Effective date: December 18, 2018
Data We Collect
When you interact with our Website, we may collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”), as described below:
Personal Data That You Provide: If you voluntarily submit information to us (for example, when you request information by completing our “Contact Us” form), we will collect Personal Data that you elect to provide, such as your name, contact information (e.g. email and phone number) and the content of your message or request.
Automatically Collected Data: As you interact with our Website, our server collects certain usage information, such as information about the number and frequency of visitors; how users are directed to and visitor paths through our Website. This information includes the websites that you access immediately before and after your visit to our Website, the Internet browser you are using and your internet protocol (“IP”) address.
How We Use Personal Data
We use your Personal Data as necessary for certain legitimate business interests, which include the following:
- To respond to your inquiries or questions;
- To administer our Website and prevent fraud, criminal activity, or misuses of our Website and ensure the security of our IT systems, architecture and networks; and
- To comply with legal obligations, legal process and procedures.
For information about what we mean by “legitimate interests” and the rights of individuals in the European Union (“EU”), please see the “EU Users” section below.
How We Share Data
We may share your data as follows:
- With our service providers who assist us in meeting business operations needs and to perform certain services and functions, including analytics (e.g. Google Analytics and WordPress), search engine providers, providers of hosting, cloud services and other information technology service providers that assist us in the maintenance, improvement and optimization of the Website;
- With any relevant third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, including in the event of a reorganization, dissolution or liquidation; and
- Any relevant party, claimant, law enforcement agency, court, governmental, supervisory or regulatory bodies, to the extent necessary for the establishment, exercise or defense of legal rights in accordance with applicable law and regulation.
What Are Cookies. A “cookie” is a piece of information sent to your browser by a website you visit.
Type of Cookies Used. The Website uses the following technologies:
- Google Analytics. The information collected by Google (including your IP address) will be transmitted to and stored by Google, Inc. on servers in the United States (Google is certified to the Privacy Shield for data transfers). Some Google Analytics cookies expire at the end of your browser session, whilst others can remain for up to two years WordPress, the software system on which our Website is built.
International Data Transfers
We are based in the United States. Your Personal Data will be stored on servers in the United States. We will take steps to ensure that your information receives an adequate level of security protection where it is processed and your rights continue to be protected. Some of our service providers (such as Google Inc.) are certified to the Privacy Shield, a framework operated by the U.S. Department of Commerce that permits to transfer personal data outside the EEA or, as applicable, Switzerland, to certified companies in accordance with EEA data protection law (for more information visit: https://www.privacyshield.gov).
Scope. This section applies if you are a user in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland).
Data Controller. Denham Capital Management LP is the data controller responsible for your Personal Data collected through this Website. [We have appointed Denham Capital Management (UK) LLP, our subsidiary registered in the UK as our representative in the European Union pursuant to Article 27 of the General Data Protection Regulation, only on matters related to the processing of Personal Data collected through the Website.] You may contact us or our representative as set out under the “Contact Us” section below.
Your Rights. Subject to applicable EU law, you have the following rights in relation to your Personal Data:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
- Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing.
- Right to data portability: You have the right to obtain your Personal Data in a structured, commonly used and machine-readable format where our legal basis for processing your data is your consent or necessity to perform a contract with you, if applicable.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so, if we are relying on the legitimate interest legal basis to process your Personal Data – unless we demonstrate compelling legitimate grounds for the processing;
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
You may exercise your rights by contacting us as indicated under the “Contact Us” section below.
Legitimate Interest. “Legitimate interests” means our interests in administering and conducting our business, managing risks and delivering the best Website experience to you. This Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.
We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.
To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
This Website may contain links to other sites owned and operated by other parties. We are not responsible for and have no control over the privacy policies of those sites. By providing these links we do not imply that we endorse or have reviewed these sites. We encourage you to review the privacy policies of those sites prior to providing them with any information.
Changes to the Policy
We may change this Policy at any time. If we materially change our privacy policies or practices, we will also update this Policy and notify you of such changes if required by law.
If you have any questions regarding our Policy or our privacy-related practices, please contact us.
If you are an individual in the EU, you can also contact Denham Capital Management (UK) LLP, our subsidiary registered in the UK who has been appointed as our representative in the European Union pursuant to Article 27 of the General Data Protection Regulation only on matters related to the processing of Personal Data collected through the Website. To make such an inquiry, please contact us.