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STABILIS PRIVACY NOTICE

 

Last Update: August 1, 2022

 

Stabilis Capital Management, LP (“Stabilis”) has created this Privacy Notice because we know that you care about how information you provide to us is used and shared. This Privacy Notice applies to our information collection and use practices when you visit this web site (the “Web Site”) and when we provide services to you via this Web Site (the “Services”). By visiting the Web Site, you are agreeing to the terms of this Privacy Notice and the accompanying Terms of Use, both of which govern your use of the Web Site. In addition to this Privacy Notice, depending on your relationship with Stabilis, you may receive and be covered by the Stabilis Investor Privacy Policy, other privacy disclosures within account opening documents, and other privacy and security rules.

 

We will refer to the information we obtain about you, or which could be used to identify you, as your “Personal Information.” Capitalized terms not defined in this Privacy Notice shall have the meanings set forth in our Terms of Use.

 

  • I.     COLLECTION OF YOUR PERSONAL INFORMATION

Stabilis collects your Personal Information from you directly and automatically when you use the Web Site, as well as from third–party web analytics and advertising services.

 

  1. Information you provide to us

You may provide us with the following kinds of Personal Information when you use the Web Site:

  • Contact information, such as your name, home or work address, email address, and phone number;
  • Information associated with your Stabilis account, such as your name, email, screen name, profile picture, user name and password;
  • Demographic information, such as your age, gender, preferences, interests, and favorites;
  • Geolocation information; and
  • Materials you provide to Stabilis, including feedback and suggestions (collectively “Submissions”).

 

  1. Information we collect automatically

Like most online services, we automatically receive standard technical information when you visit the Web Site. We collect this information through browser cookies, flash cookies, pixels, web server logs, web beacons, and similar technologies. This information is used by Stabilis for the operation of the Web Site, to maintain its quality, understand how you use it, maintain a persistent session, and to provide general statistics regarding use of the Web Site.

 

Information we collect automatically includes or could include:

  • Browser and device information such as unique device identifiers, mobile phone carrier, internet protocol (IP) addresses (which may identify your general geographic location), user agent string (e.g., operating system and browser type/version), and the date and time of your interactions;
  • Information about your interactions with the Web Site, such as which pages of our website you visited and when, how much time was spent on the page, and whether you read the emails we sent to you; and
  • Geolocation information.

 

  1. Information collected through third-party analytics services

We use third-party web analytics services to evaluate your use of the Web Site and to help us improve our performance and to develop new products, services, features, and functionalities. The third-party analytics services collect and analyze information about your online activities on your electronic devices, the Web Site, third-party websites, apps, and other online services. Third-party analytics services we may use for these purposes include Google Analytics, Google Firebase, Salesforce Pardot and Hubspot.

 

For more information on these third parties, including on how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Web Site.

 

 

 

  1. Information collected by third-party advertising companies

Third-party advertising companies may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect information about your activity on the Web Site for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Web Site and elsewhere. Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.

 

  1. Information obtained from third-party data providers

Stabilis subscribes to third-party databases which provide us with lists of accredited investors. We collect details from third party providers (i.e., firm details, contact information, etc.) that allow us to assess investor profile and interest. More information is available upon request.

 

 

  • II.     USE OF YOUR PERSONAL INFORMATION

Stabilis uses your Personal Information to operate the Web Site, deliver the Services you have requested, and to operate our business. This includes:

 

  1. Service-Related Usage

We use the information we collect from and about you to provide and support the Web Site and deliver the Services, such as communicating with you and other users, managing user accounts, providing customer service, and maintaining our systems.

 

  1. Analyzing and Improving the Web Site and Services

We may run calculations, aggregate, normalize, anonymize, clean, and make derivative works of your Personal Information in order to

  • Understand and analyze usage trends and preferences;
  • Monitor and analyze the effectiveness of the Services;
  • Improve the Services and develop new products, services, features, and functionality; and
  • Test the Services and our infrastructure to make sure the Services are working correctly.

 

  1. Marketing

As permitted by applicable law, we may use your Personal Information for marketing purposes, such as providing you with promotional materials that could be useful, relevant, valuable, or otherwise of interest to you. Where required under applicable law, we will obtain your prior opt-in consent to send you electronic marketing communications. Stabilis may also contact you via surveys to conduct research about your opinion of current Services or of potential new Services that may be offered.

 

  • III.     SHARING OF YOUR PERSONAL INFORMATION

We share, transfer, or disclose your Personal Information if you consent to us doing so, as well as in the following circumstances. Stabilis does not use or disclose sensitive Personal Information, such as race, religion, or political affiliations, without your explicit consent. We do not, and have not in the past, shared your Personal Information with third parties for their own direct marketing purposes.

 

  1. Service providers

We share information with third parties who provide services to us, such as customer services, website management, information technology and IT security, auditing, payment processing, data analytics, advertising, marketing, and other similar service providers. We do not authorize these service providers to use or disclose Personal Information except as necessary to perform services for us or to comply with legal requirements.

 

  1. Compliance with legal requirements

We may disclose our Personal Information if required or permitted to do so to:

  • Comply with applicable laws and legal processes;
  • Respond to requests from law enforcement authorities, public and government agencies or officials, or other persons or entities with appropriate legal authority or justification to receive such information, including persons or entities outside your country of residence; and
  • Protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.

 

  1. Affiliates and successors

We may share some or all of your Personal Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us. Further, as we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, your Personal Information may be part of the transferred assets.

 

  1. Aggregated, de-identified information

We may use Personal Information to create aggregate or statistical information that does not directly identify a specific person, and we may share that information with third parties. We may also share anonymous and aggregated reports and information on user demographics and industry patterns with third parties.

 

  • IV.     USE OF COOKIES

The Web Site use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect certain information and to enhance your experience using the Web Site.

 

One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a page on the Web Site or register with Stabilis, a cookie helps Stabilis to recall your specific information on subsequent visits. This simplifies the process of recording your Personal Information. When you return to the Web Site, the information you previously provided can be retrieved, so you can easily use the Stabilis features that you customized.

 

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You can find out how to do this for your specific browser by clicking “help” on your browser’s menu, or by visiting www.allaboutcookies.org. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Stabilis Services or Web Site.

 

If you have consented to location services through your browser’s settings, please consult your browser’s documentation regarding how to turn off location services. Note, however, that if you disable location services, you may not be able to use the full array of features and functionalities available through the Web Site and our Services.

 

  • V.     ACCESSING AND MODIFYING INFORMATION AND COMMUNICATION PREFERENCES

If you have registered for the Web Site, you may access, review, delete, and make changes to your Personal Information by following the instructions found on the Web Site or contacting us as set forth below. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Stabilis marketing email. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. Clients and investors cannot opt out of receiving transactional e-mails related to their accounts.

 

  • VI.     SECURITY OF YOUR PERSONAL INFORMATION

We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the internet. In particular, e-mails or messages sent to or from the Web Site may not be secure, and you should therefore take special care in deciding what information you send to us via those means.

 

  • VII.     EXTERNAL WEBSITES

The Web Site may contain links to third-party websites. Stabilis has no control over the privacy practices or the content of any other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy notice and terms of use when visiting any other websites.

 

  • VIII.     CHILDREN

We do not knowingly collect Personal Information from children under the age of 13 through the Web Site. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Notice by instructing their children to never provide Personal Information through the Web Site without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

 

  • IX.     DO NOT TRACK

As discussed above, third parties such as advertising networks and analytics providers may collect information about your online activities over time and across different websites when you access or use the Web Site. Currently, various browsers offer a “Do Not Track” option, but there is no standard for commercial websites. At this time, we do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

 

  • X.     NOTICE TO NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of personal information to third parties. You can exercise this right by contacting us at [privacy (at) stabiliscap.com] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

 

  • XI.     IMPORTANT NOTICE TO NON-U.S. RESIDENTS

The Web Site and its servers are operated in the United States. If you are located outside of the United States, please be aware that any Personal Information you provide to us will be transferred to the United States, where the privacy laws may not be as protective as those in your country of origin. By using the Web Site and by providing us Personal Information when using our Services, you consent to this transfer and our use of the data provided by you in accordance with this Privacy Notice, and you do so at your own risk.

 

  • XII.     CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice is effective as of the date stated at the top of this Notice. We may change this Privacy Notice from time to time and without prior notice to you to reflect changes in our privacy practices. We will indicate at the top of this Privacy Notice when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes. By accessing the Web Site after we notify you of changes to this Privacy Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of your Personal Information is governed by the Privacy Notice in effect at the time we collect the information.

 

  • XIII.     CONTACT INFORMATION

Stabilis welcomes your comments regarding this Privacy Notice. If you have any questions or comments about this Privacy Notice, our privacy practices, or if you believe that Stabilis has not adhered to this Notice, please email us at [privacy (at) stabiliscap.com]. We will use commercially reasonable efforts to respond to you and promptly determine and remedy any problems.