Privacy Policy and GDPR Notice

Alambic Investment Management (“Alambic”) operates a website at http://www.alambicim.com a (the “Service”). This page informs you of our policies regarding the collection, use and disclosure of your Personal Information (as described below) when you use our Service.

We will not use or share your information with anyone, except as described in this Policy.

We use your Personal Information (as defined below) only to provide and improve the Service, our responsiveness to our clients and investors, and to ensure our compliance with applicable securities laws.

By using the Service, you agree to the collection and use of information in accordance with this policy.

Please see below “GDPR Notice” for important information for those resident in or citizens of the European Economic Area.

​

Information Collection and Use
Personal Information

When you access our website pages or contact us, especially any password protected areas of the website, you may provide us with certain Personal Information, which means information that is collected from your interaction with the Site and identifies you as an individual (“Personal Information”).

Personal Information for non-password protected areas of the website may include, but is not limited to, your IP address, website usage information, and other technical data such as browser type, unique device identifiers, language preference, referring site and the data and time of access, operating system, and mobile network information, as well as approximate location data (from IP address).

For password protected areas of the website, Personal Information may include, but is not limited to, email address, name, phone number, postal address, and other information, such as accredited and/or qualified investor status, comments, suggestions, and requests.  We collect and use this information for internal use only.

​

Non-Personal Information

We and/or our third-party technology vendors may collect or process certain types of non-personal information (i.e., information that does not identify you as an individual).

For example, like many site operators, we collect information that your browser sends whenever you visit our Site or fill out “requests for information” (“Log Data”).  This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, device information, location information, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

As described more fully below under the heading “Service Providers,” we may also use third-party services, such as Google Analytics, that collect, monitor and analyze this type of information to improve our Service’s functionality.  These providers have their own privacy policies addressing how they use such information.

​

Uses of Personal and Non-Personal Information

We use both Personal Information and Non-Personal information to improve the Service we provide, including, but not limited to, the content and other material we display on the website; to conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and improve and report on the performance of our Service; to ensure our compliance with applicable securities laws.  For example, we will use such information to analyze visitors to our website, and, for the password protected areas of the Service, to verify accredited investor versus non-accredited investor attempts at registration, and to determine any violations of law, or problems with registration or access, etc.

Alambic reserves the right to disclose information that does not directly identify you.  For example, we may collect aggregated or anonymized data, to improve our website’s service.  Personal Information is shared with staff, and consultants only on a confidential and need-to-know basis.

​

Cookies.

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes such as site visitation. We use cookies on the Websites, and we collect unique identifiers from your mobile device when you use our Website.  These may be session cookies that expire when you close your browser and/or persistent cookies that stay on your computer until you delete them.  If you choose to disable any non-essential cookies, some areas of our Website may not work properly.  We may also collect your device type, browser type, operating system, IP address, domain name, and time and date stamp for your visit.

Information about cookies is available at http://aboutcookies.org.  Many web browsers allow you to manage your preferences.  You can set your browser to refuse cookies or delete certain cookies.  You may be able to manage other technologies in the same way that you manage cookies using your browser’s preferences.  On your mobile device, you may also have a “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.  The Help feature on most browsers provides information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.

​

Sharing Personal Data: Service Providers.

We do not sell or rent Personal Data to marketers or third parties.  Generally, we will share Personal Data collected with Third Party Providers only in limited circumstances, including:  We may contract with other third-party service providers to facilitate our Service, to provide the Service on our behalf, to perform related services and to assist us in analyzing how our Service is used.  These third parties have access to your Personal Information for the sole purpose of performing specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.  We will also share Personal Data if we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process, or to enforce our TOS.

​

Do Not Track Disclosure

Do Not Track (“DNT”) is a preference you can set in your web browser to inform websites that you do not want to be tracked.  We do not support DNT on the Service.

​

Communications

For registered users only, we may use your Personal Information to contact you with newsletters, marketing or promotional materials that may be of interest to you.  This is only if you register as a user on the password protected portions of our websites.

​

Compliance with Laws

We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.

​

Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure.  We strive to use commercially acceptable means to protect your Personal Information, including maintaining appropriate physical and technical protections and using third party service providers who maintain similar standards.  However, we cannot guarantee the absolute security of your Personal Information.

​

International Transfer

Your information, including Personal 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.  If you are located outside United States and choose to provide information to us, please note that we transfer the information, including Personal Information, to United States and process it there.  Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

​

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site.  We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.  We strongly advise you to review the Privacy Policy of every site you visit.

​

Children’s Privacy

Only persons age 18 or older have permission to access our Service.  Our Service does not address anyone under the age of 18 (“Children”).  We do not knowingly collect personally identifiable information from children under 18.  If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us.  If we become aware that we have collected Personal Information from children under age 18 without verification of parental consent, we will take steps to remove that information from our servers.

​

Changes

The Privacy Policy is effective as of October 3, 2018, and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.  We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically.

Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.  If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

​

Retention period  

We reserve the right to retain your personal information as permitted or required by law or under your consent.  We will store your Personal Data (i) only for as long as is required to fulfil the purposes set out below or (ii) until you object to our use of your Personal Data (where we have a legitimate interest in using your Personal Data), or (iii) until you withdraw your consent (where you consented to Alambic using your Personal Data).  Some Personal Data are required to be retained for a period of seven years or more to satisfy legal requirements, such as recordkeeping, securities law, and tax and credit reporting requirements, as well as for purposes of fraud prevention, audit and data integrity.  In addition, Alambic reserves the right to retain, as well as to use and disclose as permitted pursuant to this Privacy Policy, your personal information for such period of time as reasonably needed by us to facilitate activities and transactions for the operation of the Service and related services and to improve User experiences.  We reserve the right to retain information that does not directly identify you, for example, aggregated or anonymous zed data.

​

GDPR Notice

On May 25, 2018, a European Union data privacy law called the “General Data Protection Regulation” or “GDPR” became effective.  The GDPR regulates how “Personal Information” from individuals in the EU can be “processed” and provides data privacy protections.  While we do not believe we collect information subject to the GDPR, we are providing the below additional information to those in the European Economic Area (“EEA”) and some other non-US countries.

We will consider EEA-located persons who have provided us with Personal Information as having the right to (i) request access to and rectification or erasure of that person’s Personal Information, (ii) obtain restriction of processing or object to processing of that Personal Information, and (iii) data portability.  If an individual in an EAA country who has provided us with Personal Information wishes to exercise any of these rights, he or she should contact Alambic using the contact information below.

By accessing certain parts of this website and signing up to receive our newsletters or other information, all individuals, including those in EEA countries, consent to us collecting and storing information necessary for us to continue to provide services.

Alambic will retain Personal Information for as long as we are required to perform our obligations under applicable law and regulations (including the U.S. Investment Advisers Act).  This may extend for several years in certain instances.

As noted, Alambic is legally required to keep certain Personal Information in the United States our service providers must also process and store certain types of Personal Information, especially for those who invest with us, outside the EEA.  Persons who do not wish their Personal Information to be transferred, processed, or stored outside the EEA should not seek information about Alambic or attempt to invest with Alambic.

Persons located in EEA countries have the right to lodge a complaint about the processing of their Personal Information with their local data protection authorities.

For the purposes of European data protection laws, the Fund and the Investment Manager are the “data controllers” of Personal Information regarding Shareholders.

​

Contact Us

If you have any questions about this Privacy Policy, please contact us at info@alambicim.com. You can also send questions or comments to:

Alambic Investment Management, LP:

266 Beach Road

Belvedere, California 94920 USA

415-495-4900