Last Revised: November 12, 2015

This Privacy Policy describes the types of information Golden Pacific Capital, LLC and/or its affiliates (“Golden Pacific”, “we” or “us”) may collect from you or that you may provide when you visit our website, http://www.goldenpacificcapital.com (the “Site”) and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect:

  • On the Site;
  • In e-mail, text and other electronic messages between you and the Site;
  • When you provide personally identifying information such as your name, address, phone number, and e-mail address (“personal information”) through the Site when, for example, you fill out forms or registrations within the Site.

It does not apply to information collected by:

  • Golden Pacific offline or through any other means, including on any other website operated by us or any third party, including our affiliates and subsidiaries; or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from the Site.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

YOUR PRIVACY IS NOT FOR SALE

We do not and will not sell or rent any personal information obtained through your use of the Site to anyone, for any reason, at any time. Golden Pacific may use and disclose that your personal information only as follows:

  • to third-party organizations that provide services to Golden Pacific Capital, LLC to fulfill your request (e.g. to process your buy or sell transaction) and are bound by these same privacy restrictions;
  • unless you ask us not to, we may contact you via email in the future to tell you about specials, new service offerings, or changes to this privacy policy;
  • to analyze site usage and improve the Service;
  • to deliver to you any administrative notices, alerts and communications relevant to your use of the Service;
  • to fulfill your requests for certain services and transactions;
  • for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
  • as otherwise set forth in this Privacy Policy.

In the event that you access the Site through one of our partners or service providers, through a co-branded URL or by web services, your email address used for registration on the Site may also be provided to that partner or service provider.

HOW WE LIMIT THE COLLECTION AND USE OF PERSONAL INFORMATION

Certain areas and features of the Site are available to you without registration or the need to provide to us any information. However, other features of the Site may require registration, which involves provision to Golden Pacific of an email username, address, a password and additional details for fulfilling your service requests or for participating in our third party sites (collectively the “Registration Information”).

HOW YOU CAN CHANGE YOUR REGISTRATION INFORMATION

If your Registration Information changes during your subscription to the Site you may update it any time via the Site.

HOW WE USE ONLINE SESSION INFORMATION TO IMPROVE YOUR EXPERIENCE

When you visit goldenpacificcapital.com, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Web design and functionality.

Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer’s hard drive. Golden Pacific Capital, LLC may set and access cookies on your computer to track and store preferential information about you. Golden Pacific Capital, LLC may gather information about you through cookie technology. For example, Golden Pacific Capital, LLC may assign a cookie to you. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer or device and to delete cookies stored on your computer or device. If you choose to eliminate cookies, the full functionality of the Service may be impaired for you.

Web beacons or zero or single byte tags are embedded in a Web page or email for the purpose of measuring and analyzing site usage and activity. Golden Pacific, or third party service providers acting on our behalf, may use Web beacons to help us analyze Site usage and improve our services and Site content.

We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online and email campaigns or analyze visitor activity on the Site and related sites. We may permit these service providers to use cookies and other technologies to perform these services for us. We do not share any personal information about our customers with these third party service providers, and these service providers do not collect such information on our behalf. Our third party service providers are required to comply fully with this Privacy Policy.

Google Analytics

We also use a tool called “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

CHILDREN’S PRIVACY

For protecting the privacy of young children, Golden Pacific does not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, do not share any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 is allowed to provide any personal information to Golden Pacific. In the event that we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. As a parent you are responsible for any transactions or services requested from Golden Pacific.

DISCLOSURE OF YOUR INFORMATION TO PROTECT OUR RIGHTS OR IF REQUIRED BY LAW

Notwithstanding the foregoing, Golden Pacific reserves the right (and you authorize Golden Pacific) to share or disclose your personal information when Golden Pacific determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:

  • To enforce our rights against you or in connection with a breach by you of this Privacy Policy;
  • To prevent prohibited or illegal transaction or activities; or
  • When required by any applicable law, rule regulation, subpoena or other legal process.

YOUR DATA MAY BE TRANSFERRED UPON CHANGE OF CONTROL BUT ONLY IN ACCORDANCE WITH THIS POLICY

Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change of control. If we sell, merge or transfer any part of our business, part of the sale may include your personal information. If so, you will be asked if you’d like to stop receiving promotional information following any change of control.

YOU CAN TRANSPORT OR DELETE YOUR DATA

Your data is yours. You can request us to remove it anytime you want. When you request us to delete your account for the Site, your data will be permanently expunged from our primary production servers and further access to your account will not be possible. We will also promptly disconnect any connection we had established to your account information and delete all related credentials. However, portions of your data, consisting of aggregate data derived from your account information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media. Golden Pacific keeps these backups to ensure our continued ability to provide the Site to you in the event of malfunction or damage to our primary production servers. We also reserve the right to use any aggregated or anonymous data derived from or incorporating your personal information.

ELECTRONIC COMMUNICATIONS FROM US

We provide our registered customers with periodic newsletters, information regarding new offers and email alerts. We also allow users to subscribe to email newsletters and from time to time may transmit emails promoting Golden Pacific or third-party goods or services. Site subscribers have the ability to opt-out of receiving our promotional emails and to terminate their subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts.

YOUR DATA IS SECURE

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on secure servers behind firewalls, and we implement data encryption and network security measures to protect your information. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

EXTERNAL PRIVACY

Golden Pacific is not responsible and cannot vouch for the privacy practices of other web sites, including web sites that are linked to the Site. Once you leave the Site, you are subject to the privacy policy of the web site you are currently browsing.

YOU ARE RESPONSIBLE FOR MAINTAINING THE CONFIDENTIALITY OF YOUR LOGIN ID, PASSWORD OR ANY LINKS SENT TO YOU RELATED TO YOUR INFORMATION

We recommend that you change your password periodically. Your password must be 6-8 characters in length. You are responsible for maintaining the security of your Login ID and Password. You may not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at investors@goldenpacificcapital.com. In any event you should change your password immediately via the Site. We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy Policy.

If you are forwarding any links related to data or otherwise provided by Golden Pacific, you are doing so at your own risk. Golden Pacific cannot be held liable for any consequences of such sharing.

If you have a security related concern, please contact us at investors@goldenpacificcapital.com. We will work closely with you to ensure a rapid and personal response to your concerns.

WE POST UPDATES ON OUR WEBSITE WHENEVER THERE IS A CHANGE TO OUR PRIVACY AND SECURITY POLICY

We update this Privacy & Security Policy periodically. The date last revised appears at the top of the Policy. Changes take effect immediately upon posting.

CONTACT US IF YOU HAVE ANY QUESTIONS OR CONCERNS

If you have questions, comments, concerns or feedback regarding this Privacy and Security Policy or any other privacy or security concern, send an e-mail to: investors@goldenpacificcapital.com.

If you feel that we are not abiding by this privacy policy, you should contact us immediately via telephone (917)688-4273, you can e-mail us through our website’s home page or use the Contact Us page on our website.