Arlyn Capital Fund (“Arlyn Capital ”, “we”, “us” or “our”) respects your privacy and the security of your Personal information. Arlyn Capital collects and receives information that relates to identified or identifiable individuals. Personal information (“Personal Information”) is any information that relates to identified or identifiable persons, in particular by reference to an identification number or to one or more factors specific to their physical, physiological, mental, economic, cultural or social identity. This policy describes what Personal Information we collect and how we use, process and disclose such Personal Information. This Privacy Policy does not apply to other entities that are not owned or controlled by Arlyn Capital, nor does it apply to persons who are not employees or agents of Arlyn Capital, or that are not under Arlyn Capital’s control.
We may update this Privacy Policy as required. Each time you use our services you should review this Privacy Policy. If we make any material changes to this Privacy Policy we will post a notice on our website when these changes are implemented. Your use of our services following any such changes indicates your acceptance of our Privacy Policy.
Your Personal Information is only collected in accordance with the law. Arlyn Capital does not collect any Personal Information about visitors to our website unless visitors provide such information voluntarily or unless otherwise permitted by applicable laws and regulations governing the protection of Personal Information. Our services are intended for adults only. We do not knowingly collect, solicit, use, process, or disclose Personal Information relating to children.
We may collect your Personal Information from direct and indirect interactions with you to provide our services as agreed by you. Specifically, we may gather Personal Information that may include your: Full name, postal address, email address, and telephone number, We may also collect device/IP data relating to you including IP address, device ID, and domain server.
We may use this Personal Information to: Set up meetings with you, maintain a record of your contacts, respond to your inquiries and fulfill your requests, assist you with your transactions, or provide you with investor-related services.
The use and processing of your Personal Information are necessary for our legitimate interests in providing our services, which include primary operations as a venture capital organization, carrying out administrative duties, running our business, and making or directing investment decisions.
The use and processing of your Personal Information described above are required for our legitimate interests to develop our services and grow our business.
Your Personal Information may be collected directly by interacting with us via:
● Our website, owned and operated by Arlyn Capital (https://revroadcapital.com)
● Our social media and networking pages including:
○ Linkedin (https://www.linkedin.com/company/revroad-capital/);
○ Twitter;
○ Facebook; and
○ Our Affiliates’ social media and networking pages.
● Our events. Arlyn Capital may host, co-host, coordinate, and/or operate Arlyn Capital events, at which we may create visual or audio recordings, take photographs, conduct surveys or similar activities at such events and may as a result collect and process certain Personal Information.
● Email, telephone, in person, by mail, or by providing us with Personal Information for the purposes of applying for investment, becoming or applying to become an investor or applying for employment or in the course of employment.
Your Personal Information may also be gathered by automated means or indirectly via public sources such as results from search engines, third-party databases, company registration offices or cookies on our website.
Arlyn Capital may, where necessary and/or appropriate, process the Personal Information that you provide or that we receive if you participate in any Arlyn Capital program, use any Arlyn Capital service or website or social media and networking pages (“Arlyn Capital Services”), in order to:
● Provide the Arlyn Capital Services you request;
● Manage contact requests: We may use your Personal Information to reply to contact initiated by you, such as through a web form, chatbot, survey responses or Arlyn Capital support. We process your Personal Information for these purposes for our legitimate interest in replying to/fulfilling your request, collecting survey responses and carrying out our contractual obligations under the applicable terms;
● Be compliant with legal obligations that apply to Arlyn Capital ;
● Protect the critical interests of individuals engaging with Arlyn Capital (including employees, prospective employees, LPs, etc.);
● Comply with business and operational measures, such as data security monitoring, service analytics, internal research, and quality control;
● Protect Arlyn Capital’s legitimate interest, and rights, privacy, safety and/or property, and/or those of others.
● Protect, investigate, and deter any fraudulent, harmful, unauthorized, unethical or illegal activity.
● Improve our website: We process your interactions with our website, content, and offerings to assess and improve these and the user experience, such as by use of cookies (see Section 6 below). Such data is generally aggregated unless Personal Information is required for the particular processing operation. We process your Personal Information for this purpose for our legitimate interests of maintaining and improving our website and providing tailored content, or where required by law, on the basis of your consent.
Arlyn Capital may disclose your Personal Information to Arlyn Capital Affiliates, third-party service providers such as human resources, legal, accounting, and cloud storage services, communications and networking services, IT system administrators and professional advisors, background check providers, regulators, government or law enforcement officials (where required) and other relevant authorities (where required). Such disclosures will only be made in accordance with this Privacy Policy and any iterations of this Privacy Policy made over time. All third-party service providers are only permitted to process your Personal Information in accordance with stated purposes and in accordance with our instructions. All processing of your Personal Information by third parties is carried out in accordance with the law and industry-standard security measures.
Arlyn Capital will not sell, rent, release, disclose, disseminate, make available transfer or otherwise communicate in any manner your Personal Information to any third party in exchange for monetary or other valuable consideration.
Cookies are small digital signature files that are stored by your web browser that allow your preferences to be recorded when visiting the website. Also, they may be used to track your return visits to the website. Third-party advertising companies may also use cookies for tracking purposes.
Arlyn Capital uses industry-standard security measures to prevent the loss, misuse, or alteration of your Personal Information within our control, including organizational, technical, and physical measures. In addition, we limit access to your Personal Information to those Arlyn Capital-authorized personnel who have a legitimate business purpose to access such information. All such personnel are subject to strict confidentiality obligations.
We have implemented measures in the event of any suspected Personal Information breach. In such instances, we will notify you and the applicable data protection regulator as required by law. Unfortunately, no security system is entirely secure, and we cannot guarantee the security of your information.
Arlyn Capital will retain and process Personal Information for a period of time consistent with the purpose of collection (see section 3 above) and/or as long as necessary to fulfill our legal obligations. We determine the applicable retention period by taking into account the (i) amount, nature, and sensitivity of the Personal Information, (i) relevant use, including whether we can achieve the use through other means (e.g., by instead using anonymized information); (iii) potential risk of harm from unauthorized use or disclosure of the Personal Information, and (iv) applicable legal requirements such as statutes of limitation.
In certain circumstances, we may anonymize your Personal Information. In such circumstances, we may use such anonymized data indefinitely without further notice to you.
You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
● Disclosure of Personal Information We Collect About You. You have the right to know and request disclosure of:
■ The categories of personal information we have collected about you, including sensitive personal information;
■ The categories of sources from which the personal information is collected;
■ Our business or commercial purpose for collecting, selling, or sharing personal information;
■ The categories of third parties to whom we disclose personal information, if any; and
■ The specific pieces of personal information we have collected about you.
■ Please note that we are not required to:
■ Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
■ Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
■ Provide the personal information to you more than twice in a 12-month period.
● Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose. In connection with any Personal Information we may sell, share, or disclose for a business purpose, you have the right to know:
■ The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and
■ The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.
■ You have the right to opt-out of the sale of your Personal Information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.
● To opt-out of the sale or sharing of your personal information, visit our homepage and reach out to us via email using the verbiage ‘Opt Out’ in the subject line.
● Right to Deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
● Delete your Personal Information from our records; and
● Direct any service providers or contractors to delete your Personal Information from their records.
● Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.
● Please note that we may not delete your personal information if it is reasonably necessary to:
● Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
● Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes;
● Debug to identify and repair errors that impair existing intended functionality;
● Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
● Comply with the California Electronic Communications Privacy Act;
● Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
● Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
● Comply with an existing legal obligation; or
● Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
● Right of Correction. If we maintain inaccurate Personal Information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
● Protection Against Retaliation. You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:
● Deny goods or services to you;
● Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
● Provide a different level or quality of goods or services to you; or
● Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
● Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your Personal Information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of Personal Information, the sale of Personal Information, or the retention of Personal Information.
Arlyn Capital reserves the right to make changes to this Privacy Policy at any time without prior consultation. Any changes to this Privacy Policy will be posted on the Arlyn Capital website (https://www.arlyncapital.com/).
To exercise your rights please contact Arlyn Capital by mail at the following address: Arlyn Capital, 2250 West Center Street, Springville, UT 84663 or contact us via email at aj@arlyncapital.com with a copy of your identification. Depending on your request and the applicable law, we may be entitled to decline your request.
Last updated: November 4, 2024
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