Contact Us