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THREE SIXTY CAPITAL PARTNERS¹ is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, THREE SIXTY CAPITAL PARTNERS is committed to the appropriate protection and use of personal information (sometimes referred to as “personally identifiable information” or “PII”) that has been collected through its web sites.

Generally, our intent is to collect only the personal information that is provided voluntarily by visitors to our web sites so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this Online Privacy Statement (“Online Privacy Statement” or “Privacy Statement”) to learn more about how we collect, use, share and protect the PII that we have obtained.

Collection and use of PII 
We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your PII to THREE SIXTY CAPITAL PARTNERS (if, for example, you are a former employee). By registering and/or submitting personal information on our web sites, you are also agreeing to the use of this information in accordance with this Privacy Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you send us an email message requesting information about THREE SIXTY CAPITAL PARTNERS, we will use your email address and other information you supply to respond to your request. If you send us a resume or curriculum vitae (CV) to apply online for a position with THREE SIXTY CAPITAL PARTNERS, we will use the information that you provide to match you with available THREE SIXTY CAPITAL PARTNERS job opportunities.

THREE SIXTY CAPITAL PARTNERS generally collects only the personal information necessary to fulfill the visitor’s request. Where additional, optional information is sought, you will be notified of this at the point of collection.

THREE SIXTY CAPITAL PARTNERS only collects “sensitive” personal information when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person’s race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record. Please use your discretion when providing sensitive information to THREE SIXTY CAPITAL PARTNERS, and under any circumstances, do not provide sensitive information to THREE SIXTY CAPITAL PARTNERS, unless you thereby consent to THREE SIXTY CAPITAL PARTNERS’s use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in THREE SIXTY CAPITAL PARTNERS databases. If you have any questions about whether the provision of sensitive information to THREE SIXTY CAPITAL PARTNERS is, or may be, necessary or appropriate for particular purposes, please contact THREE SIXTY CAPITAL PARTNERS at the address indicated below.

Automatic collection of PII 
In some instances, THREE SIXTY CAPITAL PARTNERS automatically collects certain types of information when you visit our web sites and through emails that we may exchange. Automated technologies may include the use of web server logs to collect IP addresses, “cookies”, and web beacons. The collection of this information will allow us to better understand and improve the performance, usability and effectiveness of THREE SIXTY CAPITAL PARTNERS web sites and to measure effectiveness of our marketing activities.

IP addresses 
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

Cookies 
A “cookie” is a small piece of text that a Web site places in the cookie file of your browser and that allows the site to remember who you are. Cookies cannot be used to run programs or deliver viruses to your computer. THREE SIXTY CAPITAL PARTNERS only uses cookies in accordance with applicable laws.

Cookies by themselves do not tell us your email address or otherwise identify you personally. If you visit a THREE SIXTY CAPITAL PARTNERS web site, we use cookies to compile aggregate statistics to help us determine what areas of the site visitors prefer.

If you subsequently register with a THREE SIXTY CAPITAL PARTNERS web site, this information may be linked to a cookie in order to enhance and personalise your online experience (e.g., by welcoming you back when you return or providing you access to your registration information).

You have the choice of deciding whether to accept cookies or not. You can set your browser to notify you when you receive a cookie or to reject cookies. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our Web site features.

Web beacons 
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. THREE SIXTY CAPITAL PARTNERS only uses web beacons in accordance with applicable laws.

THREE SIXTY CAPITAL PARTNERS or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we may confirm a recipient’s email address through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

Sharing and transfer of PII 
We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards.

In some instances, THREE SIXTY CAPITAL PARTNERS may also share PII about you with various outside companies or service providers or vendors working on our behalf to help fulfill your requests.

In addition, THREE SIXTY CAPITAL PARTNERS may transfer certain PII across geographical borders to other THREE SIXTY CAPITAL PARTNERS member firms or outside companies working with us or on our behalf. THREE SIXTY CAPITAL PARTNERS may also store PII in a jurisdiction other than where you are based. By providing PII on THREE SIXTY CAPITAL PARTNERS’s web sites, visitors are consenting to this transfer and/or storage of their data across borders.

THREE SIXTY CAPITAL PARTNERS may also disclose PII in connection with the sale, assignment, or other transfer of the business of the site to which the data relates, in order to respond to requests of government or law enforcement agencies or where this is required by applicable laws, court orders, or government regulations. These disclosures may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat. THREE SIXTY CAPITAL PARTNERS does not sell PII to any third parties. Also, THREE SIXTY CAPITAL PARTNERS will not transfer the PII you provide to any third parties for their own direct marketing use.

Children 
THREE SIXTY CAPITAL PARTNERS understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

Choices 
You have several choices regarding your use of our sites. In general, you are not required to submit any PII when you visit our web sites, but THREE SIXTY CAPITAL PARTNERS may require you to provide certain PII in order for you to receive additional information about our services and events. Certain web sites may also ask for your permission for certain uses of your PII, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

Access 
If you have submitted personal information to THREE SIXTY CAPITAL PARTNERS, under most circumstances you have the right to reasonable access to that data to correct any inaccuracies. You can also make a request to update or remove information about you by contacting privacy@360capital.co.nz, and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

Data security and integrity 
THREE SIXTY CAPITAL PARTNERS has reasonable security policies and procedures in place to protect personal information from unauthorised loss, misuse, alteration, or destruction. Despite THREE SIXTY CAPITAL PARTNERS’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. We also make reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual’s request or until that person asks that the information be deleted.

Links to other sites 
Please be aware that THREE SIXTY CAPITAL PARTNERS web sites may contain links to other sites, including sites maintained by other THREE SIXTY CAPITAL PARTNERS member firms that are not governed by this Privacy Statement but by other privacy statements that may differ somewhat. We encourage users to review the privacy policy of each Web site visited before disclosing any personal information.

Changes to this policy 
THREE SIXTY CAPITAL PARTNERS may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how THREE SIXTY CAPITAL PARTNERS is protecting your information.

Policy questions and enforcement 
THREE SIXTY CAPITAL PARTNERS is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personally identifiable information, please contact us at privacy@360capital.co.nz. You may also use this address to communicate any concerns you may have regarding compliance with our Online Privacy Statement.