PRIVACY
POLICY
Last Updated: June 2023
This Privacy Policy
describes how Valiant Capital Management, L.P., Valiant Peregrine Management,
L.L.C. and their affiliates (collectively, “Valiant,” “we,” “us” or “our”)
collect, use, store and disclose personal information we obtain from certain
sources indicated below and rights applicable to California residents with
respect to personal information.
This Privacy Policy describes how, while a “business” under the California Consumer Privacy Act (“CCPA”), we (including the
entities we control within our business) otherwise collect, use and disclose
personal information about California residents who engage with us in a business-to-business capacity, as vendors,
prospective business customers or office visitors, or as individuals whose
personal information is otherwise stored or processed in our contact management
systems. It also describes how we have
collected, used, stored and disclosed such information for the past 12 months.
This
Privacy Policy does not apply to certain information that we or our
service providers collect, use and disclose with respect to individuals who
engage with us for investment services.
They will receive our separate Privacy Notice
governed by federal law at the time they seek such services.
Personal Information We Collect
We
may collect and maintain personal information in a number of ways, including
when you visit our office and when you contact us by email or telephone.
· Information Collected
Through Technology.
We do not collect any personal information through this Site.
· Audio and Visual Information. We maintain
various security measures to protect our premises,
including video cameras.
We also collect
identifying information, sensitive personal information (such as social
security, driver’s license and passport numbers and bank account information)
and commercial information as needed to effect investment transactions and provide
investment services, as
described in our Privacy Notice provided to those who engage with us for
investment services.
Sources of Personal Information
Much of the information referenced above will have been provided by you, but some may come
from other sources, such as your representatives or a mutual referral contact.
Use
of Your Personal Information.
We use personal information under
this Privacy Policy, and consistent with our separate Privacy Notice for those
who seek our investment services, to operate our business. For example, we may
use personal information:
If you do not provide requested
information in connection with our operations, we may be unable in some
circumstances to comply with our obligations or pursue a relationship with you,
and we will tell you about the implications of that decision.
Information We Disclose
It is our policy to not disclose your personal information, except we
may disclose your personal information as permitted by law or otherwise
described in this Privacy Policy and our separate Privacy Notice for those who seek our investment
services, to the following types of parties:
We
do not sell personal information and we do not share personal information for
cross-context behavioral advertising.
Children
Our services are not directed to, and we
do not knowingly collect or share personal information from anyone under the
age of 16.
Do Not Track Signals.
Our Site is not
designed to respond to “do not track” signals received from browsers.
Global Privacy Control
Our Site does not send any tracking
technologies or cookies and, therefore, does not use Global Privacy Control.
Data Retention
Except as otherwise permitted or
required by applicable law or regulation, we will only retain your personal
information for as long as necessary to fulfill the purposes we collected it
for, as required to satisfy any legal, accounting, or reporting obligations, or
as necessary to resolve disputes. To determine the appropriate retention period
for personal information, we consider applicable legal requirements, the
amount, nature, and sensitivity of the personal information, the potential risk
of harm from unauthorized use or disclosure of your personal information, the
purposes for which we process your personal information, and whether we can
achieve those purposes through other means. We specify
the retention periods for our records, including your personal information, in
our policies and procedures.
Your California
Privacy Rights
If you are a California resident,
you may have certain rights if your personal information is protected by
applicable California law, including the following rights (subject to certain
exceptions and limitations):
·
Right to Know. You have the right to request (a) the categories and specific pieces
of personal information we collect and disclose; (b) the categories of sources
from which we have collected your personal information; (c) the categories of
third parties to whom your personal information was shared or disclosed for a
business purpose; and (d) the business purposes for such collection and
disclosure of your personal information.
·
Right to Request. You have the right to request a list of the personal information (if
any) disclosed to third parties for direct marketing purposes in the prior 12
months.
·
Right to Delete. You have the right to access and then delete your personal
information that we have collected from you or maintained about you (except to
the extent we are required by law to retain any record).
·
Right to Correct
Inaccurate Information. If we maintain
inaccurate information about you, you have the right to request correction of
that inaccurate personal information, taking into account the nature of the
personal information and the purposes of the personal information processing.
We will use commercially reasonable efforts to correct this information.
·
Right to Limit. We do not use or
disclose sensitive personal information for purposes other than those permitted
by CCPA regulations section 7027(m).
·
Right to Opt-Out. You have the right to opt-out of the sale or sharing of personal
information for cross-context behavioral advertising. However, we do not sell
or share any personal information for cross-context behavioral advertising.
California
residents also have the right to not be discriminated against for exercising
any of the rights described above.
If
you are a California resident and wish to exercise these rights, please contact
us at 888-861-5301 or email at ir@valiantcapital.com. There are circumstances where we are not
required to comply with consumer requests and we will let you know if one of
those situations is applicable.
We will
confirm receipt of your request within 10 business days. If you do not receive
confirmation within the 10-day timeframe, please contact ir@valiantcapital.com.
To help protect your privacy and
maintain security, we will verify your identity before granting access to your
personal information or complying with your request. If you request to access
or delete your personal information, we will verify your identity by comparing
information we have on file against information you may provide us. If you
designate an authorized agent to make a request to access or delete your
personal information on your behalf, we may require you to (1) provide the
authorized agent written permission to do so, and (2) verify your own identity
directly with us (as described above).
We endeavor to
substantively respond to a verifiable consumer request within 45 days of its
receipt. If we require more time (up to another 45 days), we will inform you of
the reason and extension period
in writing.
Contact Details
Please contact us
if you are disabled and need a copy of this Privacy Notice prepared for you in
a manner that is accessible. Any such request may be made via phone at 888-861-5301
or via email at ir@valiantcapital.com.
Employees, contractors and job applicants, please find our CCPA Notice for Employees and Contractors CCPA Notice for Employees and Contractors