PRIVACY POLICY
ATEM Capital LLC provides this Privacy Policy (collectively with its affiliates and the funds and accounts sponsored or managed by them, “ATEM,” “we,” “us,” or “our”). It is intended to describe the personal data or personal information (collectively, “Personal Information”) we collect, how we use and share it, and rights you may have regarding this information. By accessing the website, you agree to our collection and use of Personal Information as described in this Policy and our Terms of Use.
PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the installed cookies on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products you view, what websites or search terms referred you to the Site, and how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:
“Cookies” are data files that are placed on your device or computer and often include a unique anonymous identifier. For more information about cookies and how to disable cookies, visit http://www.allaboutcookies.org .

“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Also, we may collect 1) contact information and other identifiers, such as name, signature, postal address, e-mail address, phone number, fax number, account name, Social Security number, tax identification number, photographs, copies of identification documents (e.g., passport, driver’s license), and other similar identifiers; 2) demographic and association-related information; 3) commercial and financial information; 4) Internet or other electronic activity information, such as information regarding an individual’s interaction with a website or application, and calls and e-mails sent and received; 5) geolocational information that may be collected on ATEM contractors and vendors; 6) audio, electronic, visual, thermal, or olfactory information; 7) educational and professional background information.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We use Personal Information that we generally collect for 1) communicating with you; 2) for business operations, including but not limited to securing financing; 3) managing administrative and operational matters; 4) administering our service provider, contractor, and vendor relationships and services; 5) conducting research and analysis; 6) marketing our products and services; 7) complying with applicable legal or regulatory requirements and ATEM policies and contracts; 8) monitoring, managing, and securing resources, property, and personnel, 9) sharing with third parties that may in the future acquire or be interested in acquiring all or part of our assets or interests in our business, or that may succeed us in carrying on our business or to which our business is transferred; 10) as described to you when collecting the information.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally, to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above. Finally, we may also share your Personal Information to comply with applicable laws and regulations, respond to a subpoena, search warrant or another lawful request for information we receive, or protect our rights otherwise.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
YOUR RIGHTS
Persons in certain jurisdictions (e.g., the EEA / UK) have rights under data protection laws that may apply to the Personal Information we hold about those persons and which they may exercise. These include 1) to request access to your Personal Information; 2) to request rectification of inaccurate or incomplete Personal Information; 3) to request the erasure of your Personal Information (a “right to be forgotten”); 4) to restrict the processing of your Personal Information in certain circumstances; 5) to object to our use of your Personal Information, such as where we have considered such use to be necessary for our legitimate interests and/or in the case of direct marketing activities; 6) where relevant, to request the portability of your Personal Information to a third party; 7) where you have given consent to the processing of your Personal Information, to withdraw your consent; 8) to complain with the competent supervisory authority.
If you are a European resident, you have the right to access the personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident, we note that we are processing your information to fulfill contracts we might have with you or otherwise to pursue our legitimate business interests listed above.

Additionally, please note that your information will be transferred outside of Europe, including Canada and the United States.
DATA RETENTION
We will maintain your Personal Information for our records unless and until you ask us to delete this information. We may process your Personal Information in the United States, the EEA / UK, and other countries outside the jurisdiction where it was collected that may not offer the same level of data protection as that afforded by the jurisdiction in which you are present. We will process Personal Information (or procure that it be processed) in accordance with the requirements of applicable law, which may include having appropriate contractual undertakings in legal agreements with service providers who process Personal Information on our behalf. Further information about the transfer of Personal Information (including to countries outside of the EEA / UK) is available on request using the contact details set out below.
MINORS
The Site is not intended for individuals under the age of 18.
CHANGES
We reserve the right to amend, alter, or otherwise change this Privacy Policy at our sole and absolute discretion. If we make material changes to the Privacy Policy, we will post a notice in this Policy. Use of the website following any such notification constitutes your agreement to follow and to be bound by the amended Privacy Policy.
CONTACT US
If you have any questions or comments about this Privacy Policy, please feel free to contact us by e-mail to info@atemcap.com to the attention of our compliance officer.
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