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Privacy Policy

Effective: September 10, 2013
Last Revised: September 10, 2020

This Privacy Policy ("Privacy Policy") is designed to help you understand how Principia Partners LLC (including affiliates, principals, agents, successors and assigns) ("Principia") collects and uses the information that you share when you use www.ppllc.com (the "Site"). This Privacy Policy applies only to information collected on the Site and does not apply to information that Principia receives or obtains offline.

Before submitting information to the Site, please review this Privacy Policy carefully. By using or accessing the Site, you acknowledge that you accept the practices and policies described in this Privacy Policy. It is your responsibility to submit accurate information to the Site. If you prefer that we not collect any personally identifiable information from you, please do not provide us with any such information. When you submit your personally identifiable and other information on the Site, you hereby consent to the collection, use and disclosure of such information as set forth in the Privacy Policy.

1. Personal Information: "Personal Information" is information that can personally identify you. We maintain one or more databases to store your Personal Information and may retain it as reasonably required to fulfill the purposes identified herein. Personal Information that we collect depends on how you use the Site. For example, if you register to use the Site, the Personal Information that we may collect from you may include your name, email address, company of employment, title, telephone number and any other information that you provide to us.

Providing your Personal Information to us is your choice. If you choose not to provide us with certain Personal Information, you may not be able to take advantage of certain features of the Site.

2. General Information: When you visit the Site, we may automatically monitor your activity on the Site and collect various categories of general non-personal information ("General Information"), such as browser information, operating system information, search terms used to locate the Site, IP address and the date, time, length of stay and specific pages accessed during visits to the Site.

3. Emails you send to Principia: When you send an email to Principia, either through the "Contact Us" area of the Site or otherwise, Principia may retain your email address and the contents of the email you send. This Privacy Policy does not apply to content, business information, ideas, concepts or inventions that you send to Principia by email. Please refer to our Terms of Use for our policy with respect to such information. If you want to keep any information private or proprietary, please do not send such information in an email to Principia.

We use "session cookies" to help you access and navigate the Site more efficiently, to customize the user experience, to store certain user information that you previously provided (i.e., username and password) and to statistically monitor how many users are using the Site. A "session cookie" is a temporary, small file or tool stored on a user"s hard drive containing information that allows us to deliver customized information to you. You may set your browser to notify you when a cookie is placed or decline the receipt of cookies; however, certain features of the Site may not function properly or be available to you if your browser is configured to disable cookies. Session cookies are erased once you exit your web browser or turn off your computer.

Principia uses Personal Information and General Information as identified below. Except as specified in this Privacy Policy, Principia does not rent, sell, trade or disclose your Personal Information to third parties without your consent.

Some specific examples of how Principia may use your Personal Information are:

1. to customize, analyze, adjust and improve the Site to better meet your needs;
2. to facilitate communication between Principia and you;
3. to provide you with information that may interest you, such as our newsletters, informational "white pages" or emails about our products and services;
4. to provide you with marketing and promotional information about products and services we believe are of interest to you;
5. to administer a promotion or survey;
6. to enforce Principia"s agreements with you;
7. to provide you with important administrative information regarding the Site, such as changes to this Privacy Policy, our Terms of Use (https://www.ppllc.com/usage.htm) and our other policies; and
8. to prevent fraud and other prohibited or illegal activities.

Principia uses General Information to produce aggregate statistics and create profiles of Site users that include anonymous statistical demographic information. General Information also is used to determine user trends and needs and to improve the Site. We may combine General Information with Personal Information and may use and disclose the combined information as described in this Privacy Policy.

Unless you have consented, or as otherwise described in this Privacy Policy, we will not disclose your Personal Information except for:

1. Affiliates. We may share your information with our affiliates, including, but not limited to, our strategic business partners, who may use your information for purposes similar to the purposes for which Principia collects such information. Principia requires all such companies to comply with the terms of our Privacy Policy.

2. Fulfillment of Services. Principia may retain other companies and individuals to perform functions consistent with our Privacy Policy on our behalf. Examples include customer support specialists, web hosting companies, fulfillment companies (e.g., companies that coordinate mailings), data analysis firms, payment services firms and email service providers. Such third parties may be provided with access to Personal Information needed to perform their functions, but may not use such information for any other purpose.

3. Compliance with Law and Fraud Protection: We may disclose any information, including, without limitation, Personal Information, we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. Principia reserves the right to disclose your Personal Information if we believe you have or are violating of our Terms of Use (https://www.ppllc.com/usage.htm) or in order to protect or defend Principia"s rights or property, even without a subpoena, warrant or other court order.

4. Sale or Transfer of Information: In the event of a sale, merger, liquidation, dissolution or sale or transfer of substantially all of the assets of Principia or the Site, Personal Information and/or other information collected through the Site may be sold, assigned or transferred to the party acquiring all or substantially all of the equity and/or assets of Principia or the Site. In the unlikely event of an insolvency, bankruptcy or receivership, your information also may be transferred as a business asset. By using the Site and submitting your information to us, you consent to the sale and transfer of your information as described in this Paragraph 4.

If you tell us that you do not want us to use your Personal Information to contact you, Principia will respect your wishes. You may instruct Principia to stop sending you email messages, newsletters or other information by sending an email with your name, address and email address with "UNSUBSCRIBE" in the subject line of such email to info@ppllc.com or, if available, following the "unsubscribe" instructions provided. Principia may, however, continue to use your Personal Information to contact you to service your account, or as otherwise authorized by law. Please note that if you use more than one name or email address when communicating with Principia or using the Site, you may continue to receive communications from Principia to any name and/or e-mail address not specified in your opt-out request. If you would like to modify or delete your Personal Information, please send an email to info@ppllc.com with clear instructions in the body of the email about what you would like to have modified or deleted or, if available, following the "edit profile" instructions provided.

Principia has implemented technical, administrative and physical security measures to protect your information from unauthorized access and use. While Principia strives to protect your information, no data transmission over the Internet is 100% secure and, consequently, we cannot ensure the security of any information. In addition, Principia works to protect the security of your personal information when utilizing the Site by using well-known Internet encryption technologies, such as Secure Sockets Layer (SSL). You should be aware that Principia has no control over the security of other sites on the Internet you might visit or interact with even when a link may appear to said site from ours.

Principia wants you to feel confident using the Site. However, no system can be completely secure. Therefore, although Principia takes steps to secure your information, Principia does not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure. In the event of a breach of the confidentiality or security of your personal information, Principia will notify you as necessary so you can take appropriate protective steps. Principia may notify you under such circumstances using the e-mail address(es) Principia has on record for you. Users should also take care with how they handle and disclose their Personal Information. Please refer to the Federal Trade Commission"s website at https://consumer.ftc.gov for information about how to protect yourself against identity theft.

We do not knowingly collect information from minors. To use the Site, you must be the age of legal majority in your place of residence. By using the Site, you hereby represent that you are at least the age of legal majority in your place of residence. The Site does not contain an application or other mechanism to determine the age of users. All information provided to Principia will be treated as if it was provided by an adult. If, however, we learn that a minor has submitted information about himself/herself to us, we will delete the information as soon as possible.

We may provide links to third-party web sites that we do not own or control. We are not responsible for the information collection practices of any website that we do not own or control. We encourage you to review and understand the privacy practices of third-party websites before providing any information to or through them.

We may occasionally update this Privacy Policy to reflect changes in our practices. When we post modifications to this Privacy Policy, we will revise the "Last Revised" date at the top of this web page. The modified Privacy Policy will be effective immediately upon posting on the Site. Your continued use of the Site after the posting of the modified Privacy Policy constitutes your agreement to abide and be bound by it. If you object to any modification, your sole recourse is to stop using the Site.

California law permits individuals who provide Principia with Personal Information and who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. At this time, Principia does not disclose Personal Information to third parties for their direct marketing purposes. If Principia changes this policy, it will update this provision and provide instructions on how you may make a request for details concerning such information.

The Site is hosted in the United States. The Site is governed by United States law. If you are visiting the Site from outside the United States, your information may be transferred to, stored and processed in the United States. The data protection and other laws of the United States and other countries may not be as comprehensive as those in your country. By using the Site, you consent to transfer of your information to our facilities and to the facilities of those third parties with whom Principia shares your information as described in this Privacy Policy.

Any controversy or claim arising out of or relating to this Privacy Policy, or the breach thereof, shall be settled by arbitration in New York City in accordance with the laws of the State of New York. Such arbitration shall be conducted in accordance with the Rules of the American Arbitration Association and judgment upon the award rendered by the Arbitrator(s) may be entered in any Court having jurisdiction thereof. Any claim arising out of this Privacy Policy must be brought within one (1) year of the date on which the claim arose. This Privacy Policy does not create rights enforceable by third parties.

If you have questions about this Privacy Policy or Principia generally, please contact us at info@ppllc.com or (212) 480-2270.

Copyright © 2020 Principia Partners LLC. All rights reserved.