Privacy Policy
At Master Capital Partners, data protection and data security are very important to us when using our website and services. Therefore, we would like to inform you here which of your Personal Information we collect when you visit our website, and for which purposes it is used.
Background:
This privacy policy describes our privacy practices in simple language and keeps legal and technical jargon to a minimum to ensure that you understand the information. However, in order to achieve this goal, we would like to explain the following terms.
a) What is Personal Information? Personal data is any information that relates to an identified or identifiable living individual. Various pieces of information that, taken together, can lead to the identification of a specific individual are also Personal Information.
b) What is processing? "Processing" means and includes virtually any handling of data.
c) What law applies? As a rule, we use your Personal Information only in accordance with applicable data protection laws, in particular the New Jersey Privacy Law (“NJPL”) and the Personal Information Protection Act (“PIPA”).
d) Who is responsible for data processing? The data controller within the meaning of the NJPL and the PIPA is Master Capital Partners LLC, ("Master Capital Partners", "we", "us" or "our"). If you have any questions or would like to exercise your rights under the NJPL or the PIPA, please contact Mgmt@mastercapitalpartners.com; or call our New Jersey Office at 862-267-7998, or our Maryland Office at 301-4334-4194.
General principles:
a) Purpose and legal basis of processing
According to the NJPL and the PIPA, we should have both a purpose and a legal basis for processing Personal Information. The purposes are:
the provision of the website and its functions and content,
responding to contact requests and communicating with our customers and visitors,
the provision of our services; and
Security measures.
Of course, we can only do this if we have at least one of the following legal bases or, in other words, a lawful reason to do so. Unless specifically described below, we generally link the above purposes to one of the following:
Consent,
To provide our services and fulfill contractual obligations,
to comply with our legal obligations, and
To protect our legitimate interests.
b) Categories of data subjects and types of data processed
In the course of using our website and services, we process the following types of data from visitors and users:
Inventory Data,
contact data,
content data,
contract data,
usage data and
Metadata/Communication Data.
c) Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content or contact requests that you send to us. In addition, we have taken numerous security measures ("technical and organizational measures"), such as encryption or "need to know" access, to ensure the most complete protection of Personal Information processed through our website.
Nevertheless, Internet-based data transmissions can always have security vulnerabilities, so that absolute protection cannot be guaranteed. And databases or records containing Personal Information may be damaged accidentally or by unlawful intrusion. As soon as we learn of a data breach, we will notify all affected individuals whose personal information may have been compromised as soon as possible after becoming aware of the breach.
d) Retention and Storage
We will retain your Personal Information for as long as is necessary in connection with the purposes described in this privacy policy and in accordance with the legal retention periods in New Jersey and Maryland and other applicable laws, depending on the document and legal regulation.
e) Minors
We do not request Personal Information from minors and children and do not knowingly collect such data or disclose it to third parties.
f) Automated decision making
Automated decision making, including profiling, does not take place.
g) No sale
We do not sell your Personal Information.
h) Special categories of data
We do not process special category data unless it is required for a specific service and consent has been given.
Data that we collect automatically
a) Log data
Each time you visit our website, our system automatically collects the following data from the visiting device and stores it in a so-called log file: (i) name of the file accessed, (ii) date and time of the visit, (iii) amount of data transferred, (iv) notification of successful retrieval, type of browser and version used, (v) IP address (identification of the user's device), (vi) operating system of the visiting device, (vii) Internet service provider of the visiting device, (viii) website from which you access our website, and (ix) which pages of our website you access. The legal basis for this processing is our legitimate interest.
b) Content Delivery Network
We use a content delivery network (CDN) to distribute our online content. Our CDN is a network of regionally distributed servers from our technical service providers that are connected via the Internet. When you visit our website, your device's browser transmits information to these service providers, which is collected in corresponding server log files. The server log files are usually anonymized and then transmitted without personal reference. The server log files contain in particular
i) information about the browser and operating system used,
ii) the previously visited pages (so-called referral URL),
iii) the IP address of the device used,
iv) the name of the Internet provider, and
v) the date, time of all page views including the amount of data transferred. The legal basis for the processing is our legitimate interest.
c) Hosting
To provide our website, we use the services of HighLevel, LLC., which processes the data listed below and all data to be processed in connection with the operation of this website (log file when visiting the website) on our behalf. The legal basis is our legitimate interest.
Data we collect directly
We may ask you for Personal Information when you:
use our website,
request services, support or information,
participate in marketing activities online or otherwise,
interact with us on third-party social networks (subject to those third parties' terms of use and privacy policies), or
Contacting Us.
The categories of personal information we collect include your name, email address, phone number, and IP addresses. We may also collect information about your business, such as your company name and contact information, and demographic information such as your interests and preferences.
a) Contact requests
When you submit a contact request on our website, in addition to your request, you may also provide your name, email address, phone number, and the type of service you are requesting.
b) When using our services
We process the data of our service users in order to be able to provide our contractual services as well as to ensure the security of our services and to develop them further. This includes, in particular, our support, correspondence with you, invoicing and the fulfillment of our accounting and tax obligations. Accordingly, the data is processed on the basis of the fulfillment of our contractual obligations as well as to comply with our legal obligations.
Some of the data you voluntarily provide to us may be considered non-Personal Information and/or "special" or "sensitive" data in certain countries, such as your racial or ethnic origin, sexual orientation and religious beliefs. By providing this data, you consent to us processing it.
If Personal Information relates to a third party, you represent that the Personal Information is current, complete and accurate, and that you have obtained the third party's prior consent to collect, use and disclose its Personal Information for the stated purposes. You agree to promptly provide us with written evidence of such consent upon request.
Unless otherwise stated, the purposes of processing are contract performance and service, contact requests and communication, office and organizational operation, administration and response to requests, evaluation of visit activities.
The legal basis for data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations and your consent. You can withdraw your consent and ask us to stop using and/or sharing your personal and special category data by submitting your request to us.
Data from third party sources
We may receive data about you from third-party sources, such as our marketing partners, social networks and other third parties. We may use this data to better analyze your user behavior so that we can provide you with relevant marketing information and services and to prevent and combat fraud. The legal basis for data processing is our legitimate interest.
Disclosure, sharing and transfer
a) Collaboration with Processors and Third Parties.
If we disclose, transfer or otherwise grant access to data to other persons and companies (processors or third parties) in the course of our processing, this will only be done on the basis of a legal permission (e.g. if a transfer of data to third parties, such as payment service providers, is necessary for the performance of the contract), you have consented, a legal obligation requires it or on the basis of our legitimate interests (e.g. when using intermediaries, web hosts, etc.). When we engage third parties to process data on the basis of a so-called "processing contract".
b) Marketing
If you have also given us your consent to process your Personal Information for marketing and promotional purposes, we are entitled to contact you for these purposes via the communication channels for which you have given your consent. You may withdraw your consent and request us to stop using and/or disclosing your Personal Information and special category data by submitting your request to us.
c) International transfer
We process data in the course of operating our website. We do not normally transfer Personal Information to countries outside the USA. However, if we do, we ensure that the processing of your Personal Information is governed by processing agreements that include standard contractual clauses to ensure a high level of data protection.
d) Disclosure
We will not disclose or otherwise disseminate your Personal Information to third parties unless it is a) necessary for the provision of our services, b) you have consented to the disclosure, c) or we are required to do so by law, e.g. pursuant to a court order or if we need to assist in a criminal or legal investigation or other legal proceeding; if Master Capital Partners (or any part of Master Capital Partners) is sold to or merged with another company; or in the case of a domestic or foreign proceeding or to protect our legitimate interests.
Your rights and privileges
a) Data protection rights You may exercise the following rights:
Right to information
Right to rectification
Right to object to processing
Right to deletion
Right to data portability
Right to object
Right to withdraw consent
Right not to be subject to a decision based solely on automated processing.
If you have any questions about the type of Personal Information we hold about you, or if you wish to request erasure or rectification of Personal Information held about you, or exercise any of your other rights as a data subject, please contact us.
b) Updating your data
If you believe that the data we hold about you is inaccurate or we are no longer entitled to use it and you wish to request its rectification or erasure, or object to its processing, please contact us.
c) Withdrawal of your consent
You may withdraw the consent you have given at any time by contacting us. The legality of the data processing carried out until the withdrawal remains unaffected by the withdrawal.
d) Request for information
If you would like to make a request for information about your data, you can inform us in writing. We will respond to requests for information and correction as soon as possible. If we are unable to respond to your request within thirty (30) days of receiving your request, we will notify you in writing within thirty (30) days. If we are unable to respond to your request, we will tell you why (unless we are not required to do so under the relevant legal provisions set out above).
e) COPPA (Children Online Privacy Protection Act)
When it comes to the collection of Personal Information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.
f) CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with CANSPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us and we will promptly remove you from ALL correspondence.
g) Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, our website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy.
Changes and Updates
Because changes in legislation or in our internal corporate procedures may require us to amend this Privacy Policy from time to time, we encourage you to review this Privacy Policy periodically.
Concerns and Contact
If you have concerns about a possible breach of your privacy or misuse of your personal information by us, or if you have other questions or comments, you can contact us.
This privacy policy was last updated on Friday, April 14, 2023.