Introduction

Website Owner. Sustainable Capital Advisors, LLC (“SCA”, “the Company”, “we”, “us”, or “Our”) is the owner of this website (“SCA Website”).

We can be contacted:

• by mail at 200 Massachusetts Ave NW Floor 7, Washington, DC 20001
• by phone at +1 844.787.8227
• by email at info@sustainablecap.com or
• by visiting this page of the SCA Website: http://www.sustainablecap.com/pages/contact-us.

This online privacy notice (“Privacy Policy”) discloses our information practices for this SCA Website, including what type of personal identifiable information may be requested and collected, how the information is used, and with whom the information is shared.

SCA respects your privacy and is committed to protecting it through compliance with this Privacy Policy.

Please note that other SCA-affiliated websites may be governed by privacy notices containing different information practices applicable to those sites.

This Privacy Policy applies to information we collect:

• on this SCA Website, and
• in email or other electronic messages between you and this SCA Website.

It does not apply to information collected by:

• us offline or through other means, including on any other website operated by SCA or any third party (including our affiliates and subsidiaries), or
• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on this SCA Website.

Links to Other Websites. Our SCA Website may contain links to other websites.  SCA is not responsible for the privacy practices or the content of those other websites.

Terms of Use. We encourage you to ready this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you are not in agreement with our policies and practices, you may opt not to use the SCA Website.  By accessing or using the SCA Website, you agree to this Privacy Policy, which may be updated from time to time at our discretion.  Your continued use of this SCA Website after we make changes indicates your acceptance of such changes.  So, please check our Privacy Policy periodically for updates.  Any dispute over privacy between you and SCA is subject to the provisions of this Privacy Policy and to SCA’s Terms and Conditions, which are hereby incorporated herein and which can be read at Terms of Use | scap.com.

Website Visits. SCA collects certain information from SCA Website visitors. This includes, but is not limited to, the home server domain name, email address, type of computer and web browser, what pages visitor accessed, and limited information about search requests. This information is used to solve technical problems and to calculate overall usage statistics.

Website Interaction. You may opt to disclose your personal information to SCA regarding an inquiry about our services, media, engagements, careers, general information, or partnering with SCA.  To contact us with such an inquiry, you may enter your data by visiting the http://www.sustainablecap.com/pages/contact-us page of the SCA Website, where Our website will collect submitted data such as your name, mailing address, email address, as well as any documents you may choose to upload in connection with your inquiry. It is SCA’s intent to inform you before SCA collects personal information, such as a user’s name and/or address on the Internet. If you tell us that you do not wish to have this information used as a basis for further contact with you, SCA will respect your wishes.

Information from Children. SCA does not knowingly collect personal information from minors under the age of 16, nor does SCA sell its products or services for purchase by children, and will not knowingly collect or post information from a child under the age of 16 without the involvement of a parent or guardian.  Please note, certain third party websites to which we provide links may collect personal information from minors. These third party sites have their own terms of use and privacy policies.  We encourage parents and legal guardians to monitor their minor children’s internet usage and instruct their children not to provide information to websites without adult permission.  SCA does not knowingly use personally identifying information collected from children for marketing or promotional purposes, and does not disclose such information to any third party for any purpose whatsoever, unless we receive affirmative authorization (the “right to opt-in”) from the user who is between 13 and 16 years of age, or the parent or legal guardian of a user who is less than 13 years of age.  To exercise the right to opt-out, you (or your authorized representative) may submit a request by contacting us at info@sustainablecap.com or at http://www.sustainablecap.com/pages/contact-us.

Information That We Collect About You & How We Collect It

We collect several types of information from and about users of our SCA Website, including

• certain personal identifying information, which may include: name, postal address, email address, or any other identified by which you may be contacted online or offline (“personal information”, or “personal data”);
• information that is about you, but individually does not identify you; and/or
• information about your internet connection, the equipment you use to access our SCA Website, and usage details.

We collect this information directly from you when you provide it to us.

We also collect this information automatically, as you use our SCA Website.  Information collected automatically may include usage details, IP addresses, and information collected through cookies, or other tracking technologies.  As you navigate through the SCA Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• details about your visit to the SCA Website, including but not limited to traffic data, logs, and other communication data and resources that you access and use on the SCA Website, and
• information about your computer and internet connection, including but not limited to your IP address, operating system, and browser type.

The technologies we use for our automatic data collection may include:

Tracking Technologies and Cookies.  We use cookies and similar tracking technologies to track activity on our SCA Website and store certain non-personal information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze the SCA Website. The technologies we use may include:

• Cookies or Browser Cookies. SCA, or its third-party vendors, collects non-identifiable and personal information through the use of various technologies, including cookies. A “cookie” is an alphanumeric identifier that a website can transfer to user’s hard drive through the user’s browser. The cookie is then stored user’s computer as an anonymous tag that identifies the customer’s computer, but not the individual user. Cookies may be sent by SCA or its third-party vendors. As a user, you can set your browser to notify you before a cookie is received, giving an opportunity to decide whether to accept the cookie. You may also set your browser to turn off cookies; however, some websites, including the SCA Website, may not then work properly.
• Flash Cookies. Certain features of the SCA Website may use local stored objects (or flash cookies) to collect and store information about your preferences or your activity on the SCA Website. Flash cookies are not managed by the same browser settings as those used for browser cookies.
• Web Beacons. SCA may also use Web beacon or other technologies to better tailor the SCA website to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the website, a non-identifiable notice of that visit is generated which may be processed by SCA or by its suppliers. Web beacons usually work in conjunction with cookies. If a user does not want cookie information to be associated with the user’s visits to these pages, user can set its browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal electronic device when you go offline, while Session Cookies are deleted as soon as you close your web browser. We use both Session and Persistent Cookies on the SCA Website.

Collection of Non-Identifiable Information. SCA may collect non-identifiable information from user visits to the SCA Website in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on the SCA Website; website and system administration; user analysis; and business decision making. Such information is sometimes known as “clickstream data”.  SCA or its contractors may use this data to analyze trends and statistics.

Use of Your Personal Data

Limited Uses Identified. Without your prior consent, SCA will not use your personal identifiable information for any purpose other than that for which it is submitted.  SCA uses personal identifiable information to reply to inquiries, handle complaints, provide operational notices and in program recordkeeping. SCA may also process billing and business requests related to SCA Website participation.

Marketing Uses. Unless you opt-out, SCA reserves the right to provide customer with information about SCA’s website,  SCA’s products and services, and related information in which you have indicated an interest.

Stored Information Uses. SCA stores and retains the information entered on the SCA Website. Stored information is used by SCA and/or SCA agents to support customer interaction with the SCA Website; to deliver services; and/or to contact you again about other SCA services.

Online Advertising. Some companies that help SCA deliver interactive online advertising, such as banner ads, may collect and use information about SCA Website visitors to help SCA better understand the types of advertising or promotions that are most appealing to visitors.  After it is collected the information is aggregated so it is not identifiable to a specific individual.

Retention of Your Personal Data

SCA will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

In addition, SCA will retain usage data for internal analysis purposes.  Usage data refers to data collected automatically.  Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our SCA Website, or we are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Information

Your information, including personal information, is processed at SCA’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

SCA will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and personal information.

Disclosure of the Information

Within SCA. SCA is an organization with legal entities, business processes, management structures, and technical systems that may cross borders.  SCA may share your personal information within its organization, and may transfer the information to countries in the world where SCA conducts business. Some countries may provide less legal protection for customer personal information.

Mergers and Acquisitions. Circumstances may arise where for business reasons, SCA decides to sell, buy, merge, or otherwise reorganize its businesses in the United States or some other country. Such a transaction may involve the disclosure of personal identifying information to prospective or actual purchasers, and/or receiving such information from sellers. It is SCA’s practice to seek appropriate protection for information in these types of transactions.

Agents. SCA employs or engages other companies and individuals to perform business functions on behalf of SCA. These persons are provided with personal identifying information required to perform their functions, but are prohibited by contract from using the information for other purposes. These persons engage in a variety of functions which include, but are not limited to, fulfilling orders, delivering services, removing repetitive information from customer and user lists, analyzing data, providing marketing assistance, processing payments, and providing customer services.

Affiliated Businesses. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.  Our affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Marketing Analysis by Third Parties. SCA reserves the right to disclose to third parties personal information about customers for marketing analysis; however, any information disclosed will be in the form of aggregate data that does not describe or identify an individual customer.

Disclosure to Governmental Authorities. Under certain circumstances, personal information may be subject to disclosure under a judicial or other government subpoenas, warrants or orders.

With Your Consent. We may disclose Your personal information for any other purpose with Your consent.

Access Rights to Data

Information Maintained by SCA. Upon your request, SCA will provide a reasonable description of your personally identifiable information that SCA maintains in its data bank. SCA can be contacted by email at info@sustainablecap.com, telephone +1 844.787.8227, or postal mail at 200 Massachusetts Ave NW Floor 7, Washington, DC 20001.

Corrections and Changes to Personal Information. Help SCA to keep your personal information accurate. If your personal information changes, or if you note an error upon review of information that SCA has on file, please promptly email SCA at info@sustainablecap.com and provide the new or correct information.

Your California Privacy Rights. Beginning on January 1, 2005, California Civil Code Section 1798.83 permits consumers (natural persons) of SCA who are California residents to request certain information regarding SCA’s disclosure of personal information for their direct marketing purposes. To make such a request, please write to info@sustainablecap.com. Within 30 calendar days of receiving such a verified request, SCA will provide a list of the categories of personal information disclosed to third parties for third party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. SCA reserves its right not to respond to requests submitted other than to the address specified in this paragraph.

California’s privacy laws require a company to provide notice to California users of their rights to receive information on to which entities their information was shared for marketing purposes.

Information Security

Commitment to Online Security. SCA employs physical, electronic, and managerial procedures to safeguard the security and integrity of personal information. Billing and payment data is encrypted whenever transmitted or received online. Personal information is accessible only by staff designated to handle online requests or complaints.

No Liability for Acts of Third Parties. SCA will exercise all reasonable efforts to safeguard the confidentiality of SCA Website user’s personal information. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made absolutely secure. Consequently, SCA shall not be liable for unauthorized disclosure of personal information due to no fault of SCA, including, but not limited to, errors in transmission and unauthorized acts of SCA staff and/or third parties.

Treatment of Personal Information Subject to GDPR

Personal Information/Data Protection and the GDPR. We are committed to protecting the privacy and security of your personal information.  We abide by applicable national and international data protection laws and regulations relevant to our business.

Legal Basis for Processing Personal Data under GDPR.  We may process Personal Data under the following conditions:

• Consent: You have given your consent for processing personal information for one or more specific purposes.
• Performance of a contract: Provision of personal information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing personal information is necessary for compliance with a legal obligation to which SCA is subject.
• Vital interests: Processing personal information is necessary in order to protect your vital interests or of another natural person.
• Public interests: Processing personal information is related to a task that is carried out in the public interest or in the exercise of official authority vested in SCA.
• Legitimate interests: Processing personal information is necessary for the purposes of the legitimate interests pursued by SCA.

In any case, SCA will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR.  SCA undertakes to respect the confidentiality of your personal information and to guarantee you can exercise your rights.  You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to your personal data. The right to request access to, update or delete the information we have on you.
• Request correction of the personal data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
• Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request erasure of your personal data. You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it.
• Request the transfer of your personal data. We will provide to you, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the SCA Website.

General Data Protection Regulation (GDPR) – European Representative.  Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Sustainable Capital Advisors has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

• by using EDPO’s online request form: https://edpo.com/gdpr-data-request
• by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Exercising of Your GDPR Data Protection Rights.  You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. If you have contacted us or our appointed EDPO and you remain dissatisfied, if you are in the European Economic Area (EEA), please address your concern directly to the UK Data Protection authority as follows:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF; Telephone: 0303 123 1113

Privacy Policy Changes and Opt-Out Rights

Changes to Privacy Policy. This Privacy Policy was last updated as of the date listed at the top of this statement.  SCA reserves the right to change or update its Privacy Policy statement at any time.  Please check our Privacy Policy periodically for changes or updates.

Opt-Out Right. You have the right at any time to cease permitting personal information to be collected, used, or disclosed by SCA and/or by any third parties with whom SCA has shared and/or transferred such personal information. Right of cancellation may be exercised by contacting SCA via email at  info@sustainablecap.com, telephone at +1 844.787.8227, or postal mail at 200 Massachusetts Ave NW Floor 7, Washington, DC 20001.  After processing the cancellation, SCA will delete your personal information from its data base.