Privacy Policy - APEIRA CAPITAL

Last Updated: February 1, 2021

Apeira Capital Advisors LLC (“Apeira Capital,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through our website currently located at http://www.apeiracapital.com/ (together with any materials and services available therein, and successor site(s) thereto, the “Site”).

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Site may collect Personal Information, including:

Name and contact information (such as address, telephone number, or email address); and

IP address (we may also derive your approximate location from your IP address).

Use Of Personal Information

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

To provide the functionality of the Site to you;

To respond to your inquiries when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our services;

To send administrative information to you, such as changes to our terms, conditions, and policies;

To send you marketing related emails, with information about our services and other news about Apeira Capital;

To analyze Personal Information for business reporting, including:

- analyzing or predicting our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Site;
- personalizing our interactions with you and providing you with information tailored to your interests; and
- delivering content via our Site that we believe will be relevant and interesting to you;

To aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information for the purpose of generating other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual; and

To accomplish other business purposes, including:
- For data analysis, for example, to improve the efficiency of our Site;
- For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

- For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;

- For identifying usage trends, for example, understanding which parts of our Site are of most interest to users;

- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and

- For operating and expanding our business activities, for example, understanding which parts of our Site are of most interest to our users so we can focus our energies on meeting our users’ interests.

Disclosure Of Personal Information. We disclose Personal Information: to the following:

To our affiliates for the purposes described in this Privacy Policy; and

To our third party service providers, including but not limited to website hosting, data analysis, information technology and related infrastructure provision, email delivery and auditing, to facilitate services they provide to us.

Other Uses and Disclosures. We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others. We may use, disclose or transfer your information to a third party in the event of 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 Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Site collects Other Information such as:

Browser and device information;

Website usage data;

Information collected through cookies, pixel tags and other technologies;

Demographic information and other information provided by you that does not reveal your specific identity; and

Information that has been aggregated in a manner such that it no longer reveals your specific identity.

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

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 you are using. We use this information to ensure that the Site functions properly.

Cookies.
- 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 Site, 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. We also gather statistical information about use of the Site in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do- not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Site.

Pixel tags and other similar technologies.
- Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Site (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Site and response rates.
- Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/ , and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Uses and Disclosures of Other Information. 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, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, 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.

Security. 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 in accordance with the “Contacting Us” section below.

Choices. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by using the unsubscribe link contained in each of our marketing-related emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that 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.

Updating your Personal Information. If you would like to update Personal Information that you have provided to us, you may contact us in accordance with the “Contacting Us” section below.

Third Party Services. 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 website or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us or by our affiliates.

Use of Site by Minors. 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 Site 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.

Jurisdiction and Cross-Border Transfer. 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 Site 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.

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

Contacting Us. If you have any questions about this Privacy Policy, please contact us at info@apeiracapital.com or by writing to 60 Broad Street, Floor 24, New York, NY 10004. Because email communications are not always secure, please do not include sensitive information in your emails to us.