Hycroft, LLC (“Hycroft”) is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through the website operated by us from which you are accessing this Privacy Policy (the “Website”). By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

Personal Information

Personal Information We May Collect

“Personal Information” is information that identifies you as an individual or relates to an identifiable person, including:

  • Name
  • Email address
  • Contact information
  • Telephone number
  • Social media account information
  • Any other personal information you voluntarily choose to provide to us.

How We May Collect Personal Information

We and our service providers may collect Personal Information when you make use of the “Contact” functionality.

How We May Use Personal Information

We may use Personal Information:

  • To respond to your inquiries and fulfill your requests.
  • To send administrative information to you, for example, information regarding the Website and changes to our terms, conditions, and policies.
  • To send you marketing communications that we believe may be of interest to you.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Website, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

  • To our affiliates (Hycroft UK Ltd and Hycroft LLP) and to North Sea Securities, LP for the purposes described in this Privacy Policy. Hycroft is the party responsible for the management of the jointly-used Personal Information. To our third party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, email delivery, auditing and other similar services.
  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER Information

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

  • Browser and device information
  • Information collected through cookies, pixel tags and other technologies
  • Demographic information and other information provided by you
  • Aggregated information

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

  • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Website you are using. We use this information to ensure that the Website functions properly.
  • Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Website, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Website, as well as for online tracking purposes. We can recognize your computer to assist your use of the Website. We also gather statistical information about the usage of the Website in order to continually improve the design and functionality, understand how the Website is used and to assist us with resolving questions regarding the Website. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Website. We may also use cookies in online advertising to track responses to our advertisements and we may use cookies or other files to track your use of other websites

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Website. For example, we may not be able to recognize your computer and you may need to log in every time you visit the applicable Website. You also may not receive advertising or other offers from us that are relevant to your interests and needs. We and our service providers, including Google Analytics, may use the information collected through cookies to analyze the use of the Website, so that we can improve the Website. To learn more about Google Analytics, go to http://www.google.com/analytics/index.html. To learn how you may opt out of having information about your use of the Website collected by Google Analytics, go to https://tools.google.com/dlpage/gaoptout.

  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Website to, among other things, track the actions of users of the Website (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Website and response rates.
  • IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Website, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other service. We use IP Addresses for purposes such as calculating usage levels of the Website, helping diagnose server problems, and administering the Website.
  • By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Website, (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We May Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

EMPLOYMENT

We collect Personal Information from individuals who wish to be considered for potential employment. By providing this Personal Information, you understand and agree that your Personal Information will be transferred to the United States and may also be transferred to additional countries, other than your country of origin, for consideration for employment.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website links. The inclusion of a link on the Website does not imply endorsement of the linked site or service by us or by our affiliates.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

  • Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by sending an email to info@hycroftadvisors.com stating that you choose to opt-out of marketing-related emails.
  • Our sharing of your Personal Information with affiliates for their direct marketing purposes:       If you would prefer that we do not share your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by sending an email to info@hycroftadvisors.com stating that you choose to opt-out of sharing of your Personal Information with Hycroft’s affiliates for their direct marketing purposes.

We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress, or delete Personal Information that has been previously provided to us by you, you may do so by sending us an email to info@hycroftadvisors.com stating what you would like Hycroft to do with your Personal Information.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

USE OF SERVICES BY MINORS

The Website is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Website.

CROSS-BORDER TRANSFER

The Website is controlled and operated by us from the United States, and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Website you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Website or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. Please take a look at the “Last Updated” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Website. Your use of the Website following these changes means that you accept the revised Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us by email at info@hycroftadvisors.com or please write to the following address:

100 Park Avenue,
16th Floor New York,
NY 10017.

Please note that email communications are not always secure; so please do not include credit card information or sensitive information in your emails to us.