Privacy Policy

Last updated: October 1, 2022

Godspeed Capital Management LP (“Godspeed” or “The Company” or “we,” “us,” or “our”) respects your privacy, and we are committed to protecting it through our compliance with this policy (the “Privacy Policy”), as well as any applicable laws, standards, and regulations governing our collection and use of personal data. We want to be transparent with you regarding the information we collect, how we use and share it, and the controls we give you to access, update, and delete your information. This Privacy Policy sets forth Godspeed’s information collection and use practices for data collected online at the Godspeed website (the “Website”). It does not apply to information collected in connection with our offline activities or to information you provide to third parties, including through any application or content that may link to or be accessible from our website. This policy may change from time to time. Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates. If you do not agree to this Privacy Policy, do not use the Website or otherwise provide us with your personal information. By using the Website, you are acknowledging that that you have read, understood, and agreed to be bound by the Privacy Policy.

Collection and Use of Personal Information

You may view the Website without providing any personal information—such as your name, address, or date of birth— that, alone or in combination with other information, could reasonably be used to identify you.

We only collect personal information that you voluntarily provide to us through the Website. When you provide personal information to us via this or any other means, we will use this information to respond to your requests.

Generally, we do not share the personal information collected through the Website with third parties unless we have obtained your prior permission. However, we may share this information under the following circumstances without prior notice or permission: (i) with our business affiliates; (ii) with agents and contractors that assist us in administering the Website and in providing our products and services to you; (iii) in response to legal process or when we believe in good faith that the law requires it (for example, in response to a court order, subpoena or a law enforcement agency’s request); (iv) to protect the rights, property or safety of Godspeed, the Website, users of the Website and others; or (v) in connection with a transfer or sale of assets or ownership to another entity.

We do not consider the questions, comments, ideas or suggestions you submit to us through the Website to be personal information. By visiting the Website, you understand that we may use any information you transmit to us, subject to applicable law, for any purpose, including reproduction, disclosure, transmission, publication, broadcast and posting.

Use of Cookies and Other Tracking Technologies

Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when you load websites in a browser. Cookies are widely used to “remember” you and your preferences, either for a single visit (“session cookie”) or for multiple repeat visits (using a “persistent cookie”). While we currently do not use cookies on our Website, we may decide to use them in the future. In the event we do decide to use cookies on any Website, we may do so for a number of purposes, such as maintaining continuity during a user session, to gather data about the usage of our Website for research and other purposes and to enable our servers to recognize your computer so that your preferences and/or authentication credentials can be recognized so that you do not have to provide this information every time you return to our Website. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain of our Website’s features. We may occasionally use other companies to set cookies on our Website and gather cookie information for us. We will use the cookie information gathered by these companies in the same manner as stated above.

Links to Third-Party Websites

Godspeed may place hypertext links on the Website that connect to third party websites. Godspeed has no control over these linked sites or their content. Your use of such linked sites will be subject to such sites’ terms of use and privacy policies and not Godspeed’s, so be sure to read them before using such sites or transmitting any information to such sites.

Measures Taken to Secure Your Data

Godspeed follows generally accepted industry standards to protect the personal information submitted to us. No method of electronic storage, however, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect any personal information you submit through the Website, we cannot guarantee its absolute security.

Your European Data Rights

If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom, subject to applicable law, you may have the following rights in relation to personal information that we hold about you. To exercise these rights and controls, please contact info@godspeedcm.com.

Access: You have the right to ask for a copy of the personal information that we hold about you free of charge, however we may charge a reasonable fee, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.

Correction: You may notify us of changes to such your personal information if it is inaccurate or it needs to be updated.

Deletion: If you think that we should not be holding or processing your personal information anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.

Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.

Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.

Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.

Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you believe that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country. You can find details for your relevant EU national data protection authority at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

The hosting facilities for our website and operations are located in the United States. By providing us your data, you consent to its transfer and storage within the U.S. For the purpose of applicable EU laws, such third countries (including the U.S.) may not offer the same level of data protection as your country of residence. For further information about the safeguards used, please contact info@godspeedcm.com.

If you are located in the United Kingdom, as required under Article 27 UK-GDPR, Godspeed has appointed a representative who can be addressed for all questions related to the processing of personal data of persons in the United Kingdom. If you have a question or concern about how we may process your personal information in this region, please contact info@godspeedcm.com. You also have the right to make a complaint about us to the UK Information Commissioner’s Office (“ICO”): https://ico.org.uk/global/contact-us/.

Your Choices Regarding How We Use and Disclose Your Information

If you no longer want to receive marketing communications from us, you can unsubscribe by following instructions contained in the messages you receive, or by contacting us at info@godspeedcm.com.

You can decide whether or not to accept cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the services and functionalities may not work. To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

The Network Advertising Alliance (“NAI”) and the Digital Advertising Alliance (“DAA”) offer opt-out tools to help you manage your choices for participating companies that use Cookies for Interest-Based Advertising and cross-app advertising. For more information about these tools please visit: NAI Opt-Out Page and DAA Opt-Out Page.

“Do Not Track” is a preference you can set in your web browser to let the sites you visit know that you do not want them collecting information about you. Our site currently does not respond to “Do Not Track” settings.

If you need to update or correct any personal information that you have provided Godspeed through any Website, please contact us at: info@godspeedcm.com.

Questions About This Privacy Policy

If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us at info@godspeedcm.com.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age, and we do not knowingly collect personal information from anyone under 13 years of age. If you are under 13 years of age, please do not use or provide any information on our Website, use any of the interactive features of the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we may have any information from or about a child under 13, please contact us at info@godspeedcm.com.

Modifications of this Privacy Policy

Godspeed reserves the right to modify this Privacy Policy at any time. In the event that Godspeed modifies this Privacy Policy, Godspeed’s revised Privacy Policy shall be effective immediately upon the posting of such revised Privacy Policy. Your continued use of the Website following the posting of any revised Privacy Policy shall be deemed to conclusively indicate your acceptance of such revised Privacy Policy. Accordingly, you should periodically review this Privacy Policy.

Terms & Conditions of Use

General

By using this website (the “Website”), you agree to abide by these terms and conditions (the “Terms and Conditions of Use”). If you do not agree to abide by these Terms and Conditions of Use, do not use this Website. Godspeed Capital Management LP (“Godspeed”) reserves the right, in its sole discretion, to change, modify, add or remove any portion of this Website, including the Terms and Conditions of Use, in whole or in part, at any time. Changes will be effective when posted. By continuing to use this Website, you consent to such changes.

Godspeed authorizes you to view and access a single copy of the content available on this Website for your own use, including without limitation, text, written content, graphics, photographs, images, artwork, illustrations, trademarks, service marks, designs, logos, “look and feel,” audio or video clips, animations and software, and the selection and arrangement of any of the foregoing (collectively, “Content”), are protected under the copyright laws, trademark laws and other intellectual property laws of the United States and other countries.

Ownership

As between you and Godspeed, the Website, and all Content, information, products and services available on or through the Website, and the hardware and software underlying the Website, is the property of Godspeed and its applicable affiliates, content licensors and contractors and unless otherwise expressly agreed in writing between you and Godspeed, may only be used for your personal, non-commercial educational purposes. Except as expressly authorized in these Terms and Conditions of Use, you may not use, store, modify, reproduce, display, publish, distribute, transmit, sell, transfer, create derivative works of, publicly perform or otherwise exploit any Content or information available on or through the Website, in whole or in part, whether by electronic or other means, without our prior written consent. Any names, logos or other marks used on the Website may not be used or displayed without Godspeed’s prior written consent. Please be advised that Godspeed may record certain usage information, such as the number and frequency of visitors to this Website.

This Website may provide links to websites and services operated and/or owned by third-party entities. The availability of third-party links or services on the Website does not signify that Godspeed has any association with such third parties and does not constitute Godspeed’s endorsement of any information, content, products or services available through such third-party sites or services. Any inquiries about such third-party sites or services should be directed to the applicable third parties. Your use of any third-party websites and services may be subject to the applicable third-party terms and conditions of use and privacy policies. Godspeed does not have any control over these third parties and is not responsible for the actions of third parties. You acknowledge and agree that Godspeed is not responsible for and will have no liability for any damage or loss in connection with your transactions or interactions with any third parties. In addition, third-party websites and services may be linked to this Website, with or without Godspeed ‘s consent. Godspeed makes no warranty or representation regarding, does not endorse, and does not accept any responsibility for, any websites linked to or from this Website or the information appearing thereon or any of the products or services described thereon.

For Informational Purposes Only

The information, tools and material presented in this Website are provided to you for informational purposes only and are not intended to be, and should not be used or considered as an offer to sell or a solicitation of an offer to buy any interest in any investment vehicle managed by Godspeed or any company in which Godspeed or its affiliates have invested. Nothing on this Website constitutes professional or financial advice nor does any information on this Website constitute a comprehensive or complete statement of the matters discussed or the law relating thereto. Godspeed does not represent that the securities, financial instruments, products or services are suitable or appropriate for all investors.

Investment Performance Information

Information regarding the past performance of an investment is not necessarily indicative of the future performance of that investment, and no representation or warranty, express or implied, is made regarding future performance of that investment. The value of investments may fall or rise. Such information is provided solely to illustrate Godspeed’s investment experience, and processes and strategies previously used by Godspeed. Opinions and/or estimates reflect a judgment at the original date of publication by Godspeed and are subject to change without notice.

Disclaimers; Risks you Assume by Using this Website

Unless otherwise expressly set forth herein, Godspeed makes no representation that materials on this Website are appropriate or available for use in any location. If it is illegal or prohibited in your country of origin to access or use this Website, then you should not do so. Those who choose to access this Website do so on their own initiative and are responsible for compliance with local laws.

This Website and the information and materials on this Website are provided “as is” and without warranties or representations of any kind either expressed or implied and Godspeed and its affiliates disclaim all warranties, expressed or implied, including but not limited to, implied warranties of merchantability and fitness for a particular purpose. Godspeed does not warrant the accuracy, completeness or reliability of any information on this Website or that this Website will operate “error free.” No investment decisions may be made based on information contained on this Website. It is the user’s responsibility to evaluate the accuracy, completeness and usefulness of any content provided on this Website and to weigh any decision carefully. Your use of this Website constitutes your acknowledgement that you bear all risks associated with using such content. Godspeed makes no representations or warranties concerning any action taken by any person in reliance on the information provided through this Website. In no event shall Godspeed or its affiliates or service providers, or any of their respective partners, stockholders, members, managers, officers, directors, employees, agents, funds and such funds’ limited partners (collectively, the “Godspeed Parties”), be responsible for any damages, liabilities or injury, including indirect, incidental, special, punitive, multiple, consequential or other damages, however caused, arising out of your use of (or inability to use) this Website. Godspeed’s liability is limited to the maximum extent permitted by law and is limited even if Godspeed has been advised of the possibility of the damages, liability or injury that you suffer, including any damages, liabilities or injury caused by any failure of performance, error, omission, defect, interruption, delay in operation, computer virus, line failure or other computer malfunction.

If your use of this Website gives rise to any third-party claim against you or any Godspeed Party, you agree to (i) indemnify and hold harmless the Godspeed Parties with respect to any such claim, (ii) release the Godspeed Parties from any such claim and (iii) waive all laws that may limit the efficacy of such release. Godspeed reserves the right, at its own expense, to assume the exclusive defense and control of any matter for which you are required to indemnify the Godspeed Parties, and you agree to cooperate with our defense of these claims.

Governing Law; Jurisdiction and Venue

These Terms and Conditions of Use shall be governed by the laws of the State of New York, without giving effect to its conflict of law provisions. Any dispute relating to these Terms and Conditions of Use shall be brought solely in the state or federal courts located in Delaware and you agree that such courts shall have jurisdiction over you in connection with any such dispute. You must commence any cause of action you may have with respect to your use of this Website within one year after the claim or cause of action arises. If, for any reason, a court of competent jurisdiction finds any provision in these Terms and Conditions of Use to be unenforceable, that provision shall be enforced to the maximum extent permissible so as to effect the intent of these Terms and Conditions of Use, and the remainder shall continue in full force and effect. To the extent these Terms and Conditions of Use conflict with the terms and conditions of use relating to any password-protected area of this Website, the more specific terms and conditions of use relating to such password-protected area shall control.