Last updated 11/30/2022
What Information Does Karmel Gather?
Information You Give Us. We may collect and retain any information from you or your devices provided to us when you visit the Site, including when you: use our service; register for an account; or communicate with us
Automatically Collected Information.
We may collect information regarding the effectiveness of our email and other communications with you. For example, we may know if you follow a link in an email we send to you.Mobile. We may collect session and geolocation information from your mobile device. Geolocation information includes data such as your device’s physical location and may include GPS-based, WiFi-based or cell-based location information.
How Does Karmel Use Information About Me?
We and others acting on our behalf may use the information that we collect or receive to operate our business, including our Site, as described below:
Operate and Support our Site and Services.
We use the information that we gather in order to operate our Site and our services. For example, we may use the information that we collect or receive to provide assistance that you request. If you establish user account with us, we may use information about you to manage or support your account. We may identify your use of our Site across devices, and we may use information we collect from you and receive from others to optimize your use of the Site and our services as you use different devices.
We may contact you through telephone or email as permitted by law.
When Does Karmel Share Information?
What Choices Do I Have Regarding My Information?
How Can I Access and Update My Information?
Please contact us if you would like to access or update your information.
How does Karmel manage California Residents’ Privacy Rights?
If you are a resident of California, you have certain privacy rights under the California Consumer Privacy Act (“CCPA”). We honor those rights, as described below, and we are prohibited by law from discriminating against you for exercising any of those rights.
A. Right to Know
Subject to the exemption and exceptions mentioned below, if you are a California resident, you have the right to know what information we have collected about you, why we collected it, and the categories of third parties (excluding service providers) with whom we have shared the information during the past 12 months. (See below on “How to Submit a Request.”) You may request that we provide a description of the categories of information we have collected (a “Categories Request”) or a request for access to the specific pieces of information we have collected (a “Specific Pieces Request”).If you make a Categories Request, we will need to verify your identity to a reasonable degree of certainty. A reasonable degree of certainty may include you providing us with at least two data elements specific to you, so that we can verify your identity. After we confirm that your request is a verifiable consumer request, we will disclose to you:The categories of information we collected about youThe categories of sources for the information we collected about you (e.g., social media websites and government records available to the public)Our business or commercial purpose for collecting that informationThe categories of third parties other than service providers (if any) with whom we shared the informationIf you make a Specific Pieces Request, we’ll need to verify your identity to a reasonably high degree of certainty. In order to verify your identity, a reasonably high degree of certainty may include you providing us at least three data elements specific to you. After we confirm that your request is a verifiable consumer request, we will disclose to you:The specific pieces of information we collected about you that you requested
B. Right to Request Deletion
You have the right to request that we delete any of your information that we collected from you and retained, other than Personal Customer Information (as defined above). We are not obligated to comply with your request if we have a legal basis to retain the information. If you make a request for us to delete information, and you do not have any type of account with us, we may need you to provide us with at least two data elements specific to you so that we can verify your identity. Once we receive and confirm that your request is a verifiable consumer request (see below on “How to Submit a Request”), we will inform you whether we have deleted (and have directed our service providers to delete) your information from our records, or whether we are declining to grant your request to delete due to an exception to the CCPA deletion requirements.
Certain information is protected by federal and state privacy law other than the CCPA and thus the specific rights described above do not apply in the case of that information. Specifically, if you are, or apply to become, an investor in a Karmel managed fund, the non-public information we obtain from you in that context (“Personal Customer Information”) is protected under other state and federal law rather than the CCPA. Your rights as an investor are governed in the respect fund’s governing documents.
D. How to Submit a Request
To request access to or deletion of your information as described above, please submit a verifiable consumer request Clicking here or contacting at the address detailed below.We cannot respond to your request or provide you with information if we cannot verify your identity or authority to make the request and confirm that the information relates to you. This may require that you provide additional information following your request.We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We will only use information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Does Karmel Retain Information?
We retain information for as long as necessary to achieve the purpose for which it was collected, to fulfill legal or contractual obligations, or for as long as permitted by applicable law. We may retain aggregated or de-identified information indefinitely.
Does Karmel manage Do Not Track Signals?
Your browser may allow you to send us a “do-not-track signal” to communicate your privacy preferences to us. Our site may or may not respond to browser do-not-track signals.
How Does Karmel Protect the Security of the Personal Information it Collects?
We endeavor to protect the privacy of your account and other personal information we hold in our records. However, no method of information transfer over the Internet is 100% secure and we cannot guarantee the security of your information during its transmission or storage in our systems. We will assume that anyone who has the required login/password information for your account is you, so please keep this information confidential. If you believe that information about you has been subject to unauthorized disclosure, please let us know by contacting us.
How Can Karmel Capital be Contacted Regarding Privacy Issues?
You can contact us with questions or comments about our privacy practices or this Notice by contacting us or you can reach us by mail at:
Karmel Capital Management LLC
512 Via de la Valle, Suite 209
Solana Beach, CA 92075