Privacy Policy

“Personal Information” is information that identifies you as an individual or relates to an identifiable person, including:

• Name
• Postal address
• Telephone number
• Email address

We and our service providers may collect Personal Information in a variety of ways, including:

• Through the Services: We may collect Personal Information through the Services, e.g., when you contact us for information about our services or a career opportunity.
• From Other Sources: We may receive your Personal Information from other sources, such as public databases; joint marketing partners; social media platforms; and other third parties.

We need to collect Personal Information in order to provide the requested services to you. If you do not provide the information requested, we may not be able to provide the services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information:

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the Services and fulfilling your requests.
  • To provide the Services’ functionality to you, such as arranging access to your account.
  • To respond to your inquiries and fulfill your requests, such as to send you newsletters.
  • To send administrative information to you, for example, information regarding the services offered and changes to our terms, conditions, and policies.

We engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with marketing materials.
  • To send you marketing communications that we believe may be of interest to you.

We engage in this activity with your consent or where we have a legitimate interest.

• Providing personalized services.
  • To personalize your experience on the Services by presenting products and offers tailored to you.

We provide personalized services based on our legitimate interests or, to the extent required by applicable law, with your consent.

• Anonymizing and/or aggregating Personal Information.
  • We may anonymize and/or aggregate Personal Information so that it will no longer be considered Personal Information. We may use and disclose such anonymized and/or aggregated information for any purpose, as it no longer identifies you or any other individual.

• Accomplishing our business purposes.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Site and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation and/or based on our legitimate interest.

Your Personal Information may be disclosed:

• To our third party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, auditing and other similar services.
• To a third party in connection with any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.

• This may include laws outside your country of residence.

• To cooperate with public and government authorities.

• To respond to a request or to provide information we believe is necessary or appropriate.
• These can include authorities outside your country of residence.

• To cooperate with law enforcement.

• For example, when we respond to law enforcement requests and orders or provide information we believe is important.

• For other legal reasons.

• To enforce our terms and conditions;
• To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
• To allow us to pursue available remedies or limit the damages that we may sustain.

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:

• Browser and device information
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you
• Aggregated information

We and our third party service providers may collect Other Information in a variety of ways, including:

• Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version. We use this information to ensure that the Services function properly.

• Using cookies: Please see our Cookies and Similar Technologies Policy for details about the cookies and similar tracking technologies we use. Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while using the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions about them.If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept these cookies, you may experience some inconvenience in your use of the Services.We use Google Analytics to understand how visitors engage with our site and to improve our Services. For more information on how Google Analytics uses the information it receives from our Services, please visit http://www.google.com/policies/privacy/partners/.

  Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users, measure the success of our marketing campaigns and compile statistics about usage of the Services.

We do not currently respond to browser do-not-track signals.

• IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

We may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

Your choices regarding our use of your Personal Information

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by replying to info@ducerapartners.com with your opt-out request.

We will try to comply with your request as soon as reasonably practicable. If you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change or suppress your Personal Information

If you would like to request to update, correct, suppress or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us at: info@ducerapartners.com. We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. In addition, we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. We will try to comply with your request as soon as reasonably practicable.

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services.

Ducera Partners LLC, located at 499 Park Avenue, 16^th Floor, New York, NY 10022, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at info@ducerapartners.com, or:

Ducera Partner

499 Park Avenue
16th Floor
New York, NY 10022

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

You may lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at here.