Privacy Policy

Last updated: March 23, 2023

We at Lacuna Strategies LLC (“Lacuna Strategies,” “we,” “us,” or “our”) created this privacy policy (“Privacy Policy”) because protecting your private information is our priority and we are committed to safeguarding the information you provide to us. This Privacy Policy is intended to help you understand the terms and conditions surrounding the collection and use of your data and explains what personal information we may collect about you through our website, when we collect it, how we may use it, and who we may disclose it to.

By visiting our website located at https://www.lacuna-strategies.com (the “Site”), you are agreeing to the terms of this Privacy Policy.

Collection of Your Personal Information.

Personal Information We Collect

When you become a user of the Site (a “User”), you may be asked to provide us with certain personal information.

We collect personally identifiable information that you provide or have provided through some other direct contact from you. This information may include your name, address, telephone number, e-mail address or other information you voluntarily provide to request a product demo, inquire about products and/or services, or to opt-in to receiving future communications from us.

When you access our Site, we may also passively or automatically collect additional personally identifiable data and non-personally identifiable data regarding the means you use to access our Site and the content you view when you use our Site. This information may include the type and version of your browser, your service provider, Internet Protocol address (e.g. IP address), device identification information, certain geo-location data, and any search engine or other referring site you may have used to locate our website.

Usage Information

We collect and use your personal information to operate our website, deliver the products and/or services you have requested, and for marketing purposes. In some situations, we may process your personal information for more than one lawful reason depending on the specific purpose for which we are using your data. For example, if you complete an online form to request a product demo, we may collect your information to provide the demo, but we may also maintain your information after your request is complete so that we can quickly and easily respond to any future questions you may have. As a result, our collection and processing of your personal information is based upon your consent, our need to respond to your request, our obligations under law, and/or our legitimate interest in conducting our business.

We do not sell, rent or lease our customer lists to third parties. We may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, to arrange for deliveries, or for marketing purposes. We may also use your personally identifiable data to inform you of other products or services available from us or our affiliates. All such third parties are prohibited from using your personal information except to provide these services to us, and they are required to maintain the confidentiality of your information. We will use your information to respond to you regarding the reason you contacted us, or future marketing. Unless you ask us not to, we may contact you via phone or email in the future to tell you about specials, new products or services, or changes to this Privacy Policy.

In addition, we collect certain navigational information about where you go on our website, in order to determine what services or products are the most popular. We may use this data to deliver customized content and advertising within our website to customers whose behavior indicates that they are interested in a particular subject area. Such information is gathered by us in the aggregate and will not be associated with a specific individual except in connection with specific services and operations such as attribution reporting and maintenance of customer accounts.

Use of Cookies

Our website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

Cookies can be used for various purposes such as to detect whether your device has accessed a particular online service before. We use cookies on pages to make your visit to our website more enjoyable and to enable the use of certain functions.

Google Analytics

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to analyze how Users make use of our Site for the purpose of evaluating your use of the Site, to generate reports on your activities on our Site, and to provide other services relating to internet activity and usage. Google will not associate your personal IP address as part of Google Analytics with any other data held by Google. According to its own information, Google does not gather any personal information within this process. You can disable the Google functions by adjusting the settings accordingly at www.google.com/setting/ads. For more information, please visit: https://policies.google.com/privacy?hl=en-US.

You may also object to the use of cookies for measuring range and advertising purposes via the Network Advertising Initiative's deactivation page (http://optout.networkadvertising.org/) and additionally via the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

Purposes for Which We Use Your Personal Information.

We may use your personal information to operate our Site, deliver the requested products and/or services, or for marketing purposes in a manner that is consistent with this Privacy Policy and the context of our relationship with you. In accordance with data protection law, we will only use your personal information if we have a proper reason for doing so. Proper reasons may include (i) compliance with legal or regulatory obligations, (ii) to perform under a contract with you or to take action requested by you in anticipation of entering into a contract, (iii) for our legitimate interests or the legitimate interests of a third party, or (iv) where you have given consent. A legitimate interest is when we have a commercial or business reason to use your personal information, to the extent your rights or interests do not override our legitimate interest.

We will use your personal information collected through the Site for the following purposes:

  • To respond to your requests and to provide you with information or services;
  • To respond to your inquiries and contact you about changes to the Site and/or the services;
  • To send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving;
  • To send you information we think you may find useful or that you have requested from us;
  • Send you information about products or services about which you've requested information;
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
  • For any other purposes disclosed at the time the information is collected or to which you consent; and
  • As otherwise specifically described in this Privacy Policy.

Disclosure of Personal Information to Third Parties.

We do not disclose your personal information to third parties for their direct marketing purposes.

We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include personal information.

In the event of an acquisition, we expect that the information that we have collected, including personal information, would be transferred along with our other business assets.

We may disclose your personal information to government authorities and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas. We may also disclose your personal information when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other Users of this Site, or anyone else that could be harmed by such activities.

How We Protect Your Information.

We take commercially reasonable steps to protect the personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. We take precautions to protect your information. Only employees who need the information to perform a specific job function are granted access to personal information. The computers and servers in which we store personal information are kept in a secure environment.

Children Under Thirteen.

We believe that it is especially important to protect children's privacy online. We do not knowingly collect personal information from children under the age of thirteen, regardless of the source. Nor do we share with any third party for any purpose whatsoever any personal information from website visitors younger than thirteen years of age. If you are under the age of thirteen, you must ask your parent or guardian for permission to use our Site. If you believe that a User under the age of 13 may have provided us personal information in violation of this Privacy Policy, please contact us at privacy@lacuna-strategies.com.

Opt-Out & Unsubscribe.

We respect your privacy and give you an opportunity to opt-out of receiving communications or having your information shared with third-parties you've indicated you'd like to receive information from. Users may opt-out of receiving any or all communications from us by sending an e-mail to privacy@lacuna-strategies.com. This includes changing or correcting any of your personal information, requesting that we delete any or all of your personal information, or expressing concern regarding how we use your data.

Links

The Site may contain content, services, advertising and other materials that link to websites operated by third parties. We have no control over those other websites, and this Privacy Policy does not apply to them. Please refer to the privacy policies of those websites for more information on how the operators of those sites collect and use your personal information.

Do Not Track.

We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

Important Notice to Users Outside the U.S.

The Site and the services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Site or the services, you consent to this transfer.

Your Rights

You may have certain rights relating to your personal information, subject to local data protection laws. Depending on applicable state or federal laws these rights may include the right to:

  • Access your personal information held by us;
  • Learn more about how we process your personal information;
  • Have us correct inaccurate personal information;
  • Erase or delete your personal information;
  • Restrict our processing of your personal information;
  • Receive the personal information you provided to us;
  • Transfer your personal information to another controller, to the extent possible;
  • Object to any processing of your personal information;
  • Opt out of certain disclosures of your personal information to third parties;
  • If you're under the age of 16, or such other applicable age of consent for privacy purposes in relevant individual jurisdictions, opt in to certain disclosures of your personal information to third parties;
  • Not be discriminated against for exercising your rights described in this Section;
  • Not be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you;and
  • Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

Where we process your personal information for direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection.

To exercise your rights, please contact us by using the information in the “How to Contact Us” Section below. Your personal information may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.

Changes to This Privacy Policy.

This Privacy Policy is effective as of the date stated at the bottom of this Privacy Policy. We may change this Privacy Policy from time to time. These changes will be made when appropriate, and in a timely manner. We encourage you to examine our Privacy Policy from time to time to ensure you are aware of any changes we may have made. Your continued use of our Site following an update to the Privacy Policy indicates your agreement to the then current Privacy Policy.

How to Contact Us.

If you have questions about this Privacy Policy, please e-mail us at privacy@lacuna-strategies.com. Please include “PRIVACY POLICY” in the subject line.

Additional Disclosures for California Residents.

Under the California Consumer Privacy Act (CCPA) we are required to disclose whether we sell personal information. We do not sell personal information, but we may share personal information with third parties or allow them to collect personal information from our Site or services if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you direct us to disclose your personal information to third parties.

California law grants you the right to know:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting personal information;
  • The categories of third parties with whom we share 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.

In connection with any personal information, we may disclose to a third party for a business purpose, you have the right to know the categories of personal information that we disclosed about you for a business purpose.

Under CCPA and certain other privacy and data protection laws, as applicable, you have the right to opt-out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from disclosing your personal information, unless you subsequently provide express authorization for the disclosure of your personal information. To opt-out of the disclosure of your personal information, please send you request to privacy@lacuna-strategies.com.

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 to delete your personal information from their records.
  • Please note that we may not delete your personal information if it is necessary to:
    • Complete the transaction for which the personal information was collected, 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;
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
    • 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;
    • 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.

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things deny you goods or services for exercising these rights.

For more information or to exercise your rights, please contact us by using the information in the “How to Contact Us” Section above.

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