Effective: April 10, 2019

Introduction

We at Aldabra Capital GmbH (“Aldabra Capital”, “we”, “us”, and “our”) know that your privacy is important. This Privacy Notice (the “Notice”) is designed to assist you in understanding how we will process your Personal Data in the following website (the “website”):

• outsidelens.com

Please read this Notice to learn more about the ways in which we collect and use your Personal Data. If we make any material changes to this Notice, we will notify you in accordance with the process described in the Changes to This Notice section below. By using our website, you consent to our processing of your Personal Data as described in this Notice.

Data Controllership

In the context of this Notice, Aldabra Capital acts as a data controller for the Personal Data we process.

Basis of Processing

Within the scope of this Notice, we may rely on one or more of the following legal grounds for processing of your Personal Data:

•  the need to perform our obligations under a contract or to perform related pre-contractual duties;
•  the legitimate interest of the “Participant” (i.e., the individual who is being evaluated), such as to demonstrate leadership abilities; and
•  any other ground, as required or permitted by law in the specific respective context.

Categories of Personal Data

Personal Data collected by us could include:

•  contact information, such as first and last name,
•  e-mail address,
•  and mailing address;
•  demographic data, such as date of birth, gender, and country of residence;
•  professional and educational data, such as job title/position, organizational level, and education;
•  your relationship to other parties using our website;
•  information that describes an individual’s leadership style, such as leadership qualities;
•  evaluation survey input;
•  IP address; and
•  any other data we collect about you that by itself may not be Personal Data but if combined with Personal Data could be used to personally identify you.

How We Receive Personal Data

We may receive your Personal Data through our website. We may also receive your personal data from third parties, in which case we will notify you, where required by applicable laws, without undue delay.

Purposes of Processing

We may process your Personal Data for the purposes of:

• enabling the use of the website;
• sending you email notifications which you have specifically requested.

Data Retention

Data processed in the website is retained indefinitely. However, we will always respect your request(s) that we delete your Personal Data, subject to the limitations described in this Notice.

Sharing Personal Data with Third Parties

We may use third party vendors to perform certain services on our behalf, such as web hosting providers.

We may share your Personal Data with these third-party vendors solely to enable them to perform the services for us. In providing such Personal Data, we require that those third-party vendors maintain at least the same level of security that we maintain for such Personal Data.

Other Disclosure of Your Personal Data

We may disclose your Personal Data:

•  to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;
•  if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change; and
•  to our subsidiaries or affiliates only if necessary for business and operational purposes.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any Personal Data, about our website users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.

If we must disclose your Personal Data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your Personal Data will maintain the privacy or security of your Personal Data.

Use of Cookies

We use cookies to store information on your computer. Cookies improve your navigation on this site and enhance your user experience. You may delete or otherwise control cookies. For more information please visit https://www.aboutcookies.org/.

Data Integrity and Security

We have implemented and will maintain technical, organizational, and physical security measures that are reasonably designed to help protect your Personal Data from unauthorized processing, such as unauthorized access, disclosure, alteration, or destruction.

If you use our website, you are responsible for protecting the security of your user name and password. You are responsible for any transaction made using your user name and password.

Access, Review & Opting Out

If you are a data subject about whom we store Personal Data, you may have the right to request access to, and the opportunity to update, correct, or delete, such Personal Data. If you have direct access to our website, you may do this by logging into our website and making changes in the My Account section, where applicable. Alternatively, you may always e-mail us at the e-mail address found in the Contact Us section of this Notice. We will implement your requested changes as soon as we reasonably can.

Privacy of Children

Our website is not directed at, or intended for use by, children under the age of 13. We do not knowingly allow anyone under 18 to provide any Personal Data on our website. Children should always get permission from a parent or guardian before sending personal information over the Internet. If you believe your child may have provided us with Personal Data, you can contact us using the information in the Contact Us section of this Notice and we will delete the Personal Data.

Changes to This Notice

We may update this Notice from time to time by posting a new version on this web page. You should visit this page occasionally to ensure you agree with any changes. We will post our revised Notice on this web page and update the “Effective” date above to reflect the date of the changes. By continuing to use our website after we post any such changes, you agree that you accept the Notice as modified.

Contact Us

If you have a complaint, dispute, or questions regarding this Notice or our treatment of your Personal Data, please email us on via the contact us section of the website www.outsidelens.com.