Website Privacy Policy

The website (“www.solecap.com” or the “Site”), located at www.solecap.com, is owned and operated by Solebury Capital LLC.  Any reference to “Solebury Capital,” “we,” “us” or “our” in this Policy shall mean Solebury Capital LLC.  The Site includes all web pages accessible by the public.  Any reference to “you” in this Policy shall mean any user of the Site, including without limitation employees of Solebury Capital LLC.

This Policy applies only to information collected at this Site. It does not apply to information collected by us, or on our behalf, in person, through mail, by telephone, fax or any other means.  Please note that this Policy applies only to the Site and not to the web sites of other organizations to which we link.  We are not responsible for their privacy policies or practices of any other third party sites and you should make your own inquiries regarding them.

This Policy explains the principles governing our use of Personal Information (defined below) that we collect from visitors on the Site.  Personal Information may include your name, gender, email address, telephone number, address, other personal or preference information, details about your operating system, internet service provider, browser, IP address, the company name that the relevant IP address is affiliated to, the pages you visited on the Site, and the website you linked from to the Site.  We take your privacy very seriously.   If you have any questions or concerns regarding this Policy, you should contact us using the details given at the end of this document.

CONSENT
By using this Site, you agree to our collecting and using your Personal Information in the manner described in this Policy.

INFORMATION WE COLLECT ABOUT YOU
The amount and type of information received depends on how you use the Site and its various features.  In particular, when you visit the Site, you provide us with various types of information including Personal Information that you choose to disclose, and information regarding how you use the Site, which we collect as you interact with our Site.

In using the Site, you may choose to provide us with Personal Information, for example, when you register online for newsletters, request information or send us feedback or inquiries.  Personal Information may include your name, gender, email address, telephone number, address, and any other personal or preference information that we may request on a voluntary basis  in order to provide you access to the certain features of the Site, as well as to help us to identify aspects, services or offerings on the Site that you may find interesting.  Occasionally, we may also collect additional Personal Information from you through optional polls, questionnaires, or surveys.

As described further in our Cookie Policy, when you visit the Site, we collect details about your operating system, internet service provider and browser (in addition to your IP address (a unique identifier for your computer or other access device), the company name that the relevant IP address is affiliated to, the pages you visited on the Site, and the website you linked from to the Site). We do this through third party service providers, tracking technologies, and by placing “cookies,” which are small data files, on your computer.   Our third party providers may also put cookies on your computer to obtain information about you and your use of our Site.  We may also use cookies to identify returning users, and to provide users of our Site with the added convenience by being able to quickly access login-required areas of the site.  You can manage use of cookies through your browser settings.  You can find more information on our Cookie Policy.

CHILDREN
Children under 13 years old are not the target audience for the Site. To protect their privacy, we prohibit the solicitation of Personal Information from these children.  If you are under the age of 13, please do not submit your email address or any other personal information to us through the Site.

USES OF COLLECTED INFORMATION
The purposes for which we process and store your Personal Information are, or may in the future be:
• To administer, monitor, understand Site use, and improve the Site and the services provided on the Site;
• To enable us to aggregate user profiles;
• Where you have requested it or in accordance with privacy laws, to provide you (by email, phone and/or mail) with marketing, promotional, or other information that we think may be of interest to you;
• As part or current or future legal or similar proceedings; and
• To enable us to comply with our legal and regulatory obligations.

Any promotional correspondence to you will provide you with the ability to opt-out of receiving future promotional material from us and you may contact us at any time to tell us that you do not want to receive marketing information from us by emailing us at the email address below.

DISCLOSURE OF YOUR PERSONAL INFORMATION
We may provide your Personal Information to our affiliates, including without limitation The PNC Financial Services Group, Inc. to the extent permitted by applicable law.  For this purpose, we may transfer the information you provide outside your country to another country that does not have similar data protection legislation and may provide a lower level of protection for your information. By submitting any information you consent to these transfers.

We may share your Personal Information with vendors we have hired to provide services for us.

We may also release Personal Information about you if you direct us to do so, or if we are required or authorized by law or if we reasonably believe that the disclosure is necessary in order to (a) fulfill a government request; (b) conform with the requirements of law or to comply with legal process served on us; or (c) protect or defend our legal rights or property or third party licensors of any material on the Site.

We do not use or disclose your Personal Information obtained from the Site, except as expressly stated in this Privacy Policy or as otherwise may be permitted by you or required by law.  Please note that certain jurisdictions may have more restrictive privacy requirements that will prevent disclosure of your Personal Information to any other person or entity, including our affiliates.

PROTECTING YOUR INFORMATION
We have strict security and confidentiality procedures pertaining to the storage and disclosure of your information.  We restrict access to Personal Information about you to those employees, agents or other parties who need to have such information to provide you with the information you have requested, or which we believe may be of interest to you, or to enable you to use other features of the Site.

Appropriate measures will be taken to safeguard your Personal Information to prevent unauthorized access, and to comply with applicable laws regarding the protection of such information.  These measures may include physical, electronic or other procedural protections, such as passwords, firewalls, and encryption or authentication technology.

While we do our best to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us.  The information you provide to us is sent over an open network, such as the Internet or email, and may be accessed by anyone.  We cannot guarantee the confidentiality of any communications or materials sent to us over such open networks.  We therefore do not accept any liability for direct or indirect losses in relation to security of any data that you send to us.

Your use of the Site, including any disputes arising from it, is subject to this Privacy Policy as well as our Terms of Use, Disclosures, and Cookie Policy and all dispute resolution provisions therein, including the limitation of liability and choice of law provisions.   We encourage you to refer to this Policy on an ongoing basis so that you understand our current Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you that is obtained through the Site.

ACCESS TO YOUR INFORMATION
If we process your Personal Information, you may have the right to request a copy of the Personal Information that we hold about you. If you wish to request access to such personal information, please email or write to us at the email address or postal address set out below in the “Contact Us” section. We may charge you a small fee for this service.  If you discover any inaccuracy, please let us know so that we can make whatever corrections are appropriate.

You may also ask us to remove your name from our marketing databases and if you do that we will comply as soon as practicable.

CONTACT US
Should you feel that your privacy or security is being compromised, wish to make a request for access to any personal data we may hold about you or to have inaccuracies in your information corrected (as described further on the “Access To Your Information” section above), or have any questions on this policy, please contact us at Solebury Capital LLC, 400 South River Road, Suite 300, New Hope, Pennsylvania 18938; email:info@solecap.com; and facsimile: +1 (215) 862-7234.

POLICY CHANGES
We reserve the right to change our Privacy Policy at any time.

Cookie Policy

As of September 10, 2015

IMPORTANT NOTICE: PLEASE READ CAREFULLY BEFORE USING THIS WEBSITE: This policy explains how cookies are used on this website. The policy may be amended from time to time. When we do, we will let you know by appropriate means such as by posting the revised policy on this page with a new “Last Updated” date. By using this site you agree to the placement of cookies on your computer in accordance with the terms of this policy. If you do not wish to accept cookies from this site please either disable cookies or refrain from using this site.

  1. What are Cookies?

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can recognize you when you revisit and remember certain information about you. This can include which pages you have visited, choices you have made from menus, any specific information you have entered into forms and the time and date of your visit.

  1. Types of Cookies

There are two main types of cookies:

Session cookies: these are temporary cookies that expire at the end of a browser session; that is, when you leave the site. Session cookies allow the website to recognize you as you navigate between pages during a single browser session and allow you to use the website most efficiently. For example, session cookies enable a website to remember that a user has placed items in an online shopping basket.

Persistent cookies: in contrast to session cookies, persistent cookies are stored on your equipment between browsing sessions until expiry or deletion. They therefore enable the website to “recognize” you on your return, remember your preferences, and tailor services to you.

In addition to session cookies and persistent cookies, there may be other cookies which are set by the website which you have chosen to visit, such as this website, in order to provide us or third parties with information.

  1. Our use of Cookies

We currently use, and may use in the future, the following types of cookies on this website.

We use session cookies to:

help us maintain security and verify your details whilst you use the website as you navigate from page to page, which enables you to avoid having to re-enter your details each time you enter a new page.

We use persistent cookies to:

help us recognize you as a unique user when you return to our website so that you do not have to input your details multiple times as you move between our pages or services

remember how you have customized your use of this site, such as your preferred currency and time zone

collect and compile anonymous, aggregated information for statistical and evaluation purposes to help us understand how users use the website and help us improve the structure of our website.

Many cookies are designed to give you optimal usage of the web. For example, we use cookies to enable you to improve your user experience when using our website, e.g. a cookie which recognizes if your browser supports specific technology features. This helps, for example, in enabling web pages to be loaded more quickly when you request the download of a large file.

In addition to cookies which send information to us, we also use cookies which collect information and send it to third parties. An example of this is Google Analytics. We use Google Analytics to help collect and compile information like the number of visitors to the site, where visitors have come to the site from and the pages they visited. Visit Google’s site for an overview of privacy at Google and information on how to opt out of the Google Analytics cookie. Where this site allows such cookies to be set or you access other websites from this site using the links provided, the operators of these websites will use cookies in accordance with their own cookies policy, which may differ from ours.

As with first party cookies, you are able to block third party cookies through your browser settings.

Some of our cookies may collect and store your personal information, such as your name or email address. We are committed to respecting and protecting your privacy and will ensure that all personal information collected by us is kept and treated in accordance with our privacy policy. A link to this policy is available within the footer of this portal or alternatively at our solecap.com website.

  1. Refusing Cookies on this Site

Most browsers are initially set to accept cookies. However, you have the ability to disable cookies if you wish, generally through changing your internet software browsing settings. It may also be possible to configure your browser settings to enable acceptance of specific cookies or to notify you each time a new cookie is about to be stored on your computer enabling you to decide whether to accept or reject the cookie. To manage your use of cookies there are various resources available to you, for example the “Help” section on your browser may assist you. You can also disable or delete the stored data used by technology similar to cookies, such as Local Shared Objects or Flash cookies, by managing your browser’s “add-on settings” or visiting the website of its manufacturer. As our cookies allow you to access some of our website’s features we recommend that you leave cookies enabled. Otherwise, if cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using this site altogether.

Disclosure

The information, materials and tools provided on this site or in any communication containing a link to this site is provided for informational purposes only and is not a quote or a confirmation of official terms; and not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or that would subject Solebury Capital or its affiliates to any registration or new or additional legal or regulatory requirement within such jurisdiction or country. This site is intended for information purposes only, and neither the information nor any opinion contained in this site or the other sites’ pages constitutes a solicitation or offer by Solebury Capital or its affiliates to buy or sell any securities, futures contract, options contract, other financial instruments, or provide any investment advice, recommendation or service. Certain products and services may not be available to you. If you have a contractual relationship with a Solebury Capital entity that extends to products and services referenced on the Solebury Capital site or these other sites, such communications have no effect on that contractual relationship and the terms of said contract or agreement govern that relationship.

The information on this site is provided on an “AS IS” basis for use at your own risk. Solebury Capital and its affiliates do not warrant, expressly or impliedly, the accuracy of said materials, for any particular purpose and expressly disclaims any warranties of merchantability or fitness for a particular purpose. Solebury Capital will not be responsible for any loss or damage that could result from interception by third parties of any information made available to you through this site. Although the information provided to you on this site is obtained or compiled from sources we believe to be reliable, Solebury Capital cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose. Neither Solebury Capital, nor any of its affiliates, directors, officers or employees, nor any third party vendor will be liable or have any responsibility of any kind for any loss or damage that you incur in the event of any failure or interruption of this site, or resulting from the act or omission of any other party involved in making this site or the data available to you, or from any other cause relating to your access to, inability to access, or use of the site or these materials, whether or not the circumstances giving rise to such cause may have been within the control of Solebury Capital or of any vendor providing software or services support. In no event will Solebury Capital, its affiliates or any such parties be liable to you for any direct, special, indirect, consequential, incidental damages or any other damages of any kind even if Solebury Capital or any other party have been advised of that possibility.

Additionally, Solebury Capital and its affiliates make no representation or warranty of any kind with respect to the completeness, quality, accuracy, timeliness, performance, reliability or comprehensiveness of the data, materials and information set forth in this website. In no event shall Solebury Capital or its affiliates be liable to any person or entity for any direct, indirect, special, consequential or other losses, costs or damages (including, without limitation, any lost profits, business interruption, loss or interception of information, programs or other data) that are related to the use of, or the inability to use, the content, materials, information, data and functions of this website or any linked website, although Solebury Capital or its affiliates may have been made aware of the possibility of such losses, costs or damages.

Further, no party may publish, transmit, or otherwise reproduce the information, data and materials contained in this website in whole or in part, in any format to any third party without the express written consent of Solebury Capital. The descriptions in this document are not a guarantee that any particular service or application will be available for your use, nor are the descriptions a guarantee that any service or application will perform in accordance with such descriptions or help you to achieve particular results. Before determining to use any service or application offered by Solebury Capital, you should consult with your independent advisors to review and consider any associated risks and consequences. This document does not constitute an offer or agreement, or a solicitation of an offer or agreement, to enter into any particular contractual relationship with Solebury Capital, but is provided to you solely for informational purposes by Solebury Capital. This document is designed to serve as a general summary of the products, services and applications that Solebury Capital may offer from time-to-time, and is not intended to constitute advertising or advice of any kind.

All opinions and information contained in this site constitute Solebury Capital’s judgment as of the date of this document and are subject to change without notice. Solebury Capital, persons connected with it, its affiliates and their respective directors and employees may, directly or indirectly, effect or have effected a transaction for their own account in the investments referred to in said materials before or after the material is published to any customer of Solebury Capital or its affiliates or may give advice to customers that may differ from or be inconsistent with the information and opinions contained on this site or another site referenced on this site. While the information on this site was obtained from sources believed to be reliable, neither Solebury Capital or its affiliates accept any liability whatsoever for any direct, indirect or consequential loss arising from any inaccuracy herein or from any use of this document or its contents.

Past performance is not necessarily indicative of future results. The risk of loss associated with securities transactions may be substantial. Finally, this site is intended solely for distribution to professional investors outside of the United States of America, and, if further information is required, persons outside of the United States may obtain it upon request by contacting the Solebury Capital office located in or nearest to the country where they reside.

PATRIOT ACT Under Section 326 of the USA PATRIOT Act, Solebury Capital and its affiliates are required to verify the identity of their clients. Solebury Capital utilizes the services of outside vendors, such as Dun & Bradstreet, to assist with this government-mandated requirement.