Privacy Policy

Last Updated: August 2022

Eldridge Industries, LLC (“Eldridge,” “we,” “our,” “us”) has adopted this Privacy Policy to inform you of our policies and practices with respect to information collected from visitors to our website and users of our mobile applications (together and separately, as applicable, “the Site”), as well as those who interact with us. Your use of the Site and communications with us constitutes your acceptance of this Privacy Policy.

Please review this policy carefully.  If you are a visitor who is based in the European Union (“EU”), please review the section titled “European based users and the European Union General Data Protection Regulation” (“GDPR”) below.

For Informational Purposes Only

The information provided on our Site is for informational purposes only. The information contained herein does not constitute a distribution, an offer to sell or the solicitation of an offer to buy any securities in any jurisdiction in which such distribution or offer is not authorized, is contrary to local law or regulation or that would subject Eldridge to any registration requirement within such jurisdiction. No information in our Site constitutes investment, legal, tax or other advice nor is it to be relied upon in making any investment decision.

Information that We Collect

In general, we collect Personal Information when you communicate with us or third parties acting on our behalf and when you use the Site.  When we use the term “Personal Information” we mean information that we directly associate with a specific person, or that can reasonably be used to identify a specific person such as a name, address, telephone number, email address, or Internet Protocol (“IP”) address.  The Site collects some information from you that you voluntarily provide and other information that the Site collects automatically.   

Information you provide to us

Through your interactions with us, you may provide us with the following Personal Information:

  • name
  • e-mail address
  • mailing address
  • phone number

You do not need to provide us with any Personal Information to view or use the Site. However, we may still collect information through automated means, as described below, when you interact with the Site and we may require some Personal Information in order to respond to your inquiries or requests. We may also keep a record of such correspondence.

Information we obtain by automated means

When you visit our Site, we may collect certain information about your visit that is logged by automated means (such as by cookies, web server logs, web beacons and JavaScript).  The Site may also include certain features that are operated by third parties, which may collect Personal Information in conjunction with your use of the Site.  The information we collect in this manner includes:

  • IP address;
  • network location;
  • browser characteristics;
  • device characteristics;
  • operating system;
  • referring URLs;
  • mobile network information;
  • information on actions taken on our site; or
  • dates and times of Site visits.

Cookies

A “cookie” is a small piece of data that can be sent by a web server to your computer, which then may be stored by your browser on your computer’s hard drive. Cookies might be “persistent” or “session” cookies. A persistent cookie remains on your computer while session cookies are deleted as soon as your browser is closed. Cookies uniquely identify your browser and are used to store information or settings on your device. Our web servers may log information such as:

  • device type;
  • operating system type;
  • browser type;
  • domain;
  • system settings;
  • language your system uses; or
  • country and time zone in which your device is located.

We also may collect information such as the address of the web page that referred you to our site and the IP address of the device you used to connect to our site. We may log information about your interaction with the Site, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons,” which are small files that link web pages to particular web servers and their cookies. We may also send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Site.

As discussed in more detail below, we use Google Analytics on the Site.  Please refer to “Third-party analytics, plugins and widgets” for more information on our use of Google Analytics and their collection of your information.

You can restrict or otherwise change the use of cookies on the Site through your browser. Each type of browser offers ways to restrict and delete cookies. For more information on how to manage cookies through your browser, please visit the appropriate link below:

We keep Personal Information contained in cookies and obtained through the other tracking technologies confidential. We do not set any cookies outside of the Site.

Third-party analytics, plugins and widgets

We may use third-party web analytics services on our Site, such as Google Analytics, to  help us analyze how visitors use the Site. We use this information to evaluate your and other users’ use of the Site, compile reports on Site activity, and provide other services relating to Site activity and internet usage.  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. For more information about Google Analytics’ cookie and information practices (including the types of cookies used and their expiration date), please visit https://tools.google.com/dlpage/gaoptout.

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.

Use and Disclosure of Personal Information

In general, we use information collected about you to communicate with you, administer assistance when requested, and as otherwise permitted or required by applicable laws, rules, or regulations or the Terms of Use applicable to this Site. 

How we use the information we obtain

We may use Personal Information to:

  • respond to your inquiries;
  • operate, administer and improve the visitor’s experience on the Site;
  • operate, evaluate and improve our business (including developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; and performing internal functions);
  • comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms and Conditions of Use;
  • perform data analyses (including market and consumer research, demographic analyses and anonymization and aggregation of information).

We may also use your Personal Information for purposes listed in the “Information we obtain by automated means” section above.

How we disclose the information we obtain

We may disclose your Personal Information collected from your use of the Site:

  • to our affiliates, subsidiaries, agents, consultants and contractors;
  • to service providers who assist us in running the site and our business;
  • when we believe that such disclosure is required by law;
  • to enforce this Privacy Policy and our Terms and Conditions of Use;
  • to protect the rights, property, security or safety of Site users or the public;
  • to respond to an emergency; or
  • as otherwise stated in this Privacy Policy.

Additionally, we may disclose information to certain third-parties if you have requested or authorized the disclosure of such information. We may also share aggregated or de-identified information in our sole discretion. In the event of a corporate restructuring (such as a sale, merger, or other transfer of some or all of our assets), we may share your Personal Information with a third party. We reserve the right to use or disclose any information in aggregate form, for any purpose, in our sole judgment. 

Protecting your Personal Information

Personal Information held by us will be kept confidential in accordance with applicable Eldridge policies and procedures.  We will strive to ensure that all Personal Information is kept secure and safe from any loss or unauthorized disclosure or use. 

Children’s Privacy

This Site is not directed to children under 13.  We do not knowingly attempt to solicit or receive Personal Information from children under 13.  If we discover that that the Site has received Personal Information from an individual reasonably believed to be under the age of 13, we will delete such information from its systems.  If you are the parent or legal guardian of and you believe we may have inadvertently collected Personal Information from a child under 13, please contact us to request the child’s information be deleted by contacting us at [email protected].

Your Rights

We would like to keep your Personal Information accurate and complete.  If you would like us to update your information, or to consider providing you access to, or making a correction to, your Personal Information maintained in our records, please send your request to us at [email protected].

External Links to Other Websites

Our Site may provide links to other websites. The links are provided for your reference and convenience only.  These websites may operate independently from us. Linked websites may have their own privacy notices or policies.  We are not responsible for their content, any use of the websites, or the privacy practices of such websites.

Do Not Track Signals

Do-not-track is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated do-not-track signals.

Retention

We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.

Updates to Our Online Privacy Policy

Eldridge reserves the right to make changes to the Site and the Terms and Conditions of Use or Privacy Policy at any time for any reason without any prior notice to the visitor.

Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please email us at [email protected].  

European Based Users and the European Union General Data Protection Regulation

If your personal data is subject to the GDPR, please review the following information about our processing activities with respect to your Personal Information and your rights under the GDPR.   These rights are only available if you reside in, or access the Site from, certain jurisdictions and may be limited in some circumstances by local laws and regulations. 

Lawful processing of your Personal Information

If the processing of your personal data is subject to the GDPR, whenever we use or share personal data, we have identified a legal basis under which such processing may occur. 

Generally, we collect, use and disclose your Personal Information for our legitimate interests, including dealing with the operation and functioning of our Site, providing any customer services you require, enforcing the terms of any other agreement between us, for regulatory and legal purposes, and for audit purposes. Additionally, where applicable, we process your Personal Information where you have consented to such processing.

Your rights under the GDPR

If the processing of your Personal Information is subject to the GDPR, you may have the following rights to:

  • obtain confirmation that we hold personal data about you;
  • request access to and receive information about the personal data we maintain about you;
  • receive copies of the personal data we maintain about you;
  • update and correct inaccuracies in your personal data;
  • object to the processing of your personal data;
  • request portability of your personal data; and
  • have the data blocked, anonymized or deleted, as appropriate.

Further, where we are processing your personal data on the basis of your consent, you may contact us with the request to withdraw consent for such processing at any time. 

Exercising your rights under GDPR

You can exercise these rights under the GDPR by contacting us at [email protected].  Please put the statement “GDPR Privacy Rights” in the subject line of your request, and include your name, country or region, and enough information to allow us to respond to your request in the body of your e-mail. 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data.  This is a measure put in place to ensure that personal data is not disclosed to any person who does not have a right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

Questions or concerns about this Privacy Policy

If you have any questions or concerns about our Privacy Policy, please first contact us at [email protected] and provide us the opportunity to make it right.  For our users located in the European Economic Area, if you feel that, after reaching out to us with your question or concerns, you have not received a satisfactory response, you have the option to contact your country’s Data Protection Authority (“DPA”) or similar regulatory body.  To find contact information for your country’s DPA or similar body, please refer to the list provided on the website of the European Commission.