Privacy Policy
We at Cobalt Software, Inc. (“Company,” “we,” “us,” “our”) know that our users (“you,” “your”) care about how your personally identifiable information (“Personal Data”) is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By visiting or using the Website or other Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent to our collection, use, and sharing of your Personal Data in the following ways. Any capitalized terms used herein without definition shall have the meaning given to them in the Company Terms of Service.
I. WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy covers our treatment of Personal Data that you provide directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, when we gather Personal Data about you from publicly available sources or when you are accessing or using our Website or any of our other Services. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
Our treatment of Personal Data applies to the following categories of users that we have identified:
As an alternative assets industry individual who is a subject of our research (an “Individual”)
As a subscriber or prospective subscriber to the Company’s Services, both existing and former, who accesses one of our software products or Services, our website, online publications, or marketing newsletters (a “Subscriber”)
Any prospective job applicant of the Company (a “Job Applicant”)
You may fall within one or more of the categories described above.
Children’s Privacy
We do not knowingly collect or solicit Personal Data directly from anyone under the age of 16 or knowingly allow such persons to register for the Services. If you are under 16, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 may provide any Personal Data on their own behalf to us or on the Services. In the event that we learn that we have collected Personal Data from a child under age 16 (and not from a Parent on that child’s behalf), we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16 that was not supplied by that child’s Parent, please contact us at notice@cobaltgp.com.
EU Personal Data
If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined in the EU Privacy Policy.
II. WHAT PERSONAL DATA DOES COMPANY COLLECT AND HOW DOES COMPANY USE THE PERSONAL DATA?
A. Individuals
We collect Personal Data such as your first and last name, role at your firm, firm name, email address, LinkedIn profile URL, telephone number and business address.
Our researchers obtain relevant Personal Data from direct interactions or publicly available sources, such as company corporate websites, LinkedIn, regulatory filings, and news alerts. If you have attended an alternative asset industry event organized or sponsored by the Company, we will have collected Personal Data such as your first and last name, firm name, business address and other contact details.
We process your Personal Data to research key current and historical financing, performance, and investment trends in the alternative asset industry and to provide data and information on firms active in this industry. This includes the provision of company and business professional contact information such as name, role, business address, phone number, and email address. Such Personal Data will be displayed into our products made available to Subscribers.
B. Job Applicants
You directly provide to us Personal Data such as your resume and other information relevant to applying for positions at the Company such as name, email address, phone number, and resume (“Job Applicant Information”). We use Job Applicant information to determine your eligibility for the position and contact you in connection with your application.
C. Subscribers
We collect the following types of Personal Data from Subscribers and use Personal Data in the ways more fully described below.
Personal Data You Provide to Us:
Contact Information
We collect and store contact information on our Website from you when you visit our Website, sign-up for our newsletters, submit a request to schedule a demonstration of our Services, download a whitepaper, or submit a form through Contact Us on our Website. We receive and store any information you provide to us. For example, we may collect Personal Data such as your name, email address, job title, role, firm or company name, mailing address, business address, and telephone number. This Personal Data is used by our sales, account management and support teams to contact you, as appropriate, to provide the requested information, support, or services.
Account Information
When you create an account (on your behalf or on behalf of your employer), we collect your name, title, company name, and contact information.
We use your account information to process and transmit necessary data regarding your account, support, orders, payments, and general updates.
Billing and Payment Information
We may collect billing and payment information, which may include an account number or instructions for wire transfers and/or ACH transfers. We may accept payment by credit card in our sole discretion, and use third party credit card processors for such purpose. The billing and payment information, if obtained, is used to prepare and send invoices make and receive payments, and manage accounts.
Personal Data Collected About You by Company or Third Parties:
We may collect the following Personal Data about you on our own or from third parties, including through publicly available sources, such as your first and last name, role, firm or company name, email address, telephone number and business address. We may use this information to provide you with relevant content on our Website including advertisements regarding the Services, and to communicate with you via email regarding our current and future Services.
We may also receive such Personal Data directly from you if you provide us with such Personal Data.
Information Company Automatically Collects When You Use the Services:
Whenever you interact with our Website or use our other Services, we automatically receive and record certain information including, but not limited to, your IP address, browser information, device identifiers, the web pages you requested, the news stories you opened, the firms you follow, your firm and/or fund search history, your news story search history, your introductions requested and “cookie” information (collectively, “Usage Data”). “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device.
When we collect Usage Data, we use this data internally to analyze user activity, which allows us to better optimize or improve user experiences on our Website and in connection with our other Services and to recommend content that may be of interest to you and to provide a more focused user experience generally. In addition, such user analysis allows us to generate reports with aggregated results to analyze trends.
We may use this information to personalize and improve our Services, to allow you to set up a user account and profile or firm profile, to contact you, to fulfill your requests for certain products and Services (including newsletters and personalized email updates), to analyze how you and other Subscribers utilize the Website and/or other Services, and as otherwise set forth in this Privacy Policy. We may share certain types of Personal Data with third parties (described in this Section and in Section III below).
More About Cookies
Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services through the Internet. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Site or using our Services, whereas “persistent cookies” are stored on your device for a period of time after you leave a site. For more information on cookies, including how to control your cookie settings and preferences, visit http://www.allaboutcookies.org/.
We use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one. The Services use the following cookies:
Essential Cookies. Essential cookies are required for providing you features or services that you have requested. For example, certain cookies enable you to log into secure areas of our Website. Disabling these cookies may make certain features and services unavailable.
Functionality Cookies. Functional cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These cookies help us to personalize our content for you and remember your preferences.
Performance/Analytical Cookies. Performance/analytical cookies allow us to understand how visitors use our Website and Services such as by collecting information about the number of visitors to the Website, what pages visitors view on our Website, and how long visitors are viewing pages on the Website. Performance/analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
You may be able to change the preferences on your browser or mobile device to prevent or limit your computer or device’s acceptance of cookies, but this may prevent you from taking advantage of some of our Website’s features. If you click on a link to a third party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.
E-mail and Other Communications:
We may contact you, by email or other means; for example, we may communicate with you about your use of the Website or any of the Services or send to you general industry newsletters or emails with personalized news updates. Also, we may receive a confirmation and/or other information when you open an email from us. This confirmation and/or other information helps us make emails more interesting and improve our service. If you do not want to receive email or other mail from us, you may opt-out at any time. You may click the “Unsubscribe” link at the bottom of any marketing email and follow the instructions found on the page to which the link takes you. You cannot opt out of receiving transactional emails related to your account or use of the Services. Please note that if you do not want to receive legal notices from us by email, those legal notices will still govern your use of the Website or any of the other Services, and you are responsible for reviewing such legal notices for changes.
III. WILL COMPANY SHARE ANY OF THE DATA IT RECEIVES?
We may share your Personal Data with third parties as described below.
A. Individuals
Subscribers of our Services: We share your Personal Data, mainly your contact information, with Subscribers who agree to our Terms of Service and Privacy Policies. Our Subscribers include, but are not limited to, investors, fund managers, service providers and advisors in the alternative assets industry.
B. Subscribers
Affiliated Businesses and Third Party Websites We Do Not Control: In certain situations, businesses or third party websites we are affiliated with may sell items or provide services to you or otherwise interact with you through the Website and/or the Services (either alone or jointly with us). You can recognize when an affiliated business or third party is associated with such a transaction or service, and we will share your Personal Data with that affiliated business or third party only to the extent that it is related to such transaction or service or interaction. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service or other interaction relating to an affiliated website or business, please review all such policies of these affiliated websites or businesses.
Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
Usage Data: When we collect Usage Data, as described above, we may share such Usage Data in aggregate form (as combined with Usage Data that we receive from our other users), and not in a manner that would identify you personally, for marketing or other business-related purposes. For example, we may share with other users or third parties reports with aggregated results such as what firms are most popular among our users and what investment styles are trending.
Other Parties or Users Authorized by You: We may also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested.
C. Individuals and Subscribers
Vendors, Agents, and Third Party Service Providers: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Data we share with them beyond what is necessary to assist us.
Business Transfers: We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Data would be one of the assets transferred to or acquired by a third party.
Governmental Agencies: We may share Personal Data when we believe it is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud; or maintain the security of our products and Services.
With Your Consent: If authorized by you through the Services or otherwise, your Personal Data may be shared with third parties in personally identifiable form (e.g., as contact information in connection with the firm profile that you provide).
IV. IS PERSONAL DATA ABOUT ME SECURE?
The Company takes very seriously the security and privacy of the Personal Data that it collects pursuant to this policy. Accordingly, we implement reasonable and appropriate security measures to protect your Personal Data.
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Data by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other Personal Data we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Please remember that you control the information that you input, upload or otherwise provide to our Services and the data that is collected in connection with your subscription to our Services.
The Website may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.
V. WHAT PERSONAL DATA OF MINE CAN I ACCESS?
If you have an account with us, through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
Password
First and last name
Contact information
Email address
User profile information
Other content you have uploaded to the Website
Billing, payment or credit card information
The information you can view, update, and delete may change as the Website or any of the Services change.
If you have any questions about viewing or updating information we have on file about you, please contact us at notice@cobaltgp.com. We will respond to all such requests within thirty (30) days after receipt thereof. If you request that any of your Personal Data be deleted from our records, there may be a brief delay in our processing that request, while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that any of your Personal Data be deleted, we reserve the right to terminate and/or limit your access to the Services. While you may request that we delete certain Personal Data, we may continue to utilize and disclose such information in aggregate, non-personally identifiable form as provided above.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Data which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to Cobalt Software, Inc, Two Financial Center, 60 South Street, Suite 820, Boston, MA 02111.
VI. WHAT CHOICES DO I HAVE?
As explained above, you can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of the features of our Website and/or other Services.
You may be able to add, update, or delete information as explained in Section V above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by writing to notice@cobaltgp.com. Please note that some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Data after you update or delete it, but not in a manner that would identify you personally. In the event that your account is deleted by you or the Company or your subscription to the Services terminates or expires, following such deletion, termination, or expiration, you will no longer be able to access any of your account information, the information that you upload or receive through your use of the Services or other Personal Data that we hold in our records following the date the account is deleted.
VII. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time. Use of Personal Data we collect now is subject to the Privacy Policy in effect at the time such Personal Data is used. If we make changes in the way we use Personal Data, we will notify you by posting a notice on our Website, sending you an email or by some other means. Changes will become effective no sooner than thirty (30) days after they are posted or communicated to you. However, changes related to new Services functionalities and modifications made for legal reasons will be effective immediately. Your continued use of the Services following such notification shall constitute your affirmative acknowledgement of the changes and your agreement to abide and be bound by the Privacy Policy, as amended. If at any time you choose not to accept the modifications, then please terminate your subscription to the Services through your Services account.
VIII. QUESTIONS OR CONCERNS
If you have any questions or concerns regarding our privacy policies, please send a detailed message to notice@cobaltgp.com, and we will try to address your concerns.
Last Updated: February 25, 2020