Rising Tide Capital

Our Policies

Last Updated: December 3, 2021

Rising Tide Capital’s Commitment To Privacy

Rising Tide Capital (“RTC”) values your support and respects your privacy. To demonstrate our commitment to protecting your rights, whether you donate online, in person, through the mails or over the phone, we created this privacy policy (“Privacy Policy”) to explain how we treat the information you provide us through your use of our website or any offline information you share with us. By using our website, you agree to the terms of this Privacy Policy, which may be amended from time to time.

Rising Tide Capital, Inc. (“RTC,” “we,” “us,” or “our”) welcomes you. Our Services are subject to the following privacy policy (the “Privacy Policy”), which may be updated by us from time to time without notice to you. By accepting this Privacy Policy, accessing or using the Services, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy and the accompanying Terms of Use, which together make up the Agreement. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy or any other terms of the Agreement, you may not access or use the Services.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

THE INFORMATION WE COLLECT AND HOW WE USE IT

In the course of operating the Services, RTC collects or receives the following types of information, which may include personal information.

Contact Information
We collect contact information through our Services; contact information typically includes your name, email address, postal address, username and password, and any information you provide in messages to us (collectively, “Contact Information”). If you log in using any third-party social media platform access credentials, you are authorizing RTC to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed such third-party could provide to us. Such information may include, without limitation, your first and last name, username, profile picture, unique identifier and access token, and e-mail address. We use such Contact Information for purposes such as submitting and reviewing your application, registering you for an account on the Platform, providing you with information about the Services, responding to your inquiries, sending you email and text alerts (including marketing emails and text messages), or providing you the Services.

Application Information
To join a Program, you will need to submit an application. The application will request your Contact Information, as well as demographic information, including, but not limited to, your age and income range. This information is used to review your application, and if accepted, to determine your fees for participation in the Program(s).

Live-Stream Sessions
We provide our individual and group sessions virtually through our live-stream online video service provider, Zoom. Zoom automatically collects certain personal information from live-stream participants and uses such information as needed to deliver the functionality of the Zoom platform and operate its business (including to enhance or improve the Zoom services). For more information regarding Zoom’s privacy practices, please visit its Privacy Statement, available at https://zoom.us/privacy. These

We may record some or all live-stream sessions to ensure they run smoothly, to ensure that Participants are receiving appropriate content, and to provide instructors training and feedback.

Payment Information
In order for us to process your payments, we require that you provide our third party payment vendors, including AppFrontier (Chargent), certain billing information, which may include your credit card number, expiration date, bank account information, billing address, activation code, and similar information (collectively, “Payment Information”). You authorize our third-party payment vendors to collect, process, and store your Payment Information in accordance with their respective privacy policies. You can find the Privacy Policy for AppFrontier here. We reserve the right to change our payment vendors at any time, or to use additional payment vendors, at our discretion, and will update this Privacy Policy from time to time accordingly.

Server Log Information
Our servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and the pages you’ve clicked on while on our Services, and details regarding your activity on the Services such as time spent on the Services and other performance and usage data. We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing traffic, or optimizing the user experience.

Cookies
We may collect information using “cookie” and other similar technologies. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your use. We use both first and third party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.

● Session Cookies: We use session cookies to make it easier for you to navigate our Services. A session ID cookie expires when you close the Services.

● Persistent Cookies: A persistent cookie remains on your device for an extended period of time or until you delete them. To the extent we provide a log-in portal or related feature on our Services, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. Additionally, persistent cookies enable us to track and target the interests of our visitors to personalize the experience of our Services.

If you do not want us to place a cookie on your device, you may be able to turn that feature off on your device. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, certain aspects of the Services may not function properly or as intended.

Third-Party Analytics Providers
We use one or more third–party analytics services to evaluate your use of the Services, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Services you visit, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data.

By accessing and using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including 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 Services.

For Google Analytics, please visit: https://support.google.com/analytics/answer/6004245?hl=en

For Salesforce, please visit: https://www.salesforce.com/company/privacy/

For Thinkific, please visit: https://www.thinkific.com/dpa/

Aggregate Data
In an ongoing effort to better understand our visitors to the Website, Participants, and the Services, we might analyze your information in aggregate form to operate, maintain, manage, and improve the Services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics to describe the Services to current and prospective business partners and to other third parties for other lawful purposes.

Onward Transfer to Third Parties
· Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: hosting services, technical assistance, database management/back-up services, use analytics, video live-stream and recording provider, email marketing platforms, and customer service.

· We may share your personal information with our funding sources.

· We may also disclose personal information to our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control to support the marketing and sale the Services.

Business Transfers
In the event of a merger, dissolution, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This policy shall be binding upon RTC and its legal successors in interest.

Disclosure to Public Authorities
We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

OPT-OUT FOR DIRECT MARKETING; EMAIL AND TEXT MESSAGE MANAGEMENT
You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to Info@RisingTideCapital.org or by clicking on the “Unsubscribe” link located on the bottom of any RTC marketing email and following the instructions found on the page to which the link takes you. Please allow us a reasonable time to process your request. You cannot opt out of receiving transactional e-mails related to the Services.

You may also opt out of receiving marketing text messaging at any time by responding to such text messaging with “STOP.”

HOW WE PROTECT YOUR INFORMATION
RTC takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Policy. Accordingly, we implement reasonable security measures designed to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and to comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share your information (as permitted herein), nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

CHILDREN
We do not knowingly collect personal information from children under the age of 13 through the Services. 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 Policy by instructing their children to never provide personal information 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 at Info@RisingTideCapital.org and we will endeavor to delete that information from our databases.

IMPORTANT NOTICE TO ALL NON-US RESIDENTS
Our servers are located in the US and elsewhere. Please be aware that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Services, you do so at your own risk.

CALIFORNIA PRIVACY RIGHTS
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact RTC via email at Info@RisingTideCapital.org

DO NOT TRACK
RTC does not respond to “Do Not Track” settings or other related mechanisms at this time.

NEVADA PRIVACY RIGHTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at Info@RisingTideCapital.org with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

LINKS TO EXTERNAL WEBSITES
The Services may contain links to third-party websites (“External Sites”). RTC has no control over the privacy practices or the content of any such External Sites. As such, we are not responsible for the content or the privacy policies of such External Sites. You should check the applicable privacy policy and Terms of Use when visiting any such External Sites.

CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is effective as of the last updated date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By accessing the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

HOW TO CONTACT US
If you have questions about this Privacy Policy, please e-mail us at Info@RisingTideCapital.org with “Privacy Policy” in the subject line.

Information Rising Tide Capital Collects and Use of Such Information
In connection with your use of our website, we sometimes collect non-personally identifiable information about you such as your IP address and the web pages you visit. We may also send “cookies” to your computer which are small text files sent to your computer and stored on its hard drive that helps us recognize repeat visitors, facilitate each visitor’s ongoing access to and use of our site, and track usage behavior. Cookies cannot be read by a site other than ours, and no cookie will contain information that allows anyone to contact you via telephone, e-mail, or any other means. You can remove or block cookies using the settings in your browser, but in some cases, that may impact your ability to use our website.

We use “cookies” and collect other non-personally identifiable information to enhance your browsing experience on our website. We may also collect personally identifiable information about you, such as your name, address, email address, phone number, and/or payment and billing information, which is not collected by RTC unless you provide it to us voluntarily and knowingly. This information is only used to contact you with messages that are related to your interest in RTC. Other privacy practices may apply to information you provide to us through other channels.

This website uses Google AdWords a remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors to our website who may or may not have completed a task on our site, for example using the contact form to make an inquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on an individual’s past visits to the RTC website. Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy.

Rising Tide Capital Does Not Sell or Otherwise Distribute Information We Collect
Except as described in this Privacy Policy, Rising Tide Capital does not disclose personal information to any third parties unless required to do so by law. We do not sell, rent, trade, or otherwise share mailing lists or database information provided by you with any third party without your prior consent.

RTC’s Commitment to Data Security
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, RTC has put in place commercially reasonable physical, technical, and managerial procedures to safeguard and secure the information we collect online. This information is not available to the public and RTC’s personnel are dedicated to maintaining and upholding your privacy and security.

We cannot, however, ensure or warrant the security of any information you transmit to RTC or guarantee that your information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. In the event that personally identifiable information is compromised as a result of a breach of security, RTC will promptly notify those individuals whose personally identifiable information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.

Links to Other Sites
Rising Tide Capital provides links to other third-party websites for your convenience and/or information. If you access those links, you will leave RTC’s website and be re-directed to a third-party website. RTC takes no responsibility for, and exercises no control over, third party organizations’ privacy policies, security practices, views, or the accuracy of any information contained on other such sites. RTC does not endorse or make any representations about third-party websites, and the personal data you choose to provide to third-party websites is not covered by this Privacy Policy. We encourage you to review the privacy policy of any website or company before submitting your personally identifying information to them.

We may also provide social media features that enable you to share information with your social networks and to interact with RTC on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites.

Website Donor Privacy
Credit card transactions on the RTC website are processed by Braintree and are governed by Braintree’s privacy policy. Braintree collects information on behalf of RTC and does not disclose it to any party other than RTC. Braintree uses industry-accepted encryption for the transmission of credit card information, which keeps visitor information secure, accurate, current, and complete. If you donate to RTC through Braintree, you are able to opt-in to future communications from RTC. After opting-in, you may opt-out of future mailings by selecting “unsubscribe” at the bottom of each message.

Rising Tide Capital’s Refund Policy
By making a charitable gift to Rising Tide Capital, a 501(c)(3) organization, the donor understands that charitable donations are not refundable.

Changes to Rising Tide Capital’s Privacy Policy
Rising Tide Capital reserves the right to update or change this Privacy Policy at any time. Any material changes to this Privacy Policy will be posted to our website. Changes to this Privacy Policy are effective when they are posted on this page.

Questions
If you have any comments or questions regarding this Privacy Policy or the information practices of RTC, please contact us at info@risingtidecapital.org.