Effective Date: January 2021

Your privacy is important to Oakcliff Capital, and to our affiliated entities (“Oakcliff” or “we”), and we know that you care about how your personal information is used and shared.

This Privacy Policy, as part of our Terms of Use, explains what information we gather about you through our website, how we use it, how you can access it, and the safeguards we have in place to protect it. Please read this Privacy Policy carefully before using this website and related webpages (collectively, the “Site”). By accessing or using this Site, you agree to this Privacy Policy; however, if you do not agree with our policies and practices, please do not use our Site. THE SITE IS OPERATED IN THE UNITED STATES AND IS INTENDED FOR USERS LOCATED IN THE UNITED STATES.

This Privacy Policy applies to information collected and processed through the Site. If you have a business relationship with Oakcliff, you may be subject to additional privacy policies. If our additional privacy policy is applicable to you, that notice will govern over this Privacy Policy, to the extent there is a conflict.

Contact Information

Should you have any questions about our Site or this Privacy Policy, contact us at:  info@oakcliffcapital.com

Scope of this Privacy Policy

This policy applies to information we collect:

• On this Site; and

• In email, text and other electronic messages between you and the Site.

This policy does not apply to information collected:

• By Oakcliff offline or through any other means, including on any other website operated by any third party;

• By Oakcliff that is subject to our additional privacy policy; or

• By any third party, including through any application or content that may link to or be accessible from or on our Site.

Collection of Information

In the course of using this Site, Oakcliff may ask you for certain information, including, but not limited to, your name, email address, postal address and telephone number (home and work) (any of which is “personal information”). The types of personal information we collect depend on the nature of your interaction with us. Generally, you can visit our Site without telling us who you are or revealing any personal information about yourself; however, you must provide personal information in order to receive communications, make inquiries to Oakcliff, or otherwise interact with the Site.

Oakcliff may also collect non-personal information when you visit our Site, including but not limited to the type of Internet browser you are using, the type of operating system you are using, device information, the domain name of your Internet service provider, aggregate data about the number of visits to the Site and aggregate data about the pages visited, but in doing so, we do not connect this information with your personal information such as your name or email address.

Cookies and Tracking Technologies

Like most website operators, Oakcliff, its affiliated companies and business partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole (“Cookies”). A cookie is a very small text file placed on the hard drive of your computer. You can control the use of Cookies at the individual browser level, but if you choose to disable Cookies, it may limit your use of certain features or functions on our Site. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you direct your browser to our websites.

We use session Cookies that expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) and persistent Cookies that remain on your hard drive until you erase them or they expire. How long a persistent Cookie remains on your browser depends on how long the visited website has programmed the Cookie to last or they can be stored for longer.

We use Cookies for different purposes, including tracking your consent for various services, personalizing content, improving and troubleshooting the Site, and targeting advertisements.

We may use third-party service providers to monitor and analyze the use of our Site. The analytics providers we work with include Google and their privacy policy is available at https://www.google.com/policies/privacy/.

How We Use the Information We Collect

Oakcliff uses aggregate, non-personal information to provide and improve the design and content of the Site, to diagnose and fix issues with the Site and to analyze Site usage. Oakcliff shall own such aggregate, non-personal information and maintain copies of such as part of its records indefinitely.

Except as otherwise indicated, Oakcliff may use the personal information that is provided by you: (a) to provide you with information that you request from us; (b) for internal marketing purposes; (c) to respond to inquiries or questions about Oakcliff; (d) in any other way we may describe when you provide the information; (e) to protect against a threat of safety or destruction of property; (f) to provide inquirers with additional and updated information and materials regarding Oakcliff’s services; (g) to protect the rights of other users of this Site; (h) to cooperate with government officials or parties in litigation under process of law, or as otherwise required by law; (i) to protect the security or integrity of the Site; (j) to fulfill the purpose for which you provide it; (k) to protect against legal liability; and/or (l) for any other purpose with your consent. In all cases, however, Oakcliff agents, employees and contractors who have access to personal information are required to protect this information in a manner that is consistent with this Privacy Policy. Oakcliff will not use the personal information, except as set forth herein, without your express authorized permission.

Subject to applicable law, we may retain your information for as long as needed to provide you with services requested by you, comply with our legal obligations, resolve disputes and enforce our agreements. We may not remove your personal information when there is a legal storage requirement, such as accounting rules or when there are other legal grounds to keep the data, such as an ongoing contractual relationship.

Sharing Your Information

We do not sell your personal information to third parties; however, we do share personal information with third parties for other business purposes. We may disclose the personal information that we collect from you or that you provide, as follows:

• To contractors, service providers and other third parties we use to support Oakcliff and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;

• To a successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Oakcliff’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Oakcliff about our Site users, donors or clients is among the assets transferred;

• To our subsidiaries and affiliates for business purposes consistent with those for which the information was provided;

• To fulfill the purpose for which you provide it;

• With your consent;

• To comply with any court order, law or legal process, including responding to any government or regulatory request;

• To enforce or apply our terms of use and other agreements; or

• If we believe disclosure is necessary or appropriate to protect the rights, property or safety of Oakcliff, our employees, or others.

We also collect, use, and share aggregated and de-identified data such as statistical or demographic data for any purpose at our discretion. Aggregate and de-identified data could be derived from your personal information but will not directly or indirectly reveal your identity. If we combine or connect aggregate or de-identified data with your personal information so that it could be used to directly or indirectly identify you, we would treat such combined data as personal information, which will be used in accordance with this Privacy Policy.

Your Rights and Choices regarding your Personal Information

Opt-Out: Oakcliff offers Site visitors a means to choose how we use the information provided. If you do not wish to have your personal information used by Oakcliff as noted above, please notify Oakcliff directly at info@oakcliffcapital.com.  Notwithstanding the foregoing, Oakcliff may be required to use your personal information to complete transactions requested by you or to cooperate with government officials or parties in litigation under process of law, or as otherwise required by law, and/or to protect against legal liability.

Accessing and Correcting Your Information: Site users may request access to, review or modify their personal information maintained by Oakcliff by contacting us at info@oakcliffcapital.com.

We may not accommodate a request to opt-out or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect or if the identity of the requesting party cannot be verified.

Information Security

Oakcliff has implemented security measures to help protect against the risk of loss, misuse and alteration of any personal information under Oakcliff’s control. Nevertheless, such security measures may not prevent all loss, misuse or alteration of information on the Site, and Oakcliff is not responsible for any damages or liabilities relating to any such security failures. By using this Site, you understand that there is a risk that data and communications, including email and other electronic communications, may be accessed by unauthorized third parties when communicated over the Internet. The foregoing does not affect any liability which cannot be excluded or limited under applicable law.

Your California Privacy Rights

Under California law, a California resident with whom Oakcliff has an established relationship has the right to request certain information with respect to the types of personal information Oakcliff has shared with third parties for their direct marketing purposes (if any), and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. In response to a written request, Oakcliff is allowed to provide a cost-free means to opt-out of such sharing.

Since Oakcliff does not provide your personal information to third parties for their direct marketing purposes, it is not necessary for us to establish this procedure; however, if you do not want Oakcliff to use your personal information to provide information about our programs, please follow the cost-free opt-out procedures in this policy.

Our Policy on “Do Not Track” Signals and Third-Party Website Tracking under the California Online Protection Act (CalOPPA): We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. We do not engage in the collection of personal information over time across third-party websites, and we do not permit third parties to gather information passively on our website for behavioral advertising purposes.

Site Location; Transfer of Information to the United States

THE SITE IS OPERATED BY OAKCLIFF IN THE STATE OF NEW YORK, UNITED STATES OF AMERICA, AND PERSONAL INFORMATION WILL BE PRIMARILY STORED IN THE UNITED STATES. BY PROVIDING PERSONAL INFORMATION TO US, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU ACKNOWLEDGE THAT WE COLLECT, MAINTAIN, PROCESS AND TRANSFER SUCH INFORMATION IN AND TO THE UNITED STATES AND OTHER COUNTRIES AND TERRITORIES, PURSUANT TO THE LAWS OF THE UNITED STATES OR SUCH OTHER JURISDICTIONS, WHICH MAY PROVIDE LESSER PRIVACY PROTECTIONS THAN EUROPEAN ECONOMIC AREA COUNTRIES, AND TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU ACKNOWLEDGE THAT YOUR INFORMATION MAY THUS BE SUBJECT TO U.S. FEDERAL AND NEW YORK STATE LAW AND OTHER FOREIGN LAWS AND ACCESSIBLE TO U.S. AND FOREIGN GOVERNMENTS, COURTS, LAW ENFORCEMENT AND REGULATORY AGENCIES. BECAUSE OAKCLIFF IS LOCATED IN THE UNITED STATES, THESE DATA TRANSFERS TO THE UNITED STATES ARE NECESSARY TO PROVIDE THE SITE AND PRODUCTS AND SERVICES TO YOU AS SET FORTH IN THE TERMS AND TO OPERATE OUR SITE.

Information of Children

Our Site is not directed to children under the age of 13 years. We will not request personal information from anyone whom we know to be under the age of 13. By using our Site, you represent and warrant that you are at least 13 years old. If we become aware that a customer is under the age of 13 and has registered without prior verifiable parental consent, we will remove his or her personal information.

Links to Third-Party Websites

If any link is offered connecting to a third-party website, it is for the convenience of our Site visitors. The inclusion of any link does not imply endorsement by Oakcliff of that website and is provided only for informational purposes. Oakcliff reserves the right to remove any link for any reason. Websites linked to and from this Site are not necessarily under the control of Oakcliff, and Oakcliff shall have no responsibility or liability whatsoever for the content or privacy practices of any such linked website or any link or linking program at any time. If you click on a link from our Site and link to a third party’s website, then this Privacy Policy will not apply to your personal information collected on that third party’s website and you must read the privacy policy on that website to see how your information will be handled.

Changes to our Privacy Policy

Oakcliff may change this Privacy Policy at any time by posting the changed or amended Privacy Policy on the Site. Your continued viewing of or use of this Site following the posting of any changes to this Privacy Policy will indicate your assent to any such changes or amendments.

Nevada Privacy Rights

Nevada residents may opt out of the sale of their covered information, as those terms are defined in Nevada law, by submitting such request to our designated email address: info@oakcliffcapital.com; however, please note that we do not sell your covered information as defined by Nevada law.

Dispute Resolution

If you have an unresolved privacy or data use concern that Oakcliff has not addressed satisfactorily, please contact: info@oakcliffcapital.com.