Last Updated: December, 2021
By visiting the Site, you affirm your agreement to this Policy, which we may update from time to time. If we update our Policy, we will post the updated version here. Any such changes will be effective upon posting. We urge you to review this Policy each time you visit the Site. If you do not agree with any provision of this Policy, you should not visit or use the Site.
This Policy only addresses data that we collect when you use the Site. This Policy does not address our privacy practices when you interact with us in other ways, including in your capacity as an investor in investment vehicles managed or advised by Rubicon. We address these practices in separate notices to investors or potential investors. For clarity, while the “Site” includes a link to our private, password-restricted investor portal, it does not include that portal. ontp.com or write to us at Rubicon Technology Management L.L.C., 1470 Walnut Street, Suite 400, Boulder, CO 80302, Attn. Jon Franke.
What Information We Collect
Information You Provide
In general, the Site is for informational purposes only. The Site does not include any opportunities for you to input, upload or otherwise voluntarily provide personal data or other information, and the Site never requests that you provide any personal data. For example, the Site does not include any webforms, registration forms, signup pages or other such opportunities for visitors to volunteer information about themselves.
Information We Collect Automatically
- website traffic data,
- information about the location of the device accessing the Site,
- information about the type of device,
- operating system and browser you use to interact with the Site,
- when you access the Site,
- how many and which pages of the Site you viewed,
- what URL you clicked on, and what pages you visited before navigating to the Site,
- from what IP address you accessed webpages, page response times, download errors, length of visits to certain pages,
- page interaction information (such as scrolling, clicks, and mouse overs),
- and methods used to browse away from a page of the Site.
We use Google Analytics to collect some of this information. Google Analytics collects information such as how often users visit the Site, what pages users visit, and what other sites they visited prior to or after coming to the Site. More information on how Google Analytics uses your data can be found at www.google.com/policies/privacy/partners/.
One of the technologies we and our service providers use to collect this information is “cookies.” Cookies are small text files that may be placed on your browser when you visit the Site. Using the settings of your Internet browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Consult your browser’s HELP menu to learn your options with respect to cookies. If you choose to turn off cookies, you may not have access to many features that make your browsing of the Site smoother. You may at any time delete any cookies by using the relevant option of your Internet browser or by deleting the cookies on your hard drive. To find out more about cookies please visit: www.allaboutcookies.org or www.youronlinechoices.eu.
We use this information for our legitimate business interests, such as to carry out and improve our business. In particular, we use this information to:
- improve the Site,
- facilitate your access to and use of the Site,
- help us maintain the Site, and
- as otherwise specified in this Policy.
Although we do not associate any of this automatically collected information with particular individuals or otherwise use it to identify specific individuals, some jurisdictions consider information such as IP addresses, under certain circumstances, to be personal data.
When We Disclose Information
We do not share any data collected from the Site with third parties other than:
- to our service providers, to perform the functions described in this Policy;
- if we believe that such disclosures are required to comply with applicable laws, regulations, subpoenas, legal process, governmental investigations, regulatory requests or inquiries, to cooperate with law enforcement, to assert or defend legal claims, to protect our and others’ rights, property, or safety, or for the purposes of crime and fraud prevention and remediation;
- to our acquirers or successors, if Rubicon, or any of our assets or businesses, are acquired by or merged with another entity, for use in a manner consistent with this Policy; or
- if you otherwise provide consent.
We do not use or disclose such data for directing marketing purposes.
Data Transfers and Certain Data Protection Rights
To the extent that any data that we or our service providers collect pertains to an identified or identifiable natural person in the European Economic Area or the United Kingdom, the provisions of this section will apply, and you will have various rights with respect to our use, processing and sharing of such personal data, as described below. There may be exceptions to these rights under applicable law. If you wish to exercise any of these rights, please contact us using the contact information at the end of this Policy.
Only you, or a person whom you authorize to act on your behalf, may make a request related to your personal data. The request must:
- provide sufficient information for us to reasonably verify you are the person about whom we collected personal data or an authorized representative of such person; and
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal data if you do not take the foregoing actions. Making a request does not require you to create an account with us. We will use personal data provided in a request only to verify your identity or authority to make the request.
- Access: You may request a copy of the personal data that we have collected, used, shared, or sold about you, and why we collected, used, shared, or sold that personal data, including the categories of personal data collected, the specific items of personal data collected, the categories of sources from which we collected personal data, the purposes for which we use the personal data, the categories of third parties with whom we share the personal data, and the categories of information that we sell or disclose to third parties.
- Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us to let us know if any of your personal data is not accurate or changes.
- Objecting/Deletion: You have the right to object to processing of your personal data and to ask us to block, delete or restrict your personal data subject to certain exceptions. Once we receive your request and verify your identity, we will delete your personal data from our records and direct our service providers to delete your personal data from their records, unless an exception applies under applicable law.
- Portability: You have the right to request that your personal data be provided to you, or to another data controller, in a commonly used, machine-readable format.
- Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority.
We will retain personal data for no longer than is necessary for the purposes for which it was processed.
Protection of information and Network Security
We endeavor to protect your personal information. We use technical, administrative and physical methods to maintain the integrity and security of our databases, including firewalls. Please be aware though that there is no such thing as “perfect security” on the Internet, and third parties may unlawfully intercept or access transmissions or private communications. We will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personal information. You use the Site and send us information at your own risk.
Do Not Track
We do not track visitors of the Site over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals.
Access to Portfolio Company and Other Third Party Websites
If you wish to reach us concerning this Policy or any data that we collected about you when you visited the Site, please email us at email@example.com or write to us at Rubicon Technology Management L.L.C., 1470 Walnut Street, Suite 400, Boulder, CO 80302, Attn. Jon Franke.
The laws of the State of Colorado govern this Policy. Any dispute relating to this Policy or your use of the Site shall be resolved solely in the state or federal courts located in Denver, Colorado. You agree to waive trial by jury in any such action.