Privacy Policy
Effective December 1, 2024
This Privacy Policy describes how Carbon Direct Capital (Carbon Direct Capital Management, LLC, and our affiliated entities referred to collectively as “CD Capital”, “we”, “us”, or “our”) may collect, use and. share your personal information when you visit www.carbondirectcapital.com or services that link to this Privacy Policy (collectively, the “Services”) or take other actions through the Services such as choosing to contact us, receive our communications or attend our events.
We provide important information for individuals in Europe (see below).
Personal Information We Collect
Information you provide to us. Personal information you provide to us through the Services may include:
Contact information, If you request communications from us, we have a form that allows you to provide details, such as your first and last name, email address, and postal or zip code.
Correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us.
Marketing information, such as your preferences for receiving communications about our products, activities, and publications, and details about how you engage with our communications.
Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.
Information we obtain from social media platforms. We may maintain pages within a social media platform, such as LinkedIn. When you visit or interact with our page(s) on the platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platform may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
You may also have the opportunity to provide us with additional information via the third-party platform or network, such a list of your connections. You can read more about your privacy choices for social media networks and other third-party platforms in the “Other Sites, Mobile Applications, and Services” section below.
Cookies and Other Information Collected by Automated Means
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model; device identifier; browser type; screen resolution; IP address; the website you visited before browsing to our website; general location information such as city, state or geographic area; and information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
How We May Use Your Personal Information
We may use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:
We may use your personal information to:
provide, operate, and improve the Services;
facilitate social features of the Services, such as our blog
communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages;
understand your interests and personalize your experience with the Services;
provide support and maintenance for the Services; and
respond to your requests, questions and feedback.
To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities. For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
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.
To create anonymous data. We may create aggregated and other anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
How We Share Your Personal Information
We do not share your personal information with third parties without your consent, except in the following circumstances or as otherwise described in this Privacy Policy:
Affiliates. We may share your personal information with our affiliated organizations for purposes consistent with this Privacy Policy.
Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the Services (such as customer support, website troubleshooting, hosting, analytics, email delivery, marketing, and database management services).
Examples of some our current service providers (with links to their privacy policies and/or legal terms) as of the date of posting this privacy policy are:
Juniper Square Inc. https://www.junipersquare.com/privacy-policy
Microsoft https://privacy.microsoft.com/en-us/privacystatement
Pantheon (website hosting provider) https://www.pantheon.com/privacy-policy/
Blueshift Technologies LLC (web developer) https://www.getblueshift.tech/privacy-policy/
LinkedIn (ad tracking) https://www.linkedin.com/legal/privacy-policy
Triada Networks. (external IT/security partner) https://www.triadanet.com/privacy-policy
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Government Requests. Notwithstanding anything to the contrary in this policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, or legal request or to protect the safety, property, or rights of CD Capital or others. However, nothing in this policy is intended to limit any legal defenses or objections that you may have to a third party or government request to disclose your information.
Corporate transfers. We may transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a (potential) organizational transaction such as a merger, consolidation, reorganization, or in the event of dissolution.
Your Choices
Opt out of marketing communications. You may opt out of marketing emails by following the unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails. Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services or certain features. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means. In some cases, you may provide a pseudonym, such as when you sign up for our email list.
Other Sites, Mobile Applications, and Services
The Services may contain links to, or content or features from, other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third- party websites, mobile applications, or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
Security Practices
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
Some of our current security practices as of the date of this privacy policy include: data is stored within a secured facility that limits physical access; data at rest is stored in an encrypted state; all administrative accounts are protected by multi- factor authentication and, in most cases, access is also limited by IP address; all administrative actions are audited; an automated security review is undertaken on a regularly scheduled basis; a specific and targeted security review is conducted bi- annually or more often as dictated by the needs and changes introduced in the services offered.
International Data Transfers
We are headquartered in the United States and most of our Service Providers are located here as well. Thus, your personal information may be transferred outside of your state, province, or country to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Children
The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 16. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it.
Changes to this Privacy Policy
We may amend this Privacy Policy at any time by posting the amended version on the Services and indicating the effective date of the amended version. We may announce any material changes to this Privacy Policy through the Service and/or via email if we have your email address. In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acknowledgement to the amended Privacy Policy.
How to Contact Us
If you have any questions or comments about this Policy or CD Capital’s privacy practices, email us at inquiries@carbondirectcapital.com.
Your California Privacy Rights
If the California Consumer Privacy Act (CCPA) is applicable to us and to you, you have the right to:
know the categories of personal information collected about you in the prior 12 months and its sources and business purpose;
know whether your personal information is sold or disclosed, and to whom, in prior 12 months;
access and then delete your personal information (subject to exceptions); and
equal service and price (non-discrimination) if you exercise your privacy rights.
Please submit any requests to inquiries@carbondirectcapital.com. You will need to verify your identity by confirming the details that you originally provided to us to receive communications. If you did not request communications, you will need to verify the personal information that is related to your request.
For purposes of CCPA, “Personal Information” is defined to include information that identifies, relates to, describes, or is capable of being associated with a particular consumer or household. This includes (among other types of personal information) IP addresses, geolocation data, biometric information, and “unique identifiers” such as device and cookie IDs, Internet activity information like browsing history, commercial information such as products or services purchased or consuming histories or tendencies, and characteristics concerning an individual’s race, color, sex (including pregnancy, childbirth, and related medical conditions), age (40 or older), religion, genetic information, sexual orientation, political affiliation, national origin, disability or citizenship status. Inferences drawn from personal information “to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes” are also considered “personal information.”
Notice to European Users
The information provided in this section applies only to individuals in the European Economic Area and United Kingdom (collectively, “Europe”).
Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller and Representative. CD Capital is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.
The contact information for our representative in Europe is: inquiries@carbondirectcapital.com.
Legal bases for processing. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law).
Processing Purpose(s) and Related Legal Basis:
To operate the Services: Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Services you access and request.
For research and development; for compliance, fraud prevention, and safety; To create anonymous data: These activities constitute our legitimate interests.
To comply with law: Processing is necessary to comply with our legal obligations.
With your consent: Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.
Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security number, government-issued identification, payment card information, 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.
Retention. We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; or for fraud prevention). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it 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.
“Live” user data (username, email and contact preferences, sign-in information is stored without any active plans on purging old or inactive data.
User generated content (comments, documents, or other files) is retained indefinitely unless a request or order is received to remove it.
Backup data (which may contain the above user-specific information) may be retained for up to 1 year.
A user may request, in accordance with standards such as GDPR, to have their data removed from our live system, and it will eventually expire out of the backups once the retention period has ended.
Your rights
European data protection laws give you certain rights regarding your personal information. If you are located within Europe, you may ask us to take the following actions in relation to your personal information that we hold:
Access. Provide you with information about how we process your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
Please contact us at inquiries@carbondirectcapital.com to submit these requests. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us at inquiries@carbondirectcapital.com or submit a complaint to the data protection regulator in your jurisdiction.
Cross-Border Data Transfer
If we transfer your personal information from the European Economic Area to a country outside of it and are required to apply additional safeguards to your personal information under European data protection legislation, we will do so. Please contact us at inquiries@carbondirectcapital.com for further information about any such transfers or the specific safeguards applied.