PRIVACY POLICY

Effective January 19, 2021

Please read this privacy policy carefully before accessing or using this web site

This web site is owned and operated by Greater Than One (“Greater Than One”, “GTO”, “we”, “our” or “us”). GTO respects the privacy of visitors to our web site. This Privacy Policy describes types of personal data we collect about visitors to the web site, how we may use the personal data and with whom we may share it. This Privacy Policy also describes (1) the measures we take to safeguard the personal data we collect and (2) your rights and privileges concerning our collection, use, and disclosure of your personal data.

This Privacy Policy applies only to personal data collected through this web site and personal data collected by such third parties on our behalf once we have received such personal data. It does not describe the ways in which we may collect or use personal data obtained offline, or the collection, use or disclosure policies or practices of any third party.

Personal data Collection and Use

Greater Than One respects the privacy of visitors to our web site, and we recognize your need for appropriate protection and management of the personally identifiable information you share with us. You may visit our web site without telling us anything about yourself. If you contact us and choose to provide personally identifiable information, such as your name, address, telephone number or e-mail address, we will collect and use this personal data for the purpose for which you submitted it to us, namely to respond to your inquiry, to provide you with information that you have requested, to provide you with products or services, to bill you for products and services you request, to market products and services which we think may be of interest to you, or to communicate with you for other purposes which are evident from the circumstances or about which we inform you when we collect personal data from you.

Non-disclosure of Personal data

We will not sell, share, or otherwise distribute your personal data to third parties except as provided in this privacy policy. We may disclose your personal data to other GTO affiliates worldwide that agree to treat it in accordance with this privacy policy. Personal data may also be transferred to third parties who act for or on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or may otherwise be lawfully processed, such as services delivery, evaluating the usefulness of this website, marketing, data management or technical support. These third parties have contracted with us to only use personal data for the agreed upon purpose, and not to sell your personal information to third parties, and not to disclose it to third parties except as may be required by law, as permitted by us or as stated in this privacy policy.

Personal data collected from you may also be transferred to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat personal data in accordance with this privacy policy. Also, personal data may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad.

Your Privacy Rights

(access, review, correction, restriction and objection or deletion of personal data)

Whenever we process personal data concerning you, we take reasonable steps to ensure that your personal data is kept accurate and up-to date for the purposes for which it was collected. If you become aware that the personal data we maintain about you is inaccurate, incomplete, misleading, irrelevant or out of date, you have the right to access, review, update and/or rectify such Personal Data.

You may also object to or restrict the processing of your personal data if such processing is not reasonably required for a legitimate business purpose as described in this policy or in compliance with the law.

If you wish to contact us to receive further information regarding our use of your personal data, or if you wish to update and/or review your personal data, or if you wish to restrict and/or object to the processing of your personal data, please email us at privacy@greaterthanone.com or as specified in the “For Additional Information” section below.

We will attempt to provide any requested information or make requested changes to the extent allowable by applicable privacy laws. In any event, we will respond to you as soon as reasonably possible to advise you of the outcome of your request.

If we do not respond to your request in a timely manner, or if your request has been partially or wholly rejected or dismissed and/or you consider that your rights and freedoms with regard to the processing of your Personal Data have been infringed, you have the right to lodge a complaint with the competent Supervisory Authority.

Data Transfers

We may transfer the personally identifiable information we collect about you to third parties or within Greater Than One (to other GTO Affiliates worldwide). Such Data Transfers may include the transfer of Personal Data to countries other than the country in which the personal data was originally collected. Those countries may not have the same data protection laws as the country in which the personal data initially originated. When we transfer your personal data to such other countries, we will take appropriate measures to protect personal data in accordance with this Privacy policy and all applicable data protection laws.

Information Security

Greater Than One uses commercially reasonable administrative, technical, personnel-related, and physical security measures designed to safeguard the personal data in our possession against loss, theft and unauthorized use, disclosure, or modification.

Cookies

Periodically, some pages on this web site may use “cookies,” which are small files that the web site places on your hard drive for identification purposes. These files are used for web site registration and customization of your next time visit to our web site. You should note that cookies cannot read data off of your hard drive. Your web browser may allow you to be notified when you are receiving a cookie, giving you the choice to accept it or not. You can also refuse all cookies by turning them off in your browser. By not accepting cookies, some features on our web site may not fully function, and you may not be able to access certain information on this web site. However, by continuing to use the site without changing settings, you are agreeing to our use of cookies. If you require further information on how we use cookies in our website, please see the GTO Cookie Notice below.

We don’t deploy cookies through a web analytical service partner or Google Analytics.

GTO Cookie Notice

When you visit our web site, it may store or retrieve information on your browser, mostly in the form of cookies. You can find out more about cookies and how to control them in the information below.

By using our web site, you accept the use of cookies in accordance with this Cookie Notice. In particular, you accept the use of Third-Party Cookies for the purposes described below.

If you do not accept the use of these cookies please disable them following the instructions in this Cookie Notice, for instance by changing your browser settings so that cookies from this website cannot be placed on your computer or mobile device.

What is a cookie?

Cookies are small text files that are placed on your computer or other Web-accessing devices by our websites. These cookies allow us to distinguish you from other users of our website, and to enhance our website and your experience when you browse our website. We also collect information about your use of the Site through cookies and similar technology. Cookies allow us to recognize you and maintain your preferences when you return to our Site. Cookie technology collects “clickstream” data, which does not include personally identifying information, but which reflects your activities on the Site and helps us to customize our Site experience and anticipate what may be of interest to our users, by monitoring traffic in popular areas and modifying the services and information to meet customer demand.

To find out more about cookies, including how to see what cookies have been set and how to the delete them, visit www.allaboutcookies.org.

How to control cookies

If you don’t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set.

If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org (link is external), which contains comprehensive information on how to do this on a wide variety of desktop browsers.

Direct Marketing / Email Communications

In the event of direct marketing of our products and/or services, with any and all means, we will provide you with a method to opt out of or opt-in in receiving further marketing materials as required by law.

You may elect to receive email updates about developments regarding GTO’s products and/or services or about specific topics by completing the relevant electronic form on our website. If you decide, at any later time, that you no longer wish to receive such email communications from us, you may unsubscribe to any such contact list by using the relevant “Unsubscribe” link within the respective electronic communications channel, or by sending us an email entitled “Unsubscribe”.

Our Children’s Policy

We are committed to protecting the privacy of children. You should be aware that this web site content and services are not intended for, or designed to attract, children under the age of 18. No personal data should be submitted to GTO through the web site by visitors who are less than 18 years old.

CalOPPA Do-Not-Track Notice

GTO does not track its users over time and across third party websites and therefore does not respond to Do Not Track (DNT) signals. GTO does not authorize third parties to collect Personal Data directly from our users on our web site, such as through the use of third-party advertisements.

Links to Third Party Web Sites

As a convenience to our visitors, this web site may contain links to other web sites that we believe may offer useful information. Those links may include links to web sites that may perform services for us. The terms of usage and other conditions of use posted on those web sites, and not the policies and procedures we described here, apply to those web sites. We cannot guarantee the privacy standards of websites to which we link or be responsible for the contents of sites other than this one, and this privacy policy is not intended to be applicable to any linked, non-GTO site.

Information Security

Greater Than One uses commercially reasonable administrative, technical, personnel, and physical security measures designed to safeguard the personally identifiable information in our possession against loss, theft and unauthorized use, disclosure, or modification. Of course, despite these measures, we cannot guarantee perfect security of the networks, servers, and databases we operate or that are operated on our behalf.

DATA PRIVACY NOTIFICATION AND CONSENT FORM

FOR USE OF YOUR PERSONAL DATA BY GTO
FOR ELECTRONIC COMMUNICATIONS

Data controller

Greater Than One in the US (“GTO”) will act as a data controller and will process your personal data, as specified below, by determining purposes and means of its processing.

Types of personal data

GTO will process the following Personal Data as applicable:
Your contact details, including your name, address, e-mail address, country (altogether “Personal Data”)

Purposes of use of your Personal Data:

GTO shall use, process and store your Personal Data in order to send you non-customized email communications in relation to information in the area(s) of your choice and for no other purposes. Any other purpose will require your specific consent.

Scope of data flows

For the above-mentioned purposes, your Personal Data will be collected by Greater Than One, which is the US legally incorporated entity, and be transmitted to companies of the same group, with the adoption of adequate technical and organizational measures. GTO may forward the same data to third parties (individuals and/or companies) acting on its behalf as data processors.

The list of Data Processors may be requested by sending an email to privacy@greaterthanone.com.

The circulation of your Personal Data, considering the dissemination of the same, will reside on US servers. In this case, GTO will ensure that appropriate safeguards are in place to legitimize the transmission.

Free provision of data and free consent

You declare that you are eighteen (18) years old or above and legally competent.

You are free to provide such data or your consent to the relevant processing, and your refusal will solely mean that Greater Than One will not be authorized to collect and use your Personal Data.

Processing Mechanisms

Personal Data above will be processed electronically.

Data retention

If you would like your data to be deleted, please contact privacy@greaterthanone.com.

Exercise of Your rights:

You have the right to unsubscribe from receipt of emails in relation to information in the areas of your choice, amend your contact details and other personal data or change your areas choice at any time by clicking the unsubscribe link included in future email communications. You may at any time request to be informed about the personal data GTO holds about you, access your personal data or ask GTO to rectify, erase or block such personal data. For these purposes and for any other questions, please contact GTO at the following email address: privacy@greaterthanone.com; or by mail to GTO’s address: Greater Than One, 395 Hudson Street, 4th Floor, New York, NY 10014 USA.

You may at any time revoke your consent in writing and submit via email to the address specified above, without having to provide any reason.

In case your data protection-related requests are not handled in a timely and appropriate manner, you have the right to recourse to the competent data protection supervisory authority by lodging a relevant complaint.

To concretely exercise your data protection rights under applicable law in respect to third-party companies that provide services to Greater Than One, you may at any time request the list of such companies—full of their contact details—by sending an email to privacy@greaterthanone.com.

Consent

I have read and understood the content of the above notification and I expressly consent to the processing of my personal data by Greater Than One in the US as well as to the transfer of such data to entities established outside the EU, in accordance with the terms and mechanisms specified above, taking into consideration that my consent may be withdrawn at any time.

Privacy Policy Updates

Greater Than One may, at any time, revise this Privacy Policy by updating this posting. If we make revisions to this Privacy Policy, we will update the date at the top of this Privacy Policy. We will continue to use and/or disclose personal data in accordance with the policy in effect at the time the data is collected, unless you have agreed to have an updated version of the Privacy Policy apply to the data collected while a prior version of our Privacy Policy was in force.

For Additional Information

If you have any questions about this Privacy Policy, or concerns about the practices of this web site, or your dealings with this web site or any privacy-related matter in general, please email us at privacy@greaterthanone.com or contact us in writing at:

Greater Than One
Attention: Privacy Policy
395 Hudson Street, 4th Floor
New York, NY 10014 USA