Legal - Privacy & Cookie Policy

Privacy Policy

In the ordinary course of business, Pytheus LLC, and all of its affiliates (“Pytheus”) collect, use, and share personal information pertaining to its partners, employees, clients, and others. Obtaining this information is important to our ability to conduct our operations and to deliver the highest level of service, but we also recognize that you expect us to treat this information appropriately.

This policy describes the types of personal information that a relevant Pytheus entity may collect about you in compliance with applicable legal and regulatory requirements, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy.

HOW WE COLLECT INFORMATION ABOUT YOU

When you visit our website (the “Site”), our web servers collect the details of your operating system, browser version, domain name and IP address and the details of the web site you linked from to the Site. Our web servers may seek to place a “cookie” (a small data file) on your computer’s hard drive, which allows the server to recognize your computer when you visit again. If you prefer not to accept cookies, you have the option to reject them or to be alerted before one is placed.
There are parts of this Site where we may need to collect personal information from you for a specific purpose, such as to provide you with certain information you request. If you voluntarily submit information to our Site (for example, in a request for general information or through the submission of a business proposal), we may store and use any personally identifiable information, such as your name, phone number, fax number and e-mail address, for reasonable business purposes including, but not limited to, fulfilling your request and marketing and business communications and you expressly agree with the collection, use, storage and handling of your personal information as set out in this policy. If you do not provide all such information we need, we may not be able to give you the information you request.

When you contact us by email or phone about or in relation to our services or to respond to our communications we may record and use the personal information you provide, such as your name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.

Please also note we have certain responsibilities under the US Department of the Treasury Financial Crimes Enforcement Network (FinCEN) Customer Due Diligence (CDD) Rule and other rules and regulations, to verify the identity of clients and may need to make certain inquiries and obtain certain information from you for that purpose. You confirm that all information you supply will be accurate and that we may disclose such information as we consider necessary to comply with any reporting or legal and regulatory requirements.

By submitting your personal information to Pytheus, you acknowledge and agree to the processing set out in this policy, to the extent that such consent is required by applicable law.

COOKIES

Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties who receive data obtained from that website.

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.

Key concepts of cookies

First- and third-party cookies: whether a cookie is ‘first’ or ‘third’ party refers to the domain placing the cookie.

First-party cookies are those set by a website that is being visited by the user at the time (e.g., cookies placed by our Site domain).
Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie.

Persistent cookies: these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time the user visits the website that created that particular cookie.

Session cookies: these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

Why do we use cookies?

Cookies help us to provide customized services and information. We use cookies on all our Site to tell us, in general terms, how and when pages in our Site are visited, what our users’ technology preferences are – such as what type of video player they use – and whether our Site is functioning properly. Depending on their purpose, some cookies will only operate for the length of a single browsing session, whilst others have a longer life span to ensure that they fulfil their longer-term purposes (as explained in more detail below). Please note that, however long the cookies’ active life may be, you can delete cookies (and therefore stop any further data collection by them) as further described below.

In broad terms, we use cookies on our Site for the following purposes:

Analytical purposes: Analytical cookies allow us to recognize measure and track visitors to our Site and compile a record of this usage information. This helps us to improve and develop the way our Site works, for example, by determining whether visitors to the Site can find information easily, or by identifying the aspects of Site that are of the most interest to them.
Session management: The software that runs our Site uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, authenticate users and determine what features of the site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for the Site to function.

Please note that third parties may use cookies on our Site. The kind of cookies and the consequent data processing carried out by such third parties are regulated by their privacy policy.

How to delete and block our cookies

If you wish to remove cookies set by our Site from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Most web browsers allow some control of most cookies through the browser settings.

Changing your Cookie Settings. The browser settings for changing your cookies settings are usually found in the ‘options’ or ‘preferences’ menu of your web browser. In order to understand these settings, the ‘Help’ option in your internet browser will provide more details. Alternatively, the site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browsers, or you may consult the vendor documentation for your specific software.

However, cookies are necessary in order for you to be able to make full use of our Site. If you use your browser settings to block all cookies (including strictly necessary cookies), some of our Site’s functionality might be impaired. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit the Site.

Do Not Track

“Do not track” signals are preferences that users can set on their web browsers to limit how their activity is tracked across online services. The Site does not respond to “do not track” signals in your web browser.

Third-party cookies

When you visit our Site, you may receive cookies that are set by third parties. These may include cookies set by Google Analytics, WordPress or Vimeo.com. These cookies are used for the purposes described in this policy. We do not control the setting of these third-party cookies, so we suggest you might wish to check the third-party websites for more information about their use of cookies and how to manage them.

For more information about how Google Analytics collects and processes your data, please visit www.google.com/policies/privacy/partners.

USES OF COLLECTED INFORMATION

The purposes for which we use your personal information are:

to monitor, improve and administer the Site and the information and services provided on the Site;
to provide you with information on selected services that we think may be of interest to you (unless you have asked us not to do so);
for the management and administration of our business;
in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
to set you up as a client;
to provide you with our services;
to understand feedback on our services and to help provide more information on the use of those products and services quickly and easily;
to communicate with you in order to provide you with services or information about Pytheus and our products and services; or
to understand your needs and interests.

We do not collect personal information other than for the stated purposes above. When we use personal information we make sure that the usage complies with applicable law and the law allows us and requires us to use personal information for a variety of reasons.

These include where:

we need to do so in order to perform our contractual obligations with our clients;
we have obtained your consent;
we have legal and regulatory obligations that we have to discharge;
we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
the use of your personal information as described is necessary for our legitimate business interests, such as (i) allowing us to effectively and efficiently manage and administer the operation of our business; (ii) maintaining compliance with internal policies and procedures; and/or (iii) promoting our business and services.

DISCLOSURES OF YOUR PERSONAL INFORMATION WITHIN PYTHEUS

In order to provide efficient and reliable services and to improve service options available to you, we may share your personal information with our subsidiaries or affiliates. For this purpose, we may transfer the information you provide outside your country to a Pytheus entity in another country that does not have similar data protection legislation, however any personal information transferred within the Pytheus entities network will be held to applicable internal data protection standards. We have taken certain measures outlined below to try to ensure the security of your information. By submitting any information, you consent to these transfers.

DISCLOSURES OF YOUR PERSONAL INFORMATION TO THIRD PARTIES

We may share, and have shared over the past twelve (12) months, your personal information with other companies we have hired to provide services for us, or have hired us to provide services to them. Before we do so, we have taken the necessary steps to ensure that your personal information will be protected. These companies – our vendors – are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only on our behalf for the purposes that Pytheus has hired them and for which it has instructed them. We will not disclose your personal information to third parties if it is outside of the lawful purposes to use such personal information as set out above.

We may also release information about you if you direct us to do so, or if we are required or authorized by law to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding, or to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities.

Where you have provided personal information to us, you expressly consent to the sharing of such personal information with third parties for the purposes set out in this section.

RETENTION PERIOD AND SECURITY OF COLLECTED INFORMATION

How long we will retain your personal information for will vary and will be determined by the following criteria:

the purpose for which we are using it – Pytheus will need to keep the data for as long as is necessary for that purpose; and
legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.

Although Pytheus endeavors to take steps to provide a secure environment for users accessing the Site, due to the nature of the Internet, Pytheus cannot guarantee confidentiality or security of the personal and other information being provided. Pytheus makes no warranty whatsoever to you, express or implied, regarding the security of the Site, including with respect to the ability of unauthorized persons to intercept or access information transmitted by you through the Internet.

Pytheus welcomes your e-mail correspondence. However, it is possible that information transmitted to Pytheus may be read or obtained by other parties. Messages sent over the Internet cannot be guaranteed to be completely secure or error free as they are subject to possible interception, corruption, delays, loss or possible alteration. Pytheus is not responsible for them and will not be liable to you or anyone else for any damages or otherwise in connection with any messages sent by you to Pytheus or any message sent by Pytheus to you over the Internet. If you send e-mail (encrypted or not) to Pytheus over the Internet, you are accepting the associated risks, including lack of confidentiality.

Further, despite all possible security measures that Pytheus would take to keep this Site free from hacking and other interference, this Site like any other website is not free from such risks. Pytheus disclaims all liability on account of any loss or damage that any user may suffer or incur on account of any alteration or manipulation of any data or information accessed or downloaded from this Site.

Whilst Pytheus endeavors to take every reasonable precaution to ensure accuracy, security and confidentiality of information available through / on the Site, Pytheus cannot be held responsible for any consequence of any action(s) carried out by any authorized or unauthorized user.

If Pytheus becomes aware of a material breach which causes some of your personal information to be exposed, we will notify you to the extent reasonably possible in a timely manner.

CALIFORNIA RESIDENTS’ RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

Where applicable, California residents have the following privacy rights under the California Consumer Privacy Act of 2018 (the “CCPA”). For the purposes of this section of the policy “Personal Information” means any data that defines, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household, which is in the possession of, or is likely to come into the possession of any Pytheus entity.

These rights include, to the extent required by the CCPA and subject to verification and any applicable exceptions:

the right to request information regarding Personal Information collected about you as described below:
- the categories of Personal Information we have collected about you;
- the categories of sources from which that Personal Information we have collected;
- the specific pieces of Personal Information we have collected about you;
- the categories of third parties to whom such Personal Information was disclosed;
- the business or commercial purpose for which the Personal Information was collected;
the right to request that we erase your Personal Information in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Information but we are legally entitled to retain it; and
the right to be free from unlawful discrimination for exercising any of the rights above.

We will need to verify your identity prior to addressing or fulfilling a request made pursuant to the CCPA. Your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to Personal Information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

Please note that Pytheus does not, and will not, sell Personal Information collected about you.

You can exercise your rights by contacting us using the details listed below under the section titled “Contacting Us.”

PERSONAL INFORMATION HANDLED BY PYTHEUS ENTITIES IN THE EU

For the purposes of this section of the policy “Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of any Pytheus entity based in Europe (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Pytheus or any other person in respect of an individual.

Disclosure of your Personal Data within Pytheus

Where we transfer your Personal Data to another country outside the European Economic Area (“EEA”), we will ensure that it is protected and transferred in a manner consistent with legal requirements. We will protect the Personal Data being transferred outside of the EEA in one of the following ways:

the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
in other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.

How long we keep your Personal Data

How long we will hold your Personal Data for will vary and will be determined by the following criteria:

the purpose for which we are using it – Pytheus will need to keep the data for as long as is necessary for that purpose; and
legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

Your rights

If you are an EU-based individual, in all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Pytheus;
the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details listed below.

CHANGES TO THIS POLICY

This privacy and cookie policy is effective as of March 01, 2024. We may update this policy from time to time as the Site changes and privacy law evolves. If we update it, we will do so online and follow such other steps as required by applicable law.

CONTACTING US

If you have any questions about Pytheus’ handling of your personal information (including Personal Data), or about this policy, or if you wish to access your personal information or make a complaint about the way we have collected, used, held or disclosed your personal information, please contact us here:

compliance@pytheus.com