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Website Privacy Policy

Effective Date: October 1, 2020

Crewcial Partners LLC (“we”, “us”, “our” or “Company”) created this Privacy Policy (“Privacy Policy”) in order to ensure the confidence of visitors and clients (“you” or “your”) of and to our website, www.crewcialpartners.com and any successor website subdomain subsite which links to or references this Privacy Policy (the “Website”) which are owned and operated by us. This Privacy Policy applies to your use of the Website and our services. Except where specified herein, if at all, this Privacy Policy does not apply to information you may provide to us offline.


We strongly believe in the privacy of Personal Information we collect from individuals who use of our Website. We want you to understand how and why we collect, use and disclose Personal Information about you through our Website. This Privacy Policy provides you with information concerning our practices and procedures as they relate specifically to information we collect through our Website. We provide this Privacy Policy in connection with, and as incorporated in its entirety in, our Terms of Use located at www.crewcialpartners.com/touw (the “Terms of Use”).By using the Website you consent to the terms and conditions of this Privacy Policy. Because the Web is an evolving medium, we may need to change our Privacy Policy at some point in the future, in which case we will post the revised Privacy Policy on this website and update the “Last Updated” date above to reflect the date of the changes. If you are using the Website as a part of an organization or business entity, you represent and warrant that you have appropriate authority to bind such organization or entity to these terms and conditions of this Privacy Policy, and any reference to “you” herein will include such organization or entity. Capitalized terms not defined herein shall have the meanings set forth in our Terms of Use.


1. Types of Information Collected. We collect certain information from and about users of our Website, including information about your internet connection, the equipment you use to access our Website, IP addresses, and usage details, and similar information collected through tracking technologies (“Traffic Data”) as further described in our Cookie policy set forth below. In addition, for individuals that actively seek to contact us from our Website, we collect a name and email address by which you may be personally identified and contacted online as well as information you may provide about the subject of your inquiry to and your message (collectively “Contact Data”)We also collect Personal Information and other information you provide to us, which may include: information that you provide by filling in forms on our Website, including information provided at the time of registering to use our Client Portal, records and copies of your correspondence (including email addresses), if you contact us; and information when you report a problem with our Website.


2. Uses of Information Collected. We use Contact Data to send you information about our company or our products or services, or to contact you when necessary. We will direct electronic communications to your email address. We use your Traffic Data to customize and tailor your experience on the Website and to assist us in product development. We may share your Personal Information with our affiliates. We may also share your Personal Information with third parties as required for them to provide services to us, such as hosting services.3. Sharing of Personal Information. We share Traffic Data with our third party service providers only on an aggregate basis. We do not share Contact Data with other companies, other than companies that are providing us services related to the purpose for which you provided the information.5. Confidentiality and Security of Personal Information Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce any Terms of Use associated with this Website. We take security measures that we consider reasonable and appropriate to protect against loss, misuse and alteration of the information under our control, but given the nature of the Internet, we cannot guaranty the security of the information. Your Personal Information is stored on secure servers that are not legitimately accessible by third parties, except for our third-party agents providing the services associated with this Website.6. Other Limits to Your Privacy We have no control over other web sites use of your Personal Information and you should exercise caution when deciding to disclose your Personal Information.7. Children’s Privacy We do not knowingly collect or use any personally identifiable information from online visitors under 13 years of age.8. Legal Compliance, Business Transition and Other Disclosures. Notwithstanding anything to the contrary stated herein or within our Terms of Use, we may occasionally release information about users of our Website when we deem such release appropriate to comply with law, respond to compulsory process or law enforcement requests, enforce our Terms of Use, or protect the rights, property or safety of users of our Website and services, the public, Crewcial Partners, our affiliates, or any third party. Further, in the event our company goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. You will be notified via email of any such change in ownership or control of your personal information.9. Your California Privacy Rights(As provided by California Civil Code Section 1798.83)Residents of the State of California, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law (if any) during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing at:


Crewcial Partners LLC

Attention: General Counsel

810 7th Ave

New York, NY 10019


10. Consent to Transfer Information to the United States. The Website is operated in the United States and intended for users located in the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. For the purposes set out in this Privacy Policy, personally-identifying information may be transferred to, processed, stored and accessed by us, our affiliates and our unaffiliated service providers in the United States and in other jurisdictions where we or they operate. Courts and other authorities in these jurisdictions may, in certain circumstances, be entitled to access your personally identifying information. By using the Website or providing us with any information online, you consent to this transfer, processing, storage and access of your personally-identifying information in and/or outside of the jurisdiction in which you reside.11. Updates and Changes to Privacy Policy. We reserve the right, at any time and without notice, to add to, change, update or modify this Privacy Policy, simply by posting such change, update or modification on the Website. Any such change, update or modification will be effective immediately upon posting on the Website. Therefore, it is important that you periodically review this Privacy Policy.12. Further Information. If you have comments or questions about our Privacy Policy, you may contact us as follows:


Crewcial Partners LLC

Attention: General Counsel

810 7th Ave

New York, NY 10019



Crewcial Partners COOKIE POLICY


Last modified: July 2017

This Cookie Policy applies when you visit, access, or use websites (“Sites”) of Crewcial Partners. Cookies are small text files or pieces of information that a website places on your device when you visit a website. Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use cookies to bring together information we collect about you. You can choose to have your device warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. If you turn cookies off, you won’t have access to many features that make your experience on Crewcial Partners’ websites more efficient and some of our services will not function properly, including without limitation Crewcial Partners’ Client Web Portal. Please see the last section of this Cookies Policy for more information about how to manage or disable browser cookies. There are several categories of cookies that may be used, and each performs different functions. General information about cookies and how they work is made available at various websites, including allaboutcookies.org. Crewcial Partners LLC is a company with its offices at 810 Seventh Avenue 32nd Floor, New York, NY 10019 (collectively “we”, “us” or the “Company”). We use cookies and other tracking technologies to deliver and improve the Sites, and to display relevant content, products and services on those Sites. This Cookie Policy explains these technologies and where applicable, how you can choose to control them.

By using the Sites, you expressly consent that we can use these technologies as described in this Cookie Policy. We hope that this Cookie Policy helps you understand, and feel more confident about, our use of cookies and other tracking technologies. If you have any further questions regarding this Cookie Policy or requests, please contact us at http://dev.crewcialpartners.us/investment-consulting-contacts.

We may change this Cookie Policy at any time. Please check back frequently to review any updates to this Cookie Policy. Please take a look at the last modified date at the top of this page to see when this Cookie Policy was last revised. Any changes in this Cookie Policy will become effective when we make the revised Cookie Policy available on or through the Sites.1. WHAT IS A COOKIE?

Cookies are small text files that are stored on your computer or on your mobile device. They are widely used in order to make websites or mobile applications work in a better, more efficient way. For example, they can recognize you and remember important information that will make your use of a website or mobile application more convenient (e.g., by remembering your user preferences).2. WHAT COOKIES MAY WE USE?

Below we list the different types of cookies we may use on the Sites. We may also use cookies and similar tools to correlate your use of the Sites to personal information obtained about you. For example, if you have asked us to provide you information about our services, your Client Portal account, or content we have provided to you through the Client Portal, we may utilize our cookie and/or clickstream data about your activities when you engage with us on the Sites . By evaluating this information, we may more clearly target the information we provide you to the specific items we think you will find interesting, based on your prior online activities and preferences. Strictly Necessary Cookies.

These cookies are essential to the Sites in order to facilitate our log-in process and enable you to navigate the website and to use its features. Without these cookies, we may not be able to provide certain services or features, and the websites, including without limitation the Client Portal, will not perform as smoothly for you as we would like.

Functionality Cookies.

In some circumstances, we may use functionality cookies. Functionality cookies allow us to remember the choices you make while browsing on the Sites, and to provide enhanced and more personalized content and features, such as customizing a certain webpage, remembering if we have asked you to participate in a service you request, like commenting in a forum, obtaining documents or content, and the like. In order to permit your connection to the Sites, our servers receive and record information about your computer and browser, potentially including your IP address, browser type, and other software or hardware information. All of these features help us to improve your visit and assist in navigation of the website’s features.

Analytics Cookies.

We and our service providers may use analytics cookies, which are sometimes called performance cookies, to collect information about your use of the Sites and enable us to improve the way it works. Analytics cookies collect information about how you use the Sites, for instance, which pages you go to most. The information allows us to see the overall patterns of usage, help us record any difficulties may have while using the website and show us whether our advertising is effective or not.3. HOW DO THIRD PARTIES USE COOKIES ON THE WEBSITES?

In some circumstances, we may work with third parties to provide services on our Sites. For example, we use analytics services supported by third party companies who generate analytics cookies on our behalf. We may not have access to these cookies, although we may use statistical information arising from the cookies provided by these third parties to customize content and for the other purposes described above. These companies may also transfer this information to other parties where required to do so by law, or where such other parties process the information on their behalf.

We may not control these third-party cookies and their use may be governed by the privacy policies of the third parties employing these cookies. To learn about these cookies and to disable or reject third-party cookies, please refer to the relevant third party’s website.

You can also learn more about controlling cookies in section 4 below.4. HOW CAN YOU CONTROL COOKIES ON OUR WEBSITES?

You may refuse to accept cookies at any time by activating the setting on your browser which allows you to refuse cookies. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider’s website via your help screen. You may wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers. Please note that by disabling or blocking any or all cookies, some features of the website may not operate as intended, or you may not have access to features or personalization available through the website.


In compliance with California AB 370, Section 22575, we have a responsibility to inform you that the Sites do not take any specific automated action in response to browser Do Not Track signals or other similar mechanisms (collectively, “DNT signals”). As specified in Sections 2 and 4 above, there are actions which you can take to restrict or eliminate the use of tracking technologies within the Sites; however, no actions are taken automatically in response to DNT signals.


Crewcial Partners currently does not provide a mobile application. However, in general, where you are accessing the Sites through your mobile device, certain information may still be collected automatically by cookies, such as the type of mobile device you are using and unique identifier (such as the device ID, IP address, MAC address, IMEI number, app ID (a unique identifier relating to the particular copy of the app you are running) and information about your use of our Sites.

What to do if you do not want your device information stored or accessed?

Manufacturer/device/web browser settings: Depending on the information being stored or accessed on your device, you may wish to restrict or block the information. You may be able to block access to your device through your device’s operating system settings or manufacturer settings. For instance, if your device has the ability to provide location data, you can opt-out of location services in the “settings” of your mobile device. If you have any concerns about the information which might be accessed from or stored to your device by us, you may wish to only access our content through a web browser and to alter your settings as discussed in this Cookie Policy in Section 4.