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EM Capital Management, LLC - Privacy & Cookie Policy

Approved as of 01-08-2015


EM Capital Management, LLC is a limited liability company organized under the laws of the State of Delaware and has offices in San Francisco, California, USA. Our affiliate firm, EM Capital Management (Hong Kong) Limitied is a limited liability company registered in Hong Kong SAR and has its registered office Hong Kong, and without notice, an office in London (together referred to as “EM Capital Management, LLC” , “EM Capital” or “we”, “our”, “us”).


This Privacy Policy describes the personally identifiable information that EM Capital Management, LLC collects through our website at,, and equivalent domains (the “Site”) and our use of that information.


This Privacy Policy applies solely to our collection of information through the Site and our use of that information and does not apply to our offline practices.Information may be shared by and between EM Capital Management, LLC in the USA and EM Capital Management (Hong Kong) Limited in the UK. In relation to the processing of information in the context of the London office, for the purposes of the UK Data Protection Act 1998, the data controller is EM Capital Management (Hong Kong) Limited.


Please read the following carefully to understand our practices regarding your personal information, and how we will treat it.


By visiting the Site you are accepting and consenting to the practices described in this Privacy Policy.


Information We Collect

The Site does not collect personally identifiable information about you unless you expressly provide such information, such as your name, physical address, and email address, to us on a voluntary basis; for example, when subscribing to our electronic newsletter, or requesting more information to be sent to you about EM Capital Management, LLC.  We may also add the information you expressly provide to our databases, subscriber lists, or contact lists.If you decide at any time that you no longer wish to receive materials from us, please see “Contact Us; Opt-Out” below. On rare occasions, we may send important administrative information regarding the Site or services to users using their email addresses; because such information may be important to your use of the Site, it may not be possible to “opt out” of receiving such emails.


Non-Personally Identifiable Information

We also automatically collect non-personally identifiable information through cookies and log files when you access the Site. Such information includes, without limitation, the following: your internet service provider, the IP address of the computer you are using, the type of browser software and operating system that you use, the date and time you access the Site, your length of stay on the Site, the pages that you visit on the Site, the Web site address, if any, from which you linked directly to the Site, the Web site address, if any, to which you travel from the Site, and other similar traffic information.We may aggregate your information with similar data collected from other users to help us improve our Site and the services we provide through our Site. We do not use such data in any way to create or maintain a personal profile of you or to collect personally identifiable information from you.



In order to improve the Site, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent from the Site to your browser or the hard drive of your computer, tablet or mobile phone ('device') and is stored on your device's hard drive. A cookie records on your device information relating to your internet activity (such as whether you have visited the Site before).The cookies we use on the Site are solely for website analytical purposes. We do not use cookies to collect any personally identifiable information about you.


We use the following cookies on the Site:


Google Analytics

We use Google Analytics which is a web analytics service provided by Google Inc. in order to understand how visitors to the Site use the Site.The Google Analytics cookies collect information about how people are using the Site, for example which pages are visited the most often, how people are moving from one link to another and if they get error messages from certain pages. The cookies do not gather any information that identifies you. The information these cookies collect is grouped together with information from other people's use of the Site on an anonymous basis. Overall, these cookies provide us with analytical information about how the Site is performing and how we can improve it.


You can opt out of Google Analytics without affecting your use of the Site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.


Clicky Analytics

Clicky Analytics cookies are used to monitor website traffic levels, search queries and visits to the Site. Clicky Analytics cookies do not collect personal information about you. The cookies enable the analytics to determine whether you are a return visitor to the Site, and to track the pages that you visit during your session.For details about the cookies, and how to disable them, please check the Clicky privacy policy at this page. If you wish to restrict or block the cookies which are set by the Site, or indeed any other website, you can do this through your browser settings. Your web browser's help function should tell you how to do this.


Our Use of Information We Collect

We use information held about you in the following ways:to send you the subscriptions you request;to respond to your inquiries and comments;from time to time, to send you information regarding events and developments that we think may be of interest to you; andto administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.


Disclosure of Your Information

Generally, we do not disclose personally identifiable information that we collect through your use of the Site to unaffiliated third parties without your consent. However, we reserve the right to provide such information to our employees, contractors, agents, and designees to the extent necessary to enable them to perform certain Site-related services on our behalf.


We also reserve the right to disclose such information to any third party if we believe that we are required to do so for any of all of the following reasons: (i) by law; (ii) to comply with legal processes or governmental requests; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of the Site or our network; or (iv) to protect the rights, property, or safety of EM Capital Management, LLC and its affiliates, their partners, members, and employees, users of the Site, or the public.


EM Capital Management, LLC reserves the right to transfer any and all information we collect from users, or that we otherwise collect in connection with the Site, including, without limitation, to unaffiliated third parties, in the event of a sale or transfer of assets or portion of our business.


Where We Store Your Personal Data

The information that you give us or that we collect from you may be transferred to, and stored at, a destination outside the United States, Hong Kong  or the European Economic Area ("EEA"). It may also be processed by staff operating outside these areas and the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.



EM Capital Management, LLC employs industry standard security measures designed to protect against loss, misuse or alteration of personally identifiable information under our control. Unfortunately, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure. Therefore, while we employ industry standard security measures to protect your personally identifiable information, we cannot guarantee the security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the Site.


Links to Other Web Sites

The Site may contain links to Web sites owned by third parties. If you link to any such Web site, any information you disclose on that site is not subject to this Privacy Policy. You should consult the privacy policies of each Web site you visit. We are not responsible for the privacy practices of others. Any Site link to a Web site owned by a third party does not constitute an endorsement, approval, association, sponsorship or affiliation with the linked site unless specifically stated.


Children Under 13

The Site is not directed to children under 13 years of age, and we do not knowingly collect personally identifiable information from such children. If you are younger than 13, please do not provide any personally identifiable information while using the Site.Changes to Privacy PolicyWe reserve the right to update, revise, or otherwise change this Privacy Policy at any time and any changes to the Privacy Policy will be effective upon posting. Your use of the Site constitutes your acceptance of the currently posted Privacy Policy, and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms.


Access to Personal Information

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your information, please contact us at  We may charge a fee of £10 (or US Dollar equivalent) towards our costs in providing you with the requested information.


Contact Us; Opt-Out

If you would like to update or otherwise change the personally identifiable information you have provided to us, or if you no longer wish to receive materials from us or want your personally identifiable information removed from our databases, please contact us at


Alternatively, when you receive materials from us by email, you may make use of the “opt out” provision in such email to let us know that you no longer wish to receive such materials from us. If you have any questions about this Privacy Policy or our collection and use of your personally identifiable information, please contact us at


Credit for this Privacy Policy language is given to: BuckleySandler, LLP

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