Last Updated: March 2024

At Bookmark Partners LLC (together with its subsidiaries and affiliates, “Bookmark Partners”), your privacy is very important to us. This Privacy Policy (“Policy”) describes and governs our use and disclosure of the information we collect through the Bookmark Partners website at https://www.bookmarkpartners.com/ (the “Site”), as well as information that we collect through other means about people who contact us, vendors, and prospective investors and employees.

For users of the Site, your use of the Site signifies acceptance of the terms of this Policy. Undefined capitalized terms used herein shall have the definitions as set forth in our Terms and Conditions.

1. Information We Collect
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a. User-Provided Information
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‍At present, users cannot directly submit information via the Site. However, direct information may be necessary to access specific services, provide services to us, or request information. This includes details such as name, contact info, resume data, payment details, or other personal information. Unless screening is required by OFAC laws or similar regulations, no statutory or contractual obligation compels the provision of personal data. Failure to provide information may restrict access to certain services or information.
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‍b. Information From Third Parties
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‍We collect data from third parties, such as CVs from recruiting firms, fit-for-work details from physicians, background information from check providers, data from social media, and information from publicly available lists. Data from business partners and vendors supports our investment services. Information gathered is often aggregate and not individually identifiable, though personal data may be included. The extent of information obtained is governed by third-party sources.
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‍c. Passive or Automatic Collection of Information
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i. Device/Usage Information
Automatic collection of data about the devices used to access the Site includes IP addresses, location information, device identifiers, browser types, and interaction details with the Site. This information assists in analyzing site usage and improving user experience.
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ii. Cookies and Electronic Technologies
‍Data on Site use is collected through server logs, cookies, and tracking pixels. Cookies recognize computers, store preferences, understand visited web pages, enhance user experience, and perform searches and analytics. Tracking pixels and web beacons assess message interactions. Users can manage cookie settings through their browsers.
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‍d. Online Analytics

‍Third-party web analytics services, like Google Analytics, are used for auditing, research, and reporting. Information, including IP addresses, is disclosed to these service providers for evaluating Site use, analyzing trends, fraud prevention, and providing features.
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‍e. Do-Not-Track Signals

‍The Site currently does not recognize or respond to browser-initiated Do Not Track (DNT) signals. Third-party responses to DNT signals are beyond our control and are governed by their privacy policies.

‍2. How We Use Your Information
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We may utilize the collected information for the following purposes:
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- For the specific reasons you provided it to us or a vendor.
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- To deliver the features and services offered through the Site.
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- For enhancing and providing our investment services, encompassing the evaluation of potential investments and management of existing ones.
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- To address your requests or send you relevant communications.
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- Conducting surveys and analyzing market trends and interests.
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- Processing and responding to inquiries or soliciting feedback.
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- Internal research and reporting.
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- Enhancing the content and features of the Site.Recruiting purposes.
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- Enforcing the legal terms governing your use of the Site.
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- Administering and troubleshooting the Site.

Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates, vendors, and/or other non-affiliated third parties, and use such combined information in accordance with this Policy.

We may aggregate and/or de-identify information we collect. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties.

‍3. When We Disclose Your Information
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We might reveal and/or share your information with non-affiliated third parties in the following situations:

Consent: We may disclose your information to third parties based on your explicit consent.

Service Providers: Your information may be provided to select third parties that perform services on our behalf. These services include, but are not limited to, communications, market research, customer support, data storage, analysis and processing, and legal services.

Protection of Bookmark Partners and Others: You acknowledge and agree that Bookmark Partners may access, preserve, and disclose your information if required by law or in good faith belief that such access, preservation, or disclosure is permitted by the privacy policy or reasonably necessary for reasons such as legal compliance, enforcement of policies, response to claims of content violations, customer service requests, and protection of rights, property, or safety.

Business Transfers: In the course of developing our business, we may engage in activities such as buying, merging, or partnering with other companies. In such instances, user information, including yours, may be among the disclosed or transferred assets. If any of Bookmark Partners' assets are sold or transferred to a third party, your information could be part of the transferred business assets.

4. Legal Basis for Processing Personal Data
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In accordance with the legal requirements in specific jurisdictions, companies are obligated to inform individuals about the legal basis they rely on for utilizing or disclosing personal data. In compliance with applicable laws, the grounds for processing your personal data are outlined as follows:
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Legitimate Interests: In numerous instances, we process personal data based on the legitimate interests of engaging in commercial activities. This includes, but is not limited to, providing investment services, managing and sustaining our Site, enhancing our business operations, communication activities, addressing information security requirements, and safeguarding the interests of our investors, Bookmark Partners, Bookmark Partners funds, and other stakeholders. This is conducted in a manner that does not supersede the interests or fundamental rights and freedoms of the individuals affected.
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Legal Compliance: Certain uses and disclosures of personal data are necessary to fulfill our legal obligations.
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Honor Our Contractual Commitments to You: A significant portion of our personal data processing is carried out to fulfill contractual obligations to our investors or to undertake actions, as requested by investors, in anticipation of entering into a contractual agreement with them.
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Consent: When we obtain personal data from a third party that has secured your consent, we may process your personal data based on the consent provided.

‍5. Your Choices, EU Data Subject Rights and California Privacy Rights
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‍You can request access to and/or revision of certain personal data by contacting us as described below. If you wish to limit the emails you receive from us, you can let us know by contacting us as described in the “Contact Information and Questions About this Policy” section.

Subject to local law, you may have certain rights with regard to your personal data. To learn more about the personal data we collect about you or the rights you may have, please contact us at the contact information below. These rights may include the following rights to (1) access or rectify your personal data or request its deletion, (2) request a restriction on the processing of your personal data, (3) object to the processing of your personal data, or (4) exercise other rights with respect to your personal data. Please contact us as described below. While we strongly encourage you to first raise any questions or concerns about your personal data directly with us, you may have a right to lodge a complaint with the relevant supervisory authority.

Many of the rights described here are subject to significant limitations and exceptions under applicable law (e.g., objections to the processing of personal data, and withdrawals of consent, typically will not have retroactive effect). Please also note that if we collected your personal data from a third party, you may also need to contact that third party in order to exercise your rights with them.

California residents can make certain requests about their personal information under the California Consumer Privacy Act (“CCPA”). Specifically, if you are a California resident, you may request that we:

- provide you with information about: the categories of personal information we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information. Such information is also set forth in this Policy;
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- provide access to and/or a copy of certain information we hold about you;
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- delete certain information we have about you; and/or
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- provide you with information about the financial incentives that we offer to you, if any.

California residents can also designate an authorized agent to make access and/or deletion requests on their behalf. We will take reasonable steps to verify your identity before responding to a request for access and/or deletion from you or your designated agent. The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law.

If you are a California resident and would like to exercise any of legal rights under the CCPA, please contact us at privacy@bookmarkpartners.com.

‍Sale of personal information.

The CCPA sets forth certain obligations for businesses that “sell” personal information. Pursuant to the definition of “sell” under the CCPA and current guidance, we do not engage in such activity and have not engaged in such activity in the past twelve months, including for minors under 16. Please note, we do share certain personal information with our service providers and certain other entities as set forth in When We Disclose Your Information.

‍6. Notice to California Residents
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‍If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the CCPA). We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities to which we share such information in the Information We Collect, How We Use Your Information, and When We Disclose Your Information sections of this Policy. We provide additional information required by the CCPA below.
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‍Categories of personal information we collect, use and disclose.
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Throughout this Policy, we discuss in detail the types of information we collect from and about users and discuss how we use and share such information. See Personal Information We Collect for more details. The following are the “categories” of personal information under the CCPA that we collect and that we may, as discussed throughout this Policy, use and disclose for our business purposes:

Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); device identifiers (such as IP address and unique device identifiers); Internet or other network or device activity (such as browsing history or app usage (such as your notes and highlights in the Services); general geolocation data from IP addresses; and other information that identifies or can be reasonably associated with you.
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‍How we use these categories of personal information.
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We use the categories of personal information we collect from and about you consistent with the various business purposes we discuss throughout this Policy. See How We Use Your Information for more details.

‍7. Data Transfer
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‍Our computer systems are currently based in the United States, and your personal data will be processed in the United States, which may not offer the same level of protection as the privacy laws of your jurisdiction.

‍8. Children’s Privacy
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‍The Site is intended for general audiences and not for children under the age of 16. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) or personal data (under the GDPR) from children under the age of 16 without valid parental consent, we will take reasonable steps to delete it as soon as practicable.

‍9. Security
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‍We have implemented administrative, technical, and physical security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

‍10. Data Retention
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‍We will hold your information for as long as necessary to fulfill the purposes set forth in this Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.

‍11. Third-Party Links and Services
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‍The Site may contain links to or “frame” third-party websites, applications, and other services, including our investor website, as described above. Please be aware that we are not responsible for the privacy practices of such other sites and services. We encourage our users to be aware when they leave our Site and to read the privacy statements of each and every site they visit that collects their information.

‍12. Changes to this Policy
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‍We will continue to evaluate this Policy, and we may make changes to the Policy accordingly. Any changes will be posted here and you should check this page periodically for updates. If we make material changes to this Policy, we will provide you with notice as required by law.
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‍13. Contact Information and Questions About this Policy
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‍If you have any questions about our Policy, please contact us at privacy@bookmarkpartners.com.