Privacy Policy

Privacy Policy

EFFECTIVE DATE: 16 November 2019

This Privacy Policy applies only to (“Site”), which is operated by Decurion Management Company (“Decurion”). This Privacy Policy only covers information collected at the Site and does not cover any information collected elsewhere by Decurion or any of its affiliated companies (unless specifically stated). By using the Site, you consent to this Policy and our website Terms of Use.


We may collect information through the Site, such as through a “contact us” feature, and some of that information may be considered “personal information” under various applicable laws. We consider information that identifies you as a specific, identified individual to be personal information (such as your name, phone number, e-mail address), and we treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. And, if we combine information we consider to be non-personal with personal information, we will treat that combined information as personal information under this Privacy Policy.

In addition to information you may provide to us directly, our Site may automatically or passively collect information as you access and use the Site, such as IP address and browser or device identifier (“Usage Information”). Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Site, the search terms you entered into a search engine that lead you to our Site (if applicable), all of the areas within our Site that you visit, and the time of day you visited the Site, among other information. In addition, we automatically collect your IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone or other device you may use to access the Site. A Device Identifier is a number that is automatically assigned to your device used to access a Site, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us, or our third-party service providers, with information regarding the physical location of the device used to access the Site.

The Site is for a general audience and we do not knowingly collect information from anyone younger than 18 years old.


We may use the information collected from visitors to the Site for several purposes, such as to enable you to use our Site, to respond to users who have contacted us, to contact you with administrative communications and, in our discretion, changes to our Privacy Policy, Terms of Use or any of our other policies, to understand how visitors use the Site, to improve our Site, products, and services and for other internal business purposes, to process information you provide via our Site, including verifying that your email address is active and valid, to comply with regulatory and legal obligations, and for purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

Analytics Providers

We may use analytics providers to help us understand and analyze the types of users who visit the Site and how they use the Site. In order to provide their services, these analytics providers collect information from and about you, including Usage Information and may set and access their own tracking technologies (discussed below) on your device, such as cookies and web beacons. Specifically, we may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to and opt out of them by downloading the Google Analytics opt-out browser add-on, available at


We, and our vendors and analytics providers, may use tracking technologies for a variety of purposes, including to help us gather information for analytics purposes. The tracking technologies we use include:

Cookies. “Cookies” are pieces of information (data files) transferred to a browser when the user visits a site. These technologies are able to store a unique identifier for a device to allow us to recognize the device whenever the device is used to visit the Site. We may use cookies for various purposes, including remembering information that will make your use of the Site more convenient and to track the total number of visitors to our Site on an aggregate basis. You can find more information about cookies and how they work at All About Cookies.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “pixel tags,” “1×1 GIFs,” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, to count visitors to the Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.


Some browsers allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no standard definition or application of “Do Not Track” at this time. To the extent required by law, Decurion will use commercially reasonable efforts to detect and process “Do Not Track” signals. To find out more about “Do Not Track,” please visit


We may share non-personal information, such as Usage Information and aggregated user statistics, with third-parties in our discretion. We do not share personal information with third parties for those third parties’ own marketing purposes. We may share information we have collected from you with third-parties with your consent, as disclosed at the time we collect the information, as otherwise described in this Privacy Policy, and under the following circumstances:

  • with its parent and affiliates, primarily for business and operational purposes;
  • with our vendors or service providers, such as a web hosting company, analytics service providers or customer service provider in order to provide services to us or to you;
  • to comply with legal process or a subpoena or to otherwise comply with law or regulation, or at the request of a governmental entity conducting an investigation;
  • to protect and defend the legal rights or property of Decurion, our Site or users, or any other party, and to protect the health and safety of our users or the general public; and
  • in the event Decurion goes through a business transition (such as a merger, acquisition by another company, bankruptcy, or sale of all or a portion of its assets, including, without limitation, during the course of any due diligence process), your Personal Information will likely be among the assets transferred. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.


The Site may contain links to third party websites. For example, the Site may contain links that direct users to our social networking pages (such as Facebook or Twitter). If you click on the social networking buttons or third-party links, you will be taken off of our Site, and your use of those third parties’ websites and platforms are subject to their privacy policies and practices. We are not responsible for the privacy or business practices of any third party.


We use commercially reasonable security measures to help secure your Personal Information. However, no system can be guaranteed 100% secure. We therefore cannot ensure or warrant the security of any information that you transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties. You use the Site and provide us with information at your own initiative and risk.


The Site are operated in the United States. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to and processed in the United States. By using the Site or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.


To the extent allowed by applicable law, Decurion reserves the right to change this Privacy Policy at any time without prior notice. Decurion will notify you of material changes by posting the changed or modified Privacy Policy on the Site. We may also provide notice to you in other ways, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Site after the effective date of the revised Privacy Policy will constitute your consent to those changes to the fullest extent allowed by applicable law. However, Decurion will provide notice and obtain your consent (opt-in or opt-out) if required. Note, that you may need to consent to our new policies in order to continue to use the Site.


If you would like more information about this Policy, or about Decurion’s online privacy practices please contact us: