Privacy Policy

1. Personal Information We Collect

In the twelve months before the effective date above, we collected the following categories of personal information from a website visitor, depending on how the visitor interacts with the website:

• Identifiers, such as name, email address, mailing address, and phone number, when a visitor submits a form, subscribes to a communication, or contacts us.
• Professional or employment-related information, such as job title, employer, and firm affiliation, when a visitor provides it.
• Internet or other electronic network activity information, such as IP address, browser and device type, page viewed, referring page, and interaction with the website, collected through the technology described in Section 4.
• Audio, electronic, or similar information, such as the content of a message sent through a chat feature, contact form, or similar channel.
• An inference drawn from the categories above about a visitor's interest in our content, where a technology described in Section 4 performs that function.

We do not knowingly collect personal information from a visitor under sixteen years old, and the website is not directed to a child. If you believe we have collected personal information from a visitor under sixteen without appropriate consent, contact us at law@lutycapital.com so we can address it.

2. How We Use Personal Information

We use personal information to: respond to an inquiry and communicate with a visitor; send a requested communication, such as a newsletter; operate, maintain, and improve the website; understand how a visitor uses the website; maintain the security and integrity of the website; comply with a legal obligation; and for another purpose, disclosed to a visitor at or before the point of collection.

3. How We Disclose Personal Information

We disclose personal information to the following categories of recipients: a service provider that operates a function of the website on our behalf, such as website hosting, analytics, or customer communication, under a contract that restricts its use of the information to the service it provides us; a professional advisor, such as legal counsel or an auditor, where necessary; a government authority or other third party, where required by law or necessary to protect the rights, property, or safety of Luty Capital or of another person; and a successor entity in connection with a merger, acquisition, or sale of assets.

We do not sell personal information for money, and we do not share personal information for cross-context behavioral advertising, as that term is defined under California law.

4. Cookies and Other Tracking Technology

We and our service providers use a cookie, pixel, and similar technology on the website for the following purposes:

• Essential technology that allows the website to function, such as maintaining a session or remembering a cookie preference.
• Analytics technology that helps us understand how a visitor uses the website.
• Functionality technology that supports a feature such as live chat.

A chat feature on this website may be provided by a third-party vendor and may record the content of a conversation to provide and improve that feature. We identify each provider we use for this technology, and the purpose of each cookie, which we keep current separately from this Privacy Policy.

5. Do Not Track

Some browsers offer a “Do Not Track” signal. No common industry standard exists yet for responding to that signal, and we do not change how the website operates in response to a browser’s Do Not Track signal.

6. Sensitive Personal Information

We do not use or disclose sensitive personal information for a purpose beyond what is necessary to operate the website and provide the service a visitor requests. We do not collect a category of sensitive personal information, such as a government identification number, precise geolocation, or health information, through the website, unless a visitor voluntarily includes it in a message sent through a contact form.

7. Your California Privacy Rights

To the extent the California Consumer Privacy Act applies to Luty Capital as a "business" under that law, and if you are a California resident, you have the right to:

• Know the category and specific piece of personal information we have collected about you, its source, our purpose for collecting it, and the category of third party with whom we disclose it;
• Delete personal information we have collected from you, subject to an exception recognized under California law;
• Correct inaccurate personal information we maintain about you;
• Limit the use or disclosure of sensitive personal information, to the extent Section 6 describes a use or disclosure beyond what is necessary; and
• Not receive discriminatory treatment for exercising a right described in this section.

Regardless of whether the California Consumer Privacy Act applies to us, we consider in good faith a request to know, delete, or correct personal information that a visitor submits to us.

To exercise a right described in this section, contact us at law@lutycapital.com. We verify your request using the information you provide and, where necessary, request additional information to confirm your identity. Where the California Consumer Privacy Act applies to us, we respond within forty-five days of a verifiable request and may extend that period once by an additional forty-five days where reasonably necessary, in which case we notify you of the extension within the initial forty-five-day period. An authorized agent may submit a request on your behalf with proof of your authorization.

8. California Shine the Light

A California resident may ask us, once each calendar year and at no charge, for a description of the category of personal information we disclosed in the prior calendar year to a third party for that third party’s own direct marketing purpose, and the name and address of each third party that received it. To make this request, contact us at law@lutycapital.com with "Shine the Light Request" in the subject line. We respond within thirty days of a request sent through the contact method we designate for this purpose, or within one hundred fifty days of a request sent through another method.

Based on the disclosure practices described in Section 3, we do not currently share personal information with a third party for that third party’s own direct marketing purpose.

9. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purpose for which we collected it, comply with a legal obligation, resolve a dispute, and enforce our agreement, after which we delete or de-identify it.

10. Security

We maintain an administrative, technical, and physical safeguard designed to protect personal information. No method of transmission or storage is completely secure; we cannot guarantee absolute security.

11. Other U.S. State Privacy Rights

If you reside in a state that grants a privacy right similar to those described in Section 7, we honor a verifiable request made under that state’s law using the process described in Section 7, to the extent that process satisfies the requirement of the applicable state law.

12. International Visitors

This website is operated from the United States. If you access it from outside the United States, your information will be processed in the United States, where privacy law may differ from the law of your country. Where required by applicable law, we rely on legally recognized data transfer mechanisms, such as the Standard Contractual Clauses, for a transfer of personal information outside the United States.

If you are a consumer based in the European Union, the United Kingdom, or Switzerland, contact us at law@lutycapital.com with a question about how we handle your information.

13. Changes to This Privacy Policy

We may update this Privacy Policy. We post the updated version on this page with a new effective date, and, where a change is material, provide additional notice appropriate to the change.

14. Contact Us

Questions about this Privacy Policy, or a request described in Section 7 or Section 8: law@lutycapital.com