Zebra Capital Management, LLC (“Zebra Capital”) (i) operates the Zebra Capital website, (ii) together with its affiliate, Zebra Advisors, LLC (“Zebra Advisors”; Zebra Capital and Zebra Advisors being collectively referred to as “us”, “we” or “our”), provides investment advisory services to pooled investment vehicles, an open-ended registered investment company, pension and profit sharing plans and separate accounts; and (iii) licenses certain of its intellectual property to third parties on a case-by-case basis (individually and collectively, the “Services”).
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Services and the choices you have associated with that data.
We use your data to provide and improve the Services. By using the Services, you agree to the collection and use of information in accordance with this policy.
Services shall have the meaning given to such term above.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Processor means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Data Processors in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Services and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Services to you.
Types of Data Collected
While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address; and
- First name and last name; and
- Phone number; and
- Address, state, province, ZIP/postal code, city; and
- Company affiliation and title
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by contacting us.
We may collect information that your Internet browser, computer and/or mobile device sends whenever you visit our website. Like most websites, our servers automatically log each visitor and may collect the following and other information:
- Internet Protocol (IP) address; and
- Browser and operating system version; and
- Previous pages on our website that you visited, the referring web page address, the time and date of your visit, unique user identifiers and other diagnostic data.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.
Cookies we may use:
- “COOKIELAWINFO-CHECKBOX-NON-NECESSARY” cookie User session cookie which keeps track of each cookie approved by the user, which expires 1 year from the time of creation.
- “VIEWED-COOKIE-POLICY” cookie. User session cookie used to save the user’s acknowledgement that cookies are being used, which expires 1 year from the time of creation.
“Do Not Track”
Currently our website does not respond to “Do Not Track” features enabled through your web browser.
Use of Data
We use the collected data for various purposes, including without limitation:
- To provide and maintain our Services;
- To notify you about changes to our Services;
- To allow you to participate in interactive features of our Services when you choose to do so;
- To provide customer support;
- To gather analysis or valuable information so that we can improve our Services;
- To monitor the usage of our Services;
- To detect, prevent and address technical issues; and
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information.
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
We may process your Personal Data for various reasons, including without limitation:
- We need to perform a contract with you;
- You have given us permission to do so;
- The processing is in our legitimate interests and is not overridden by your rights;
- For payment processing purposes; and
- To comply with the law.
Retention of Data
Transfer of Data
Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We may disclose your Personal Data in the good faith belief that such action is necessary including, without limitation,:
- To comply with a legal obligation;
- To protect and defend our rights or property;
- To prevent or investigate possible wrongdoing in connection with the Services;
- To protect the personal safety of users of the Services or the public; and
- To protect against legal liability
Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
Please contact us If you wish to be informed what Personal Data we hold about you.
In certain circumstances, you have the following data protection rights:
The right to access, update or to delete the information we have on you. Whenever made possible, you have the right to access, update and request deletion of your Personal Data. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent to our processing of your personal information to the extent such processing is based on consent at any time where we relied on your consent to process your personal information.
To exercise any of your rights, or if you have any other questions about our use of your personal information, please email firstname.lastname@example.org or write to us at Zebra Capital Management, LLC, 2187 Atlantic Street, 4th Floor, Stamford, CT 06902. You may also use these contact details if you wish to make a complaint to us relating to your privacy. Please note that we may ask you to verify your identity before responding to such requests.
You also have the right to complain to a Data Protection Authority about our collection and use of the Personal Data. For more information, please contact your local Data Protection Authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Services (“Service Providers”), to provide the Services on our behalf, to perform Service-related services or to assist us in analyzing how our Services are used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Links to Other Sites
Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that any of your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Effective date: December 9, 2019