Bruin Capital
Privacy Policy

Thank you (“you” or “user”) for visiting the website of Bruin Capital Holdings, LLC. (together, “Bruin,” “we” or “us”). Your visit to this website (the “Site”) is subject to this privacy policy (“Privacy Policy”). By visiting the Site, you agree to this Privacy Policy, which may be updated by us at any time. If we update our Privacy Policy, we will post the updated document here. Any such changes will be effective upon posting. We urge you to review the Privacy Policy each time you visit the Site. If you do not agree with any provision of the Privacy Policy, you should not visit or use the Site.

This Privacy Policy does not concern your interaction with Bruin in any manner other than your use of the Site. This Privacy Policy also does not address our privacy practices with respect to any nonpublic personal information we may collect from you as an investor in investment vehicles managed or advised by Bruin. We address these practices in separate notices to investors or potential investors.

Your privacy is important to us. This Privacy Policy seeks to help you understand whether and how we collect information about you when you visit the Site, and how we use such information.

If you have any questions or comments about our Privacy Policy, you can email us at privacy@Bruincptl.com or write to us at Bruin Capital; 7 Renaissance Sq., Second Floor, White Plains, N.Y., 10601.

01. WHAT INFORMATION WE COLLECT

When you enter and browse the Site, we may collect two different types of information about you: information you provide to us and information we collect through technology. Bruin may retain any information collected through the Site for an indefinite period of time.

You may choose to contact us using links or contact information available on our Site. In such instances, you may provide information that we collect and store in a way that allows us to relate it to you personally, including but not limited to your name, e-mail address, mailing address and phone number. We refer to such information as personal information. Additionally, we may collect and retain a record of all communications with you, and we may monitor and record other activity on our Site for any reason or for no reason.

We may collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to the Site. At times, we may also use IP addresses to collect information regarding the frequency with which you or other users browse various parts of the Site. The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect and process information on our behalf. We may collect the information from use of these technical methods in a form that is personally identifiable.

During some visits to our Site, we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

If you continue to use the Site with a browser set to accepting cookies, we will assume that you accept receipt of all cookies coming from the Site.

03. GOOGLE ANALYTICS

We use Google Analytics to collect information about your use of the Site. Google Analytics collects information such as how often users visit the Site, what pages users visit, and what other sites they visited prior to or after coming to the Site. More information on how Google Analytics uses your data can be found at www.google.com/policies/privacy/partners/. We use the information we get from Google Analytics only to improve the Site. By using the Site with your browser set to accepting cookies, you consent to Google Analytics’ use of cookies on the Site.

04. HOW WE USE INFORMATION WE MAY COLLECT

Bruin does not disclose any nonpublic personal information about its Site users to any nonaffiliated third party, except as set forth below.

We may use or disclose certain personal information we collect about you or that you provide when you visit and browse the Site as part of our normal business operations, including to respond to requests from you. We may also use service providers in connection with the Site. These companies and individuals may have access to and use your personal information, as needed to perform their functions.

We will disclose personal information we collect from you when we believe that such disclosures are required by law, regulation, legal process, subpoena, document or governmental request. We may also do so to help enforce our Terms of Use, protect your safety or security, or protect the safety and security of tangible or intangible property that belongs to us, to you or to third parties. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Site and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

Also, in the event that Bruin, or any portion of our assets or businesses, are acquired by or merged with another entity, whether an affiliate or a third party, user information may be one of the transferred assets. We may transfer all user information (which may include personal information) to our acquirers or successors. Other than as part of such transaction, we will not sell any of your personal information without your consent.

05. PROTECTION OF INFORMATION

We endeavor to protect your personal information. We use technical, administrative and physical methods to maintain the integrity and security of our databases, including firewalls. Please be aware though that there is no such thing as “perfect security” on the internet, and third parties may unlawfully intercept or access transmissions or private communications. We will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personal information. You use our Site and send us information at your own risk.

06. DO NOT TRACK

We do not track visitors of the Site over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

07. RIGHTS UNDER GDPR

In places where the EU General Data Protection Regulation (“EU GDPR”) and/or the UK General Data Protection Regulation (“UK GDPR”) (EU GDPR and UK GDPR, collectively, “GDPR”) apply, you may have certain rights in relation to personal information that constitutes “personal data” as defined in GDPR.

These rights may include: (x) the right to ask us to correct your personal information where it is inaccurate or incomplete; (y) the right to ask us to access the personal information we hold about you and be provided with certain information about how we use your personal information and who we share it with. In certain circumstances, you have the right to ask us to delete the personal information we hold about you, including: (i) where you believe that it is no longer necessary for us to hold your personal information; (ii) where we are processing your personal information on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing; or (iii) where you believe the personal information we hold about you is being unlawfully processed by us.

In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal information: (a) where you believe the personal information we hold about you is inaccurate and while we verify accuracy; (b) where we want to erase your personal information as the processing is unlawful but you want us to continue to store it; (c) where we no longer need your personal information for the purposes of our processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or (d) where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection. In addition, you can object to our processing of your personal information based on our legitimate interests and we will no longer process your personal information unless we can demonstrate an overriding legitimate ground.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

To exercise any of these rights above, please email us at Privacy@Bruincptl.com.

Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or the interests of Bruin and its related parties (including their proprietary information, trade secrets or intellectual property), or where there are overriding public interest reasons or where we are required by law or bona fide internal policies and procedures to retain your personal information.

In the event that you wish to make a complaint about how we process personal information about you, please contact us at privacy@Bruincptl.com and we will work to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with the data protection supervisory authority in the applicable country in which you live or work or where you think we have infringed data protection laws.

08. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Our servers are located in the United States. If you are accessing the Site from outside the United States, please be aware that your information may be transferred to, stored and processed by us in our facilities and by those third parties with whom we may share your personal information as outlined in this Privacy Policy, in the United States, and in other countries.

Depending on what country you are a resident of, these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will, however, take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law and we transfer your data in compliance with all applicable law.

09. INFORMATION AND DELETION REQUESTS

Based on the applicable laws of your country or state, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. If you are a resident of the State of California, you have the right to request that we disclose to you or delete certain information about our collection and use of your personal information. Once we receive your request and verify your identity, we will disclose such information to you or delete the same, unless a legal exception applies. For example, we may deny your deletion request if retaining the information is necessary for us or our providers to complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

To exercise the rights described above, please submit a request to us by either:

Calling us toll-free at [•].

Emailing us at privacy@Bruincptl.com.

Your request must:

Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person.

Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with nonpublic personal information if we cannot verify your identity or authority to make the request and confirm that the requested personal information relates to you. We will use the information provided in a request solely to verify your identity or authority to make the request.

We will not discriminate against you if you exercise your privacy rights.

We do not “sell” personal information that we collect from you, as “sell” is defined in the California Consumer Privacy Act.

10. CALIFORNIA’S SHINE THE LIGHT LAW

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our Site users who are California residents to request and obtain from us a list of their personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not share any personal information with third parties for their direct marketing purposes.

11. GOVERNING LAW

The laws of the State of New York govern this Privacy Policy and your use of this Site in all respects. Any dispute relating to this Privacy Policy and your use of this Site shall be resolved solely in the state or federal courts located in New York, New York. You consent and submit to the personal jurisdiction of such courts for the purposes of any such dispute, controversy or claim and agree to waive trial by jury in any such dispute.

12. CONTACT

If you have questions or comments about this Privacy Policy, you may email us at privacy@Bruincptl.com or write to us at Bruin Capital; 7 Renaissance Sq.; 2nd Floor; White Plains, N.Y., 10601.

© 2021 Bruin Capital Holdings, LLC. All Rights Reserved.