Updated January 2023

Your privacy is important to us. This Privacy Policy describes the types of information High Road Capital Partners, LLC, (“High Road” or “We”) may collect from you when you visit our website www.highroadcap.com and investor reporting website (collectively, the “Website”) or otherwise interact with us online.

This Privacy Policy also explains how High Road may use and disclose your information, as well as your ability to control certain uses of your personal information.  This Privacy Policy is in addition to any separate annual Privacy Notice that High Road may send you under applicable privacy law.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy.

INFORMATION COLLECTION

Information You Provide

We collect information from you when you choose to share it with us. This may include when you visit our Website or contact us.

The information we collect from you may include:

• Contact information, including your name, address, email address, telephone, mobile, or fax number;
• Employer-related information, such as your title and the company’s name, address, phone number, and website;
• Your search queries on the Website;
• Information that you provide by filling in forms on our Website, including information provided when you update an investor account;
• Records and copies of your correspondence (including email addresses), if you contact us;
• Geolocation of any computer, mobile device, or other electronic device used to access the Website.

Information Collected from Third Parties or Other Sources

We may obtain personal or other information about you from third parties or other sources and combine this information with the information we collect from you.  This might include any other information obtained through companies that have business relationships with us, such as our licensees, affiliates, and business partners.

We may also obtain information about you from other online sources, including when you connect with High Road through its official business pages on third-party social networks (such as LinkedIn) or the “apps” on those pages.  This information may include your name, username, demographic information, updated address or contact information, interests, and publicly observed data.  We may combine this information with the information we collect from you through our Website.

Information Automatically Collected

As with many other websites, as you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, language, date and time of access, frequency, and other communication data and the resources that you access and use on the Website;
• Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type;
• Details of referring websites (URL).

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit High Road, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We may also use third-party cookies and other technologies to support our Website, provide services on our behalf, or provide relevant advertising to you. Some of these third parties may use technology such as cookies, web beacons, pixel tags, log files, or Flash cookies on our Website or apps, which may send them some of the above-referenced information. The use of this information by those third parties will be governed by their own privacy policies. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Deletion of Cookies, Tracking Options, and California Do Not Track Disclosures

You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Website. Please refer to your web browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences.

Our system may not respond to Do Not Track requests or headers from some or all browsers. To learn more about the use of cookies or other technologies to deliver more relevant advertising and to know your choices about not having this information used by certain service providers, please visit http://www.aboutads.info/choices/.
On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

INFORMATION USE

High Road may use the information we collect from and about you for any of the following purposes:

• To deliver High Road’s services to you;
• To enhance your online experience, including as a way to recognize you and welcome you to the Website;
• To review the usage and operations of our Website, and improve our content and services;
• To recognize your online activities over time and across different websites and devices;
• As applicable and with your consent where applicable, to contact you with information, newsletters, and promotional materials from High Road or on behalf of our business partners, licensees, and affiliates;
• With your consent where applicable, to serve ads or send direct messages through emails or third-party services (including social media platforms) that are targeted to reach people on those services who are identified in our databases. This may be done by matching common factors between our databases and the databases of third-party operators;
• To contact you when necessary, including for employment purposes, by email, telephone, text message, or by mail;
• To use your data in an aggregated non-specific format for analytical and demographic purposes;
• To address problems with services provided to you, or our business;
• To protect the security or integrity of the Website, and our business, such as by protecting against and preventing fraud, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorized users; and
• As otherwise described to you at the point of data collection.

INFORMATION SHARING

High Road may disclose the personal information we collect from you in the following ways:

• With our subsidiaries and affiliated companies;
• With our third-party service providers that provide business, professional, or technical support functions for us;
• As necessary if we believe that there has been a violation of our Terms of Use or of our rights or the rights of any third party;
• To respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law or otherwise as required by law;
• As otherwise described to you at the point of collection; and
• With your consent.

High Road may also share aggregate or anonymous non-personal information with third parties for their marketing or analytics uses.

We may share your personally identifiable information (“PII”) in connection with a merger, financing, acquisition, dissolution transaction, bankruptcy, or proceeding involving sale, transfer, or divestiture of all or a portion of our business. If another entity acquires our business, that entity will have your PII collected by us and will assume the rights and obligations regarding your information as allowed by this Privacy Policy.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your information:

Promotional Materials from High Road

If you do not wish to have your contact information used by High Road to share promotional materials, including press releases and investor-related materials, you can opt out by following the opt-out instructions included in the emails or mailings, or by contacting us. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
 

YOUR STATE PRIVACY RIGHTS

If you are a California, Colorado, Connecticut, Nevada, Utah, or Virginia resident, your state laws may provide you with additional rights or choices regarding our use of your personal information.

Please see Your California Privacy Rights, or local state digital privacy laws, for more information.

For example, if you are a California resident, you may request information about our disclosure of personal information, if any, to third parties or affiliated companies for their direct marketing purposes. You also have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local, and non-U.S. laws, rules, and regulations. To make such a request, please email us at compliance@highroadcap.com.

You must put the statement “Your California Privacy Rights” (or applicable home state) in the subject field. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Non-affiliated third parties are independent from High Road, and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.

LINKS TO OTHER WEBSITES

The Website, and email messages from us, may contain links to third-party websites, which may have privacy policies that differ from our own. You should be aware that the collection, retention, and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this Privacy Policy. We are not responsible for the practices of such websites.

DATA SECURITY

We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our Website visitors. While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures, and any transmission of personal information is at your own risk.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential, and changing it often to ensure it is strong. We ask you not to share your password with anyone.

DATA STORAGE

Your personal information may be stored on servers in the United States and is subject to the laws of the United States, where the data protection and other laws may differ from those of other countries. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.

YOUR OPTIONS AND ACCESS TO YOUR PERSONAL INFORMATION

To access, review, or update your information stored by High Road, you may contact compliance@highroadcap.com to have them update your information in our system. If you have any additional questions concerning access to or updating your personal information, please contact us at the information provided in the “Contact Us” section below.

California and Nevada residents may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

REVISIONS TO THIS PRIVACY POLICY

High Road reserves the right, at its sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page. If we do, we will provide access to the immediately prior version of the Privacy Policy on the Website. Your continued use of the Website following the posting of changes to these terms means you accept these changes. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

CONTACT US

We hope this Privacy Policy answers your questions about our collection, use, and disclosure of your personal data. If you have additional questions about this Privacy Policy or the practices described herein, you may contact us by email at compliance@highroadcap.com or write to us at the following address:
High Road Capital Partners
ATTN: Compliance Department
15 E. Putnam Ave., Suite 3110
Greenwich, CT 06830