PRIVACY POLICY

GDA Luma Capital Management, L.P. Privacy Policy

Effective date: November 7, 2024

GDA Luma Capital Management, L.P., together with its affiliates and funds (“GDA Luma,” “we,” or “us”) have created this Privacy Policy to explain how we collect, use, store, share and transfer personal data and information (“Personal Data”) that we may gather when you access or use our Site located at www.gdaluma.com (the “Site”). This Privacy Policy is incorporated into and is part of the Terms of Use that govern your use of the Site in general. Please read it carefully.

This Privacy Policy does not address our privacy practices concerning any nonpublic personal information we collect from our investors, potential investors, or employees (including prospective employees or contractors) through sources other than the Site. Those privacy practices are described in separate documents.

As used in this Privacy Policy, “Personal Data” includes any information that identifies or relates to a particular individual and includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. To the greatest extent permitted by law, by using the Site, you agree to the terms of this Privacy Policy and consent to our use of your Personal Data consistent with it.

If you have a disability, you may access this Privacy Policy in an alternative format by contacting info@gdaluma.com.

 

Categories of Personal Data We Collect

The following sections detail the categories of Personal Data that we may collect and have collected over the past twelve (12) months. For each category of Personal Data, these subsections also set out our commercial or business purpose for collecting that Personal Data and the categories of third parties with whom we share that Personal Data (if any). More information regarding those sources and categories are set forth in the charts below.

 

Category of Personal Data Examples of this Type of Personal Data Collected Categories of Third Parties with Whom we Share Personal Data
Identifying Information You Voluntarily Choose to Provide Name, email address, or other personal information that you send to us Service Providers
Device/IP Information IP Address, Type of device / operating system / browser used to access the Site Service Providers
Web Analytics Web page interactions Service Providers

 

The following sections provide additional information about how we collect your Personal Data.

 

Sources of Personal Data

We collect Personal Data from you in the following circumstances:

  • When you provide such information directly to us
  • When you send us an email or otherwise contact us
  • When you use the Site and such information is collected automatically.
    • The Site uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Site, to analyze trends, learn about our user base and operate and improve our Site. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Site. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Site does not support “Do Not Track” requests sent from a browser at this time.
    • You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies. Many browsers also allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our Site and some of the features and functionalities of the Site may not work.
    • To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit www.gdaluma.com or http://www.allaboutcookies.org/.

 

The Purposes for Which We Collect Personal Data

  • Providing, customizing, and improving the Site
    • Providing you with information you request
    • Providing support and assistance for the Site
    • Improving the Site, including testing, research, and internal analytics
    • For other business purposes that we disclose when collecting your Personal Data or as otherwise permitted under applicable data privacy laws.
  • Communicating with you, such as responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about GDA Luma or the Site.
  • Meeting legal requirements and enforcing legal terms
    • Fulfilling our legal obligations under applicable law, regulation, court order, or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
    • Protecting the rights, property, or safety of you, GDA Luma, or another party.
    • Enforcing any agreements with you
    • Resolving disputes

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Categories of Third Parties with Whom We May Share Personal Data

Personal Data will not be sold or shared with third parties for promotional or marketing purposes.

We may disclose your Personal Data to Service Providers.  These are third parties that help us provide our Services, including security providers, hosting and other technology and communications providers, and analytics providers.

 

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting legal requirements and enforcing legal terms” in the “The Purposes For Which We Collect Personal Data” section above.

 

Business Transfers

All of the Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, reorganization, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). If one of these events occurs, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

 

Data That Does Not Identify You

We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Site and promote our business, provided that we will not share such data in a manner that could identify you.

 

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Please be aware, however, that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

We retain Personal Data about you for as long as necessary to comply with our legal obligations, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

 

Children

You must be at least 13 years old to use the Site. We do not knowingly collect or solicit personally identifiable information from individuals under 13. If you are under 13, please do not attempt to use the Site or send any personal information about yourself to us. If we learn we have collected personal information from an individual under 13, we will delete that information as quickly as possible.

 

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@gdaluma.com.

 

ACCESS

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information: The categories of Personal Data that we have collected about you.

  • The categories of sources from which that Personal Data was collected.
  • The business or commercial purpose for collecting or selling your Personal Data.
  • The categories of third parties with whom we have shared your Personal Data, if any.
  • The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient.

 

DELETION

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions; for example, we may need to retain your Personal Data to provide you with access to the Site or complete an action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

 

EXERCISING YOUR RIGHTS

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request by emailing us at info@gdaluma.com. You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

 

SALES OF PERSONAL DATA

We will not “sell” your Personal Data, as that term is defined in the CCPA, and have not done so over the last 12 months.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our services, charge you different rates, or provide you a lower quality of services if you exercise your rights under the CCPA.

 

Other State Law Privacy Rights

 

CALIFORNIA RESIDENT RIGHTS

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at info@gdaluma.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of Sites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different sites. Our Site does not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit https://www.allaboutdnt.com.

 

NEVADA RESIDENT RIGHTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at info@gdaluma.com with the subject line “Nevada Do Not Sell Request” and providing us with your name. Please note that we do not currently “sell” your Personal Data as that term is defined in Nevada Revised Statutes Chapter 603A.

 

Contact Us

Contact Information: If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, you may contact us at info@gdaluma.com or by mail at GDA Luma, 885 Third Avenue, Suite 24C, New York, NY 10022 or GDA Luma, 1450 Brickell Bay Drive, Suite 705, Miami, FL 33131.