Privacy Policy

Great Elm Capital Group, Inc. Privacy and Cookies Policy

Effective as of November 17, 2016

The following privacy policy is designed to inform you, as a user of the Website, of the types of information that we may collect from you in connection with your use of the Website, and how that information may be used.

Great Elm Capital Group, Inc. (the “Company” or “we”) values your privacy rights, whether you participate interactively or simply view the website (the “Website”). The following privacy policy is designed to inform you, as a user of the Website, of the types of information that we may collect from you in connection with your use of the Website, and how that information may be used.  This policy only governs your activities on the Website, and it does not govern activities that are “offline” or unrelated to the Website.  Please take a moment to review our policies and practices described below.  By visiting our Website, you consent to these policies and practices.

Gathering and Use of Non-Personally Identifiable Information

Non-Personally Identifiable Information is information that, without the aid of additional information, cannot be directly associated with a specific person. 

Like most website operators, we may gather Non-Personally Identifiable Information of the sort that web browsers, depending on their settings, may make available. That information includes a user’s Internet Protocol (“IP”) address, operating system and browser type, and the locations of the web pages you view right before arriving at, while navigating and immediately after leaving the Website.  We may also collect information relating to whether you have accessed the page before and the time of your last visit.

We may collect this general non-personal information about you when you visit our Website by placing a cookie on your computer.  A cookie is a piece of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the site.  When you access our Website, we may place a cookie on your computer. This cookie is not used to identify you and will not collect personal information.  This cookie allows us to determine that a visit has occurred within our site, as well as which pages were viewed. These cookies are deleted from your computer when you leave the site and are used solely to help you navigate the site.

You can decide if and how your computer will accept cookies by configuring the preferences option within your web browser. If you choose to decline cookies, however, some of the functionality of this Website might be impaired.

We use the information collected about site visits, including IP address, the pages you view, information you search for, the average time spent on our websites, and statistical information about website visits, in aggregated form to better understand our audience and its interests, and to increase the functionality and user-friendliness of our site.  We do not attempt to link information gathered using cookies to Personally Identifiable Information.

Collection and Use of Personally Identifiable Information

“Personally-Identifiable Information” or “PII” is information such as a name or email address that, without more, can be directly associated with a specific person.

We will collect certain PII about you if you contact us through our website or other means (using the Contact or Email Notification pages) and submit such information. For example, we will ask for and collect your name, company name, address, city, state, zip/postal code, country, email address, phone number, fax number, and any other information that you choose to provide to us in your subject line and message boxes.  We, or our Service Providers, may also collect your PII, including, without limitation, your e-mail address, if you subscribe to our e-mail alerts.

We consider the PII we collect from you to be confidential. If you submit your e-mail address or other PII to us via our Website while requesting information or email notifications, we will use this information only to the extent necessary to respond to your request(s) and as discussed below.

To the extent permitted by law, any information collected over our website or concerning its use (personal and non-personal) may be disclosed to government authorities or third parties pursuant to a legal request, subpoena, or other legal process. We may also use or disclose your information as permitted by law to protect the rights or property of the Company, our customers, our Website, its users, or third parties, or when we otherwise believe in good faith that the law requires it.

If you are visiting the site from outside the United States, including from a member state of the European Union or another country with strict data protection or privacy laws, you (i) should be aware that this site is hosted, and some Great Elm companies are located, in the United States and other countries that do not have similar laws in place and to which your PII may be transferred and (ii) expressly consent to the processing of your information in accordance with the terms and conditions set forth in this policy. 

You have rights of access to, or correction of, personal information held about you by some of Great Elm’s affiliated companies under UK and other data protection laws. If you wish to review or correct the PII we may have about you, please submit a request to do so through our Contact page.

To What Third Parties Do We Disclose Your Personally Identifiable Information?

We might share your PII with our affiliated companies and with our business partners or others who work for us such as service providers, vendors, contractors and agents (collectively "Service Providers") to enable them to perform services for us.  We require that our Service Providers not sell, transfer or use your PII other than in accordance with our privacy policy with them.

Third parties are under no obligation to comply with this Privacy Policy if you provide information directly to those third parties. The Company neither owns nor controls third-party websites accessible through the Website. Therefore, before visiting a third-party website and before providing any PII or other information to any third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to protect their privacy.

We might also disclose your PII to third parties as described in this Privacy Policy under "What If There Is a Change in Corporate Control?"

How Do We Protect Personally Identifiable Information Collected on This Site?

We have established certain reasonable electronic and administrative safeguards and take reasonable precautions to protect the PII in our possession from loss, misuse, and unauthorized access, disclosure, alteration and destruction. We do not warrant or represent that this level of security meets or exceeds any particular standard. You should keep in mind that no Internet transmission is ever 100% secure or error-free.  Due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from unauthorized intrusion by third parties, such as hackers.  While we strive to protect visitors' personal information, we cannot ensure or warrant the security of any information visitors transmit to us, and visitors do so at their own risk. 

What If There Is a Change in Corporate Control?

In the event of a corporate change in control resulting from, for example, a sale to, or merger with, another entity or in the event of a sale of assets, the Company reserves the right to transfer your personal information to the new party in control or the party acquiring assets.

Changes to This Privacy Policy

We reserve the right, in our sole discretion, to modify, alter or otherwise update this policy at any time and you agree to be bound by such modifications, alterations or updates. We will notify you of material changes to this privacy policy by posting the revised policy with the date it was revised on this page. Unless we obtain your express consent, any revised Privacy Policy will apply only to information collected after such time as the revised Privacy Policy takes effect, and not to information collected under any earlier Privacy Policies. Your continued use of our Website constitutes your agreement to this privacy statement and any updates and, in particular, our use of your PII as described in it. We encourage you to periodically review this privacy statement to stay informed about any changes to this Privacy Policy.

How Can You Contact Us?

If you would like to contact us about this policy or our Website, please reach out to us via the Contact page.