The privacy practices of this Website Privacy Policy apply to our services available under the domain and subdomains of www.newharborcap.com (the “Website”) and supplements New Harbor Capital LLC Privacy Policy provided to investors annually. We recognize that privacy is important to our users, so we design and operate our Website with the protection of your privacy in mind. This Website Privacy Policy outlines the types of personal information we may gather when you visit our Website or use our services, as well as some of the steps we take to safeguard it. Please read this Website Privacy Policy to learn more about the ways in which we protect, use and disclose your personal information. By visiting the Website, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please do not use or access the Website.

By accepting the Website Privacy Policy and the Terms of Use, you expressly consent to our use and disclosure of your personal information in accordance with this Website Privacy Policy. This Website Privacy Policy is incorporated into and subject to the Terms of Use.

Overview

We have policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Website is protected by those policies and procedures. Generally, we collect and maintain non-public personal information about our limited partners and clients from the following sources:

• Information received from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail or in subscriptions agreements, investor questionnaires, applications or other forms, and including the information we collect on the Website, and
• Information about your transactions with us or others.
  • We do not disclose any non-public personal information about you to anyone, except as permitted by law or regulation and to service providers.
    • We do not disclose any non-public personal information about our former limited partners and clients to anyone, except as permitted by law or regulation and to service providers.
  • We maintain physical, electronic and procedural safeguards to protect your non-public personal information  in our possession or under ur control.

Policy

Collection of Information

In general, you can browse the non-password-protected sections of the Website without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users’ demographics, interests and behavior to better understand, protect and serve you and our clients. This information may include the URL from which you just came (whether this URL is on the Website or not), to which URL you next go (whether this URL is on the Website or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services.

We also may use data collection devices such as “cookies” on certain pages of the Website to help analyze our web page flow, measure effectiveness, and promote trust and safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a “cookie”.  Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Website and you may be required to reenter your password more frequently during a session.

Use and Disclosure of Information

We use the information we collect from our browser and data collection devices such as cookies to improve our operations and facilitate the services you request. We may use information collected from you to measure interest, customize your experience and enforce our Terms of Use.

You agree that we may use personal information about you to analyze Website usage, improve our content and product offerings and customize the Website’s content, layout, and services. These uses improve the Website and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Website.

We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not described in this Website Privacy Policy. For example (without limiting the foregoing), we may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal information that they collect from the Website. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications   will always remain private.

Control of Your Password and Personal Information

You are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your user name or password to access or use any part of this Website. If your password has been compromised for any reason, you should change it immediately or contact us if you need assistance.  You should promptly update your personal information if it changes or is inaccurate.

On your request, we will promptly deactivate your account access. Following deactivation we will retain your personal information to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use and comply with legal requirements. Therefore, you should not expect that your personal information will be completely removed from our databases in response to your requests. However, such personal information will only be available to select employees, service providers and governmental persons or entities.

Changes to this policy

This Website Privacy Policy may change from time to time. We may amend this Website Privacy Policy at any time by posting the amended terms on the Website. All amended terms shall automatically be effective immediately when initially posted on the Website.