PRIVACY NOTICE

 

Last updated May 10, 2024

 

This privacy notice for IGP Industries, LLC (doing business as Industrial Growth Partners) (“Industrial Growth Partners,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:

  • Visit our website at https://igpequity.com, or any website of ours that links to this privacy notice
  • Engage with us in other related ways ― including any sales, marketing, or events

This privacy notice is intended for users of our Services and does not apply to employees or job applicants or information collected in the business context. This Privacy Policy does not apply to information that we process on behalf of our business customers while providing the services to them. Our use of this information is restricted by our agreements with those business customers. If you have concerns regarding personal information that we process on behalf of a business, please direct your concerns to that business.

 

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at accounting@igpequity.com.

 

SUMMARY OF KEY POINTS

 

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Industrial Growth Partners and the Services, the choices you make, and the products and features you use.

 

Do we process any sensitive personal information? We do not process sensitive personal information.

 

Do you receive any information from third parties? We do not receive any information from third parties.

 

How do you process my information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

 

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

 

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

 

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

 

How do I exercise my rights? The easiest way to exercise your rights is by filling out our data subject request form available here: https://igpequity.com/contact/, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

 

TABLE OF CONTENTS

 

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. HOW DO WE KEEP YOUR INFORMATION SAFE?

5. DO WE COLLECT INFORMATION FROM MINORS?

6. WHAT ARE YOUR PRIVACY RIGHTS?

7. CONTROLS FOR DO-NOT-TRACK FEATURES

8. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

9. DO WE MAKE UPDATES TO THIS NOTICE?

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

1. WHAT INFORMATION DO WE COLLECT?

 

Personal information you disclose to us

 

In Short: We collect personal information that you provide to us.

 

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

 

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names
  • email addresses

Information automatically collected

 

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

 

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, general location (e.g., city), information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

 

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

 

2. HOW DO WE PROCESS YOUR INFORMATION?

 

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below).
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

Service delivery.  We may use your personal information to:

  • provide, operate and improve the Service and our business;
  • establish and maintain your user profile on the Service;
  • communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
  • understand your needs and interests, and personalize your experience with the Service and our communications; and
  • provide support for the Service, and respond to your requests, questions and feedback.

Compliance and protection.  We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the Service; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. 

With your consent.  In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

In Short: We may share information in specific situations described in this section and/or with the following third parties.

 

We may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Professional Advisors. We may share your information with our professional advisors, in which case we will require those affiliates to honor this privacy notice.
  • Authorities. We may share or transfer your information to regulatory authorities in order to respond to law enforcement requests and as required by applicable law, court order or government regulations.

 

4. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

 

We have implemented technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Please note transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

 

5. DO WE COLLECT INFORMATION FROM MINORS?

 

In Short: We do not knowingly collect data from or market to children under 18 years of age.

 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at accounting@igpequity.com.

 

6. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short:  You may review, change, or terminate your account at any time.

 

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

 

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists — however, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

 

If you have questions or comments about your privacy rights, you may email us at accounting@igpequity.com.

 

7. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

8. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

 

In Short: Yes, if you are a resident of California and have provided information to us as a consumer (as opposed to as an employee/job applicant or in the business context), you may have specific rights regarding access to your personal information.

 

California Privacy Notice

 

This section applies only to California residents.  It describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and starting on January 1, 2023, the California Privacy Rights Act (“CPRA”) and their rights with respect to that Personal Information.  For purposes of this section, the term “Personal Information” has the meaning given in the CCPA and CPRA but does not include information exempted from the scope of the CCPA or CPRA.  In some cases, we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section. As indicated above, this privacy notice does not apply to job applicants or employees or information collected in the business context.

The California Code of Regulations defines a “resident” as:

 

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

 

All other individuals are defined as “non-residents.”

 

If this definition of “resident” applies to you, you may have certain rights and regarding your personal information.

 

California residents have the right to opt out of the sale of personal information, the sharing of personal information, or certain processing of sensitive personal information. IGP Industries, LLC has not sold or “shared” (as defined by the CPRA) any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. IGP Industries, LLC does not collect sensitive personal information.

 

Sensitive Information. We do not process sensitive information.

 

What categories of personal information do we collect?

 

We have collected the following categories of personal information in the past twelve (12) months:

 

Category Examples

Source

Business/Commercial Purpose for Collection

Categories of third parties to whom we “disclose” Personal Information for a business purpose
A. Identifiers Contact details, such as real name, Internet Protocol address, and email address

You

Automatic Collection

To provide you with support and respond to your inquiries

Business Transfers, Professional Advisors, Authorities
B. Personal information categories listed in the California Customer Records statute Name and email address

You

To provide you with support and respond to your inquiries

Business Transfers, Professional Advisors, Authorities
C. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

You

Automatic Collection

Automatically captured by our website and to monitor the effectiveness of outreach efforts

Business Transfers, Professional Advisors, Authorities

 

 

Your rights with respect to your personal data

 

Right to request information, access, rectification, or deletion of the data

 

You may submit requests to exercise your right to information, access, rectification or deletion at https://igpequity.com/contact, calling us toll free at 1-866-882-7638, or via email to accounting@igpequity.com. 

 

If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions and exclusions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

 

Right to be informed — Request to know

 

Depending on the circumstances, you have a right to know the following information from the preceding 12 months:

 

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • whether or not we collect, use, share, or sell sensitive personal information;
  • the purposes for which the collected personal information is used;
  • whether we share or sell your personal information with or to third parties;
  • the categories of personal information that we sold or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

 

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

 

Verification process

 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

 

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

 

You can designate an authorized agent to make a request under the CCPA or CPRA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA or CPRA.

 

Retention

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 2 years.

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

9. DO WE MAKE UPDATES TO THIS NOTICE?

 

In Short: Yes, we will update this notice if our practices change or as necessary to stay compliant with relevant laws.

 

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions or comments about this notice, you may email us at accounting@igpequity.com or by post to:

 

IGP Industries, LLC

101 Mission St

Suite 1800

San Francisco, CA 94105

United States

 

11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

Based on the applicable laws of your country, 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. To request to review, update, or delete your personal information, please visit: https://igpequity.com/contact/.