Last Updated: January 31, 2020
 

At Lighter Capital, Inc., your privacy is very important to us. The purpose of this privacy policy is to describe how we collect, use and share your personal information, in conformance with our applicable privacy law obligations. This Policy is not intended to cover information other than personal information, such as proprietary, business or anonymous information.
 

This Policy applies to personal information we collect, use or disclose, including when you:
 

• visit the Lighter Capital web site located at www.lightercapital.com, and associated sub-domains (the “Site”)

• submit personal information to us,

• apply for a job with us,

• authorize us to obtain personal information from other sources, and

• interact with us (by email, telephone, online or in person).

By visiting the Site you agree to the provisions of our Terms of Use, which is incorporated by reference into this Policy. If you do not agree to the terms of this Policy, please do not use or access the Site or use the Services (defined below).
 

Information Collected
 

We collect and store information that you voluntarily provide to us as well as data related to your use of the Site or Services.
 

We may request that you provide personal information, including your name, address, email address, telephone number, and other information from which your identity is or may be discernible. Such information is collected for the purpose of contacting you with information regarding prospective funding opportunities for your company based on your specified interests (the “Services”). It is solely up to you whether you furnish such information. If you do provide such information, you are thereby consenting to the use of that information in accordance with the policies and practices described in this Policy.
 

In addition, during your visit we automatically collect certain technical information and analytical data related to your Site visit (see Cookies and Analytics below). Technical information is non-personally identifiable information about you, including the date and time of your visit, the IP address of your computer or mobile device, your computer or mobile device browser information, the Internet address that you visited prior to and after reaching the Site, the name of the domain and host you used to access the Internet, the type of mobile device you use, your mobile device’s unique device ID and the features of our Site which you accessed.
 

Use of Information
 

Lighter Capital’s mission is to help growing businesses get financing. The main way in which we do that is by investing our own money (we are a non-bank, private equity capitalized, investor). We use personal information we collect about a client applying for financing to get the whole picture and to try and make the best investment decision for ourselves and for the client. This internal use includes sharing information among our employees, contractors, attorneys, capital providers (investors & lenders), and our Investment Committee.
 

In addition, we may use the personal information we collect for the following purposes:
 

• Providing support and services: including to provide our Services, operate our Sites and online services, and interact with you about your application, account or funding; to communicate with you about your access to and use of our Site and Services; to respond to your inquiries; to provide troubleshooting, process and collect your payments; provide technical support; and for other customer service and support purposes.

• Analyzing and improving our business: including to better understand how users access and use our Services and Sites, to evaluate and improve our Sites, Services and business operations, and to develop new features, offerings and services; to conduct surveys and other evaluations (such as customer satisfaction surveys); to monitor consumer interest in our products and Services; to troubleshoot problems that may arise on the Sites; to improve the accuracy of our customer database; to increase our understanding of our customer database; to increase our understanding of our customers; and for other research and analytical purposes.

• Personalizing content and experiences: including to tailor content we send or display on our websites and other Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences. To assist in these purposes, as well as the other purposes identified in this Policy, at certain times, we create a profile relating to you in order to show you the content that we think you might be interested in and to display the content according to your preferences.

• Advertising, marketing and promotional purposes: including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about our Services, products, or other information we think may interest you; to identify potential new customers; and to administer promotions, sweepstakes, contests or other special promotions.

• Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.

• Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties.

• Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.

• Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.

 

Aggregate and De-identified Data. We may de-identify personal information and create anonymous and aggregated data sets and reports to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry and for other research, marketing and analytics purposes. Such information may also be shared with third parties for other analytical purposes but will not personally identify any individual and therefore is not subject to this privacy policy.
 

Disclosure of Information
 

We may share the personal information we collect as follows:

 

• Service providers: We may disclose personal information with third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, customer service and/or support providers.

• Subsidiaries and affiliates: We may share your personal information with our affiliated companies (i.e., our parent company and other companies under common ownership, control or management with us); they may use such personal information for the purposes set out in this Policy.

• External partners: We may also join together with other businesses to bring selected opportunities to customers or potential customers. For example, we may share client information with external partners who can provide additional financing options. You may opt out of such sharing as explained in the Choices and Rights section below.

• Third party ad companies: We may share personal information with third parties that provide advertising, campaign measurement, online and/or mobile analytics, and related services. These third parties may receive or access as browsing and/or other data about your use of the Services, in order to help us better reach individuals with relevant ads and/or measure our ad campaigns, and/or to better understand how individuals interact with our Sites and Services overtime and across devices.

• Legal compliance: We may share personal information where necessary to comply with a law, legal obligation or legal process, such as in response to a valid court order, subpoena, or government investigation. In addition, we may share certain personal information in order to protect the rights, property and safety of our company and/or others, in support of our compliance with tax or corporate governance legislation, to assist law enforcement, for debt collection purposes, for loss and fraud prevention, or to regulatory or other governmental authorities with jurisdiction over us or our affiliates.

• Business transfers: We may disclose and/or transfer personal information as part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.

• Protect our rights: We may disclose personal information where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and/or to protect the rights, property or safety of Lighter Capital or our affiliates, clients, customers and/or others.

 

Aggregated and De-identified Data. We may share aggregate or de-identified information with third parties for research, analytics and/or other purposes.
 

Cookies and Analytics 
 

We use cookies, pixels, tags, and other technologies, which may be provided by third parties, on our Sites to enable certain functionality and for security and fraud detection and prevention, as well as to collect usage information about our Sites and the emails that we send and to personalize content and provide more relevant ads and information. We may combine the information we collect via these technologies with other information, including personal information, that we collect.
 

Cookies. Cookies are alphanumeric identifiers that are transferred to your computer through your web browser for record-keeping purposes. Some cookies enable you to log-in to our Sites or save certain settings and preferences, while others, allow us to track usage and activities on our Sites, personalize content on our Sites, or deliver more relevant ads on our Sites and third-party sites.  Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” tab on the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.  If you block cookies, however, certain features on our Sites may not be available or function properly.
 

Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.
 

Pixel tags and embedded script (aka clear GIFs and web beacons). Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, pixel tags are embedded invisibly on web pages. We may use these, in connection with our Sites to, among other things, track the activities users of our Services, improve ads, personalize and manage content, and gather usage information about our Sites. We may also use these in HTML emails to, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. For example, our website may use the Facebook Pixel. This analytics tool allows Lighter Capital to understand and deliver personalized ads. The collected data remains anonymous and Lighter Capital cannot see the personal data of any individual user. However, the collected data is saved and processed by Facebook. Facebook may be able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy found You can opt-out of Facebook’s use of Facebook Pixel through settings on your Facebook Account.
 

Third Party Analytics Tools. Our Sites use automated devices and applications operated by third parties, such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Sites 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 you can opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
 

Do-Not-Track Signals. Please note that our Sites do not recognize or respond to any signal which your browser might transmit through the so-called ‘Do Not Track’ feature your browser might have. If you wish to disable cookies on our Services, you should not rely on any ‘Do Not Track’ feature your browser might have.
 

Interest-based Advertising
 

We work with third party ad networks, channel partners, affiliates, measurement services, analytics and others (“third party ad companies”) to display advertising on our Services, and to manage or measure our advertising on third party sites, social media platforms, mobile apps and online services, as well as to send you promotional materials or offers via email or direct mail. We and these third party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Sites (as well as on third party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these third party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.  
 

Custom Lists and Matching.  We may create and disclose hashed customer list information (such as name and email address) with third parties—such as Facebook and Twitter—so that we can better target ads and content to you and others with similar interests, within these third-party services. These third parties use the personal information we provide to help us target ads and to enforce their terms, but we do not permit them to use or share the data we submit with other third-party advertisers.
 

Opt-out of targeted ads. You may control how participating third-party ad companies use the information that they collect about your visits to our Sites, and those of third parties, in order to display more relevant targeted advertising to you; for more information and to opt-out of go to:
 

• Canada: http://youradchoices.ca

• EU: http://youronlinechoices.eu

• US: http://aboutads.info

 

Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
 

Storage and Transfer of your Information
 

Your personal information may be stored or processed on our servers, and on the servers of third party service providers, in the United States, Canada and other jurisdictions.  Additionally, some of our service providers may access personal information from countries other than your home jurisdiction, and in those circumstances will be subject to the laws of that local jurisdiction.  As a result, in certain circumstances, other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the personal information collected and held by Lighter Capital.  In addition, if you are visiting the Site from a country other than the United States, your communication through our Site or any of our services may result in the transfer of information across international boundaries.  By using our Site or any of our services, you consent to the collection, storage, and processing of your information in the United States, Canada and in any country to which we may transfer your information in the course of our business operations.
 

Choices and Rights
 

Marketing emails. If you choose to take advantage of the Services by applying for financing, you will receive periodic emails regarding Services, based on the information you provide, may be of interest. If you no longer wish to receive our communications, you may unsubscribe by following the instructions included in each communication.
 

Updating Information. You may review, correct, update or change the personal information you provide at any time. If you would like to edit your personal information, please contact us, in writing, using any of the contact methods outlined below..  We may retain copies of historical data as part of our business records.
 

Opt-out.  You may opt out of our disclosure of your personal information to external partners by contacting us via email at privacy@lightercapital.com.
 

If you are a California resident, you have certain rights, under California privacy laws, regarding your personal information as set forth below.
 

Links to Third Party Sites
 

The Site may contain links to third party sites operated by other organizations. Lighter Capital is not responsible for the privacy practices or content of any of such websites to which we link. If you access such websites, either directly or via the Site, you should review the privacy policy of each respective third party.
 

Security
 

We have implemented safeguards and technical measures to protect the personal information that we have under our control from unauthorized access, use or disclosure. However, no data security measures can guarantee 100% security. You should take steps to protection your information by logging out of your account when finished and keeping your password private.
 

Children’s Privacy
 

This Site and our Services are not directed to person under the age of 13. If you become aware that your child has provided us with personal information without your consent, please contact us, in writing, using any of the contact methods outlined below.  We do not knowingly collect or solicit information from, market to or accept services from children. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information and terminate the child’s account.
 

Policy Changes
 

Each time you use the Site, the current version of the Policy will apply. Accordingly, when you use the Site, you should check the Last Updated date at the top of this Policy and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. If we materially change our policies and practices with respect to the personal information we have previously collected about you, we will endeavor to provide you notice, such as through prominent notice on our Site or by sending you an email.
 

Contact Us
 

To contact us with your questions or comments regarding this Policy or the information collection and dissemination practices of the Site, please contact us via email at privacy@lightercapital.com or by telephone at (888) 598-1005. Please note that we may need to confirm your identity or request additional details to process your request.
 

Additional Information for California Residents
 

In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”).
 

Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. In general, we may (i) collect and (ii) disclose for a business purpose, the following categories of personal information (as defined by the CCPA) about California residents: (a) identifiers: such as a real name, alias, address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers; paper and electronic customer records containing personal information, including without limitation, name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information; characteristics of protected classifications under applicable state or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information; commercial information, including records of real property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies; internet or other electronic network activity Information: including without limitation browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement; geolocation data; employment history: professional or employment-related information; education information that is not publicly available personal information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99); profiles and inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
 

We collect these categories of personal information from the sources described in the Information We Collect section above, and for the purposes described in the Disclosure of Personal Information section above.

 
 

The CCPA defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration.  We may “sell” (as defined by the CCPA) the above categories of personal information to third parties, such as our business partners so they may contact you with information, products and services for your business.  We also may make certain categories of personal information available through third party cookies and tags to collect browsing history and other information on our Sites to improve and measure our ad campaigns, including (a) identifiers such as a real name, alias, address, unique personal identifier, online identifier, IP address; and (b) internet or other electronic network activity Information: including without limitation browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
 

California Residents’ Rights. Subject to certain exceptions, California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.  Lighter Capital will respond to requests from California residents to the extent required by the CCPA.
 

• Do-not-sell: California residents have the right to opt-out of our sale of their personal information by submitting a request as set forth below. In addition, you may opt out of our sale of personal information to participating third party ad companies at: https://www.privacyrights.info/. We do not sell personal information about residents who we know are younger than 16 years old without opt-in consent.

• Notice before collection: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

• Request to delete: California residents have the right to request, at no charge, deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.

• Request to know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including:

  • categories of personal information collected;

  • categories of sources of personal information;

  • business and/or commercial purposes for collecting and selling their personal information;

  • categories of third parties/with whom we have disclosed or shared their personal information;

  • categories of personal information that we have disclosed or shared with a third party for a business purpose; and

  • categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

 

California residents may make a Request to Know up to twice every 12 months, at no charge. We will respond to verifiable requests received from California residents as required by law.
 

California residents may submit requests under the CCPA:
 

• Via email at privacy@lightercapital.com

• By phone at (206) 455-9633

 

We will respond to verifiable requests received from California residents as required by law. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA.
 

For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.