This Privacy Policy sets forth how Brick Street Capital LLC, its corporate affiliates, (referred to herein collectively as “Brick Street” or “we”) collect and process personal information about you. We are providing this Privacy Policy to you to satisfy disclosure requirements required under data protection and privacy regulations adopted by regulatory authorities in the jurisdictions in which Brick Street conducts business. These regulations require that Brick Street (as a data controller) ensure that you understand how we collect, use, process and share your personal information. Please note that certain of these disclosures may not apply to you.
This Privacy Policy applies to visitors to this website (the “Site”), including job applicants, as well as visitors to our offices, individuals who call Brick Street personnel in certain of our offices, third-party service providers, vendors and suppliers, business contacts and prospective clients and investors. If you provide personal information to us about any person other than yourself, you must ensure that the other person understands how their information will be used. You may only provide us with that person’s details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.
If you visit this website, you should review this Privacy Policy carefully and in conjunction with the Terms and Conditions of the Site, which detail other important information surrounding your use of the Site.
Website Visitors
Depending on how you choose to use the Site, we may need you to provide the following information:
- to contact us – name, address, e-mail address, telephone number and other contact details along with any other information you choose to provide;
- to login to our client/investor portal – username and password (if applicable); and
- to subscribe to certain communications – email address and country of residence (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication).
Use of Personal Information
Your personal information will be processed: (i) in order to comply with our legal and regulatory obligations; (ii) because we need the information for reasons of substantial public interests; (iii) in order to comply with our obligations under contract; and/or (iv) because we have a legitimate business interest in processing it, including for the following purposes (as applicable):
- to respond to your questions and handle and resolve complaints;
- to perform research with respect to the usage of the Site (applicable to website visitors);
- to personalize and enhance your website experience (applicable to website visitors);
- in order to comply with our obligations in connection with record-keeping requirements and applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of jurisdictions in which Brick Street conducts business (applicable to office callers, third-party service providers, vendors and suppliers);
- to maintain and provide appropriate management of our relationship with you;
- to exchange mail correspondence or documentation which may involve providing your contact details to couriers and service providers in charge of the delivery service;
- to engage your services in the future (applicable to third-party service providers, vendors, suppliers and business contacts);
- to contact you to set up meetings and/or phone calls between you and your Brick Street business contact(s); and
- to process your subscription requests and to send marketing communications about Brick Street to you (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication) (applicable to website visitors, business contacts and prospective clients and investors).
Retention of Personal Information
We will retain your personal information only for as long as we consider necessary in connection with the purposes set out in this Privacy Policy, unless applicable law or regulations require or permit a longer retention period, as described further in our document retention policies. In addition, we may retain your personal information for the duration of any period necessary to establish, exercise, or defend any legal rights.
Use of Technology and Cookies
When you visit our Site or open our emails, we may collect certain information by automated means (such as by cookies, web server logs, web beacons and JavaScript). The information we may collect in this manner includes your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our Sites, and dates and times of website visits. We also may use these and similar technology in emails we send you to collect certain information, such as whether you opened or clicked on links in our email.
We may use third-party web analytics services on our Site. These service providers help us analyze how visitors use the Site. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers. The providers of third-party plugins and widgets on our Site, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Site and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.
The Company may collect certain information about you through the use of cookies. Cookies are pieces of information, or files, placed on your device’s disk that provide information including how and when pages on the Site are accessed by users.
When visiting the Site, you may receive a pop-up banner informing you of our use of cookies.
You may also be asked to agree to allow us to use particular analytics cookies while you browse the Site. If you receive our cookie consent banner, you may click “Cookie Consent Tool” to see which cookies we have on our Site and choose whether to accept or opt-out of certain cookies while on the Site. Should you choose not to give your consent for us to use some or all of the analytics cookies on our Site, these cookies will not be placed on your browser while you browse the Site.
You may configure your browser to set preferences regarding cookies such that you can have your computer warn you each time a cookie is sent. Note that you may decline placement of cookies if your internet browser permits, though this may impact your experience of using the Site, and certain portions of the Site may be inaccessible to you if you choose to do so. You may at any time delete any cookies from your hard drive. Aggregated data gathered from cookies is used by the Company to help maintain and improve the information provided on this Site for users. The Company may also employ other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which 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 information on our behalf. We take seriously the protection of your personal information and have contracts in place with these authorized third parties to protect your personal information. We may also use these technical methods in HTML e-mails that we send Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. The Company may collect the information from use of these technical methods in a form that is personally identifiable.
During some Site visits, the Company 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 mouseovers), and methods used to browse away from the page. The Company may use this information to measure Site activity, to develop ideas for improving the Site and for any other purpose to the extent permitted by applicable law.
Children’s Online Privacy Protection Rule (“COPPA”)
The Site is not intended for or targeted towards, and we do not knowingly collect personal information via the Site from, children under 13 years of age. If we learn we have collected or received personal information via the Site about a child under 13, we will delete that information.
Updates to this Privacy Policy
Brick Street reserves the right in its sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting and we will indicate in the Privacy Policy when it was most recently updated. You should review this Privacy Policy periodically for changes applicable to you. Additionally, note that by accessing this Site subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended.
Contact Us
Please direct any questions regarding Brick Street’s Privacy Policy by contacting us through our Contact Us page.
This Privacy Policy was last updated on July 7th, 2020.