Privacy Policy

Last updated March 2015

This is the privacy policy ("Privacy Policy") for the web site located at www.steel-castle.com (the "Site") made available by Steel Castle Capital LLC and its affiliates (collectively, "Steel Castle", "we", "us"). This Privacy Policy sets forth our policies regarding the collection, use and disclosure of certain information relating to your use of the Site. Your use of the Site, registering with our Site or providing your personally identifiable information ("Personal Information") to us signifies your understanding and acceptance of the terms of this Privacy Policy.

This Privacy Policy is incorporated into, and a part of, the Terms and Conditions located at http://www.steel-castle.com/termsofuse, which govern your use of the Site in general.

Steel Castle recognizes the importance of protecting your privacy and our Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the Personal Information you provide to us, and to assist you in making informed decisions when using the Site. We will try to assess this Privacy Policy against new technologies, business practices and our clients' needs. As we update and diversify our services and products, this Privacy Policy may evolve. Please check this page for updates periodically. We will try to, although we specifically disclaim any duty to, post any changes to this Privacy Policy before they become effective. If we make any material changes to this Privacy Policy, we will notify you here, by e-mail or by means of a notice on our Site's home page.

This Privacy Policy applies only to Personal Information collected via this Site, and does not apply to information that is collected offline (such as information you may provide over the phone or when meeting with a Steel Castle employee or representative).

If you have questions or concerns regarding this Privacy Policy or wish to exclude your Personal Information from our direct marketing programs, please feel free to contact us at info@steel-castle.com or by writing to us at Steel Castle Capital LLC, 2400 E. Katella Ave., Suite 370, Anaheim, CA 92806.

THE TYPES OF INFORMATION WE COLLECT

We may have areas on the Site where you can submit information to us, and we also have features that automatically collect information from the users of our Site. References to "Personal Information" contained in this Privacy Policy means your name, company name, account number, address, telephone number, e-mail address, subscription details (i.e., particular types of investments, markets or property types on which you request information), and any other information that personally identifies you or would permit us to contact you.

INFORMATION VOLUNTARILY PROVIDED BY YOU

Registration. When you visit or transact business on our Site, you may be required to register with us or be requested to provide us with personal and account information. When you provide us with this information, we will let you know how we may use such information. If you tell us that you do not want us to use this information as a basis for further contact with you (by accessing our opt-out procedure described below), we will respect your wishes. We may also offer options for you to sign up for our newsletters or other periodic updates. During the registration process, you must provide us with a member name (or login identification) and password, your name, address and phone number and a valid e-mail address. IT IS YOUR RESPONSIBILITY TO KEEP YOUR PASSWORD STRICTLY CONFIDENTIAL.

Contacting Us. You are always free to contact us with a question or problem related to your use of the Site. Our standard business practice is to retain any communications from our Site visitors to help us to serve each of you better.

Job Application Information. We may collect Personal Information from persons interested in applying for a job with Steel Castle. By submitting job application information, you agree that Steel Castle may use and disclose the information in order to consider your application. Job application information you submit will not be used for marketing purposes, but such information may be disclosed to our business units, agents, affiliates and other third parties as part of our consideration of your application. We do not authorize unaffiliated third parties to use your personal job application information for any purpose other than consideration of your application. Steel Castle is an equal-opportunity employer and does not discriminate on the basis of race, color, gender, ethnicity, sexual orientation, national origin or religion.

THIRD-PARTY INFORMATION PROVIDED TO US

Third Party Usage. You may separately share your Personal Information with other web sites or entities, such as those that create professional marketing lists, to receive special offers and promotions from their affiliates. These web sites or entities may agree to share your information with us. Whether or not any third party actually shares your information with us and to what extent they do share your information with us will depend on their agreement with us and their respective privacy policies. Steel Castle is not responsible for and will assume no liability if a partner or other web site or entity collects, uses or shares, any information about you in violation of its own privacy policy or applicable law.

Marketing Data. We may purchase marketing data from third parties and add it to our existing user database to better target our advertising and to provide pertinent offers in which we think you would be interested. We may also associate this marketing data to the Personal Information that you provide to us.

COMMUNICATIONS FROM US; NEWSLETTERS AND PROMOTIONAL OFFERS

In order to keep our users informed about our latest news, services and products, we may send e-mails and announcements to your personal e-mail address that you provided to us while registering on our Site. If you elected to opt–in to any of our e-mail lists and later decide that you no longer wish to receive newsletters or promotional e-mail from us, you may unsubscribe from such list by following the instructions contained in each e-mail we send to you to unsubscribe from such e-mail list.

Additionally, we use your Personal Information to provide you with the information or services that you have requested. We also may use this information in order to contact you as part of a promotion and to develop products, services, and marketing programs. This process may include combining personal data drawn from online and offline sources. We do not sell or rent to third parties any of the Personal Information that is provided to us through our Site, but we may share your Personal Information with our affiliates, agents, advisors and business partners, as permitted by law. We may need to share your information with these third parties in order to attempt to fulfill your requests. Please note that our affiliates and business partners may wish from time to time to extend special offers to you on their own behalf, as permitted by law.

AUTOMATIC DATA COLLECTION

Cookies. We use what are commonly called "cookies" when you use our Site. We use these cookies to identify you as a valid user, to ensure that no one else can sign on simultaneously with your account from another computer and to help us serve you better based on your registration preferences. We may also use cookies to help us facilitate any promotions or surveys that we provide. Third parties whose products or services are accessible on our Site may also use cookies, and we advise you to check their privacy policies for information about their cookies and other privacy practices.

Performance Tracking. We sometimes use tracking technology, such as web beacons, within the promotional e-mails that we send to our subscribers or advertisements for our Site. These performance tracking devices help us to track whether an e-mail recipient has completed an event, such as signing up for a promotional activity. Such information is non-personally identifying and collected on an aggregate level. We sometimes utilize third party service providers to help us track the activity within our Site. These third parties may use temporary cookies and/or web beaconing technology to facilitate such tracking but the data would not be tracked in a personally identifiable way.

WHEN AND WITH WHOM WE MAY SHARE YOUR INFORMATION

Vendors. We may share your Personal Information with companies acting as our authorized agents in providing our service (e.g., customer/support services) to you, all of which agree to use it only for such specified purposes. In that regard, we ask each vendor to agree to implement and maintain reasonable security procedures and practices appropriate to the nature of your Personal Information in order to protect your Personal Information from unauthorized access, destruction, use, modification or disclosure.

Sale of Company or Assets. The compilation of information collected through our Site is considered a trade secret of Steel Castle. As the owner of such information, we may disclose, transfer, or sell the information to one or more third parties as an asset of the company in conjunction with due diligence for or completion of a merger, reorganization, recapitalization, financing or sale of our company or a portion of our assets, debt or equity. Changes to this Privacy Policy might also result from changes in our corporate status.

Legally Compelled Disclosure. We will also disclose your Personal Information when required to do so by law, for example, in response to a court order or a subpoena or other legal obligation, in response to a law enforcement agency's request or in special cases when we have reason to believe that disclosing your Personal Information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (whether intentionally or unintentionally) our rights or property.

Bankruptcy. You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your Personal Information to be shared or transferred to third parties without your permission.

CONSENT TO PROCESSING

By providing any Personal Information to us, you fully understand and unambiguously consent to the transfer of such Personal Information to, and the collection and processing of such Personal Information in, the United States and other countries or territories. Your Personal Information will be stored and processed on our computers in the United States. The laws on holding Personal Information in the United States may vary and be less stringent than laws of your state or country. We will use commercially reasonable efforts to hold and transmit your Personal Information in a safe, confidential and secure environment. If you object to your Personal Information being transferred or used in this manner please do not register with or use the Site.

LINKS TO OTHER SITES

As indicated above, our Site may provide links to web sites not operated by Steel Castle. Steel Castle has no control or authority over these third party web sites, and we assume no responsibility for their privacy practices. We recommend that you review a third party web site's privacy policy before submitting information.

SECURITY

Steel Castle endeavors to protect the security of your Personal Information and your choices for its intended use. We use Secure Socket Layers or SSL technology to protect the transmission of sensitive Personal Information. We store your Personal Information on a secure server and use procedures designed to protect the Personal Information we collect from unauthorized access, destruction, use, modification or disclosure.

Although we will take (and request our third party providers to take) commercially reasonable security precautions regarding your Personal Information collected from and stored on the Site, due to the open nature of the internet, we cannot guarantee that any of your Personal Information stored on our servers, or transmitted to or from a user, will be free from unauthorized access, and we disclaim any liability for any theft or loss of, unauthorized access or damage to, or interception of any data or communications. By using the Site, you acknowledge that you understand and agree to assume these risks.

MODIFICATION OF YOUR CHOICES AND PREFERENCES

Opt-out right. If you would like to opt out of any of our marketing programs, or wish to withdraw your consent to us contacting you via your e-mail, fax or phone number, or if your personal details change, please contact us through one of the following: (i) by telephone, at (714) 786-5000 and ask for our Web Master; (ii) by facsimile, at (714) 786-6580; (iii) by e-mail, by following the Opt-Out instruction contained in the body of any marketing e-mail from us or by sending us an e-mail at info@steel-castle.com by including a copy of the e-mail you have received and by typing "Remove" in the subject line of your e-mail; or (iv) by mail, care of Web Master, Steel Castle Capital LLC, 2400 E. Katella Ave., Suite 370, Anaheim, CA 92806. Your election not to receive newsletters or promotional and marketing correspondence from us will not: (a) preclude us from corresponding with you, by e-mail or otherwise, regarding your existing or past relationship with us, or (b) preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your Personal Information in the course of maintaining and improving the Site.

ACCEPTANCE OF THIS PRIVACY POLICY

By using this Site, you signify your acceptance of our Privacy Policy. We reserve the right, at our discretion, to change, modify, add or remove portions from this Privacy Policy at any time, so visitors are encouraged to review this Privacy Policy from time to time. Your continued use of our Site following the posting of changes to these terms means you accept these changes.