PRIVACY POLICY

 

Newmarket Investment Management, LP, Newmarket Global Management, LP and their affiliate companies (“Newmarket,” “we,” “us” or “our”) recognizes the importance of protecting the privacy of our online visitors. It is our intent to balance our legitimate business interests in collecting and using information received from and about you with your reasonable expectations of privacy. The following privacy policy (“Privacy Policy”) explains how we collect and use personal data (as defined below) from and about you through your interactions with us, including your interactions with this website www.newmarketcapital.com (the “Site”). When you submit information to or through the Site, you consent to the collection and processing of your information as described in this Privacy Policy. By using the Site, you accept the terms of this Privacy Policy and our Terms of Use, and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy. Please review this Privacy Policy and our Terms of Use carefully.

 

Personal Information

Newmarket may collect personally identifiable information from you through the Site when you contact us through the Site’s contact links, including information such as your name, address, email address, phone number, or other information you choose to provide to us. This information is collected and stored electronically when you submit it to us.

 

How Information is Used

We may use the information we collect for any of the following purposes:

  • to fulfil your requests; and
  • to communicate with you.

 

Sharing of Information

  • With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, provide data analysis and research Site, to send out email updates about the Site or remove repetitive information from our user lists.
  • For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain.
  • Changes of Control. We may transfer information, including your personal information, in connection with a change of ownership or control by or of us or any affiliated entity (in each case whether in whole or in part).

Newmarket does not share your personal information with third parties for those third parties’ marketing purposes.

 

Security Used & Retention of Personal Information

Newmarket uses reasonable security measures designed to prevent unauthorized intrusion to the Site and the alteration, acquisition or misuse of personal information, however, we will not be responsible for loss, corruption or unauthorized acquisition or misuse of personal information that you provide through the Site that is stored by us, or for any damages resulting from such loss, corruption or unauthorized acquisition or misuse. Newmarket will retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

 

Links to External Websites

Our Site contains links to third party websites.  Any access to and use of such third party websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third party websites, and we are not responsible for the information practices of such third party websites.

 

Cookies and Similar Technologies  

Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties which receive data obtained from that website. Currently, our website does not use cookies or similar tracking technologies. Please note that some of our third party service providers may use cookies and similar technologies to support our operations. These entities may be collecting such information in order to provide services to or for us. You should be aware that these third party services providers may have different privacy policies and information security practices, as such, we encourage you to read the privacy statements provided by other websites before you provide personal data to them.

 

Do Not Track

Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

 

Children

Our services are not directed at individuals under the age of 18.  We do not knowingly solicit or collect personal data from children under the age of 18.  If we become aware that a child under 18 has provided us personal data, we will delete such data from our files. As a parent or guardian, if you become aware that your child has provided us with personal data, please contact us at the email address or telephone number provided at the end of this Privacy Policy and we will delete your child’s personal data within a reasonable time.

 

Contact Information; Questions and Changes in Information

If you have any questions regarding this Privacy Policy or to request changes to your personal data, please contact us at 215-701-9690 or email us at info@newmarketcapital.com.

 

Notification of Changes

Any changes to our Privacy Policy will be posted to this page so users are always aware of the information we collect and how we use it. Accordingly, please refer back to this Privacy Policy frequently as it may change.