Introduction

Lazear Capital Partners, Ltd. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website lazearcapital.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect on this Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you acknowledge this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acknowledgement of those changes, so please check the policy periodically for updates.

Use by Children

Our Website is not intended for individuals under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, use any of the interactive or comment features of this Website, or otherwise 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 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 might have any information from or about a child under 18, please contact us at info@lazearcapital.com.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:
· By which you may be personally identified, such as name and email address, or any other identifier by which you may be contacted online or offline;
· That is about you but individually does not identify you; or
· About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information:
· Directly from you when you provide it to us.
· Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other technologies.
· From third parties, for example, our business partners.
Information You Provide to Us
The information we collect on or through our Website may include:
· Information that you provide by filling in forms on our Website. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website, or apply for a job.
· Records and copies of your correspondence (including email addresses), if you contact us.
· Your responses to surveys that we might ask you to complete for research purposes.
· Your search queries on the Website.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
· Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
· Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
By way of example, the Website uses Google Analytics, a web analytics service provided by Google LLC (“Google”). Google Analytics enables Google and its wholly owned subsidiaries to link information about your activity from our Website with activity from other sites or apps. Our use of Google Analytics is configured with “Restricted Data Processing” mode activated. Google indicates that a disclosure of how Google Analytics collects and processes data is available under the “How Google uses data when you use our partners’ sites or apps” heading, (located at www.google.com/policies/privacy/partners/.
Google also indicates that certain opt-out functionality may be available at the following link: https://tools.google.com/dlpage/gaoptout.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:
· To present our Website and its contents to you.
· To provide you with information, products, or services that you request from us.
· To fulfill any other purpose for which you provide it.
· To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
· To notify you about changes to our Website or any products or services we offer or provide though it.
· To allow you to participate in interactive features on our Website.
· In any other way we may describe when you provide the information.
· For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
· To our subsidiaries and affiliates.
· To contractors, service providers, and other third parties we use to support our business.
· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.
· To fulfill the purpose for which you provide it.
· For any other purpose disclosed by us when you provide the information.
· With your consent.
We may also disclose your personal information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
· To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Data Security

We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Please note that the safety and security of your information also depends on you. Unfortunately, the transmission of information via the internet is not completely secure. Although we use reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information provided or otherwise collected on or through our Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page If we make material changes to how we treat our users’ personal information, we will notify you through a notice on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Your State Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California’s “Shine the Light” law (California Civil Code § 1798.83) permits users of the Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at:
(614) 502-1411, or write to us at:

info@lazearcapital.com, or

Lazear Capital Partners, Ltd.
401 N. Front Street, Suite 250
Columbus, OH 43215

The information contained in this “Your State Privacy Rights” section of the policy applies solely to Website users who meet the definition of the term “consumer” as defined under the California Consumer Privacy Act, as amended, and the regulations adopted by the California Privacy Protection Agency, as applicable, pursuant thereto (collectively, the “CCPA”) and to other individuals entitled to analogous rights and disclosures under Colorado, Virginia, Nevada, Utah, Connecticut, Iowa, Indiana, or other applicable state law in each case if and solely to the extent applicable. Terms and correlative terms defined in the CCPA or other applicable state law contained in this section are intended to have the same meaning and effect as set forth in the CCPA or other applicable state law, as applicable.

We do not sell or share (as defined in the CCPA) personal information.

We do not use or disclose sensitive personal information for purposes other than those specified in section 7027, subsection (m) of the CCPA Regulations.

We do not have actual knowledge that we sell or share personal information of consumers under 16 years of age.

We may collect the personal information categories listed in the tables below. The tables also list, for each category, our expected retention period, use purposes, and whether we sell the information or share it with third parties for cross-context behavioral advertising.

Personal Information Category	Retention Period	Business Purpose	Sold or Shared
Identifiers, such as real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, number, or other similar identifiers.	2 Years	(1) Auditing. (2) Helping to ensure security and integrity. (3) Debugging. (4) Short-term, transient use. (5) Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments. (6) Providing advertising and marketing services, except for cross-context behavioral advertising, to you (7) Undertaking internal research for technological development and demonstration. (8) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the us, and to improve, upgrade, or enhance the Website or device that is owned, manufactured, manufactured for, or controlled by us.	No
California Customer Records personal information, such as name	2 Years	(1) Auditing. (2) Helping to ensure security and integrity. (3) Debugging. (4) Short-term, transient use. (5) Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments. (6) Providing advertising and marketing services, except for cross-context behavioral advertising, to you (7) Undertaking internal research for technological development and demonstration. (8) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the us, and to improve, upgrade, or enhance the Website or device that is owned, manufactured, manufactured for, or controlled by us.	No
Protected classification characteristics under California or federal law NONE	N/A	N/A	No
Commercial information NONE	N/A	N/A	No
Biometric information NONE	N/A	N/A	No
Internet or other similar network activity, such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	2 Years	(1) Auditing. (2) Helping to ensure security and integrity. (3) Debugging. (4) Short-term, transient use. (5) Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments. (6) Providing advertising and marketing services, except for cross-context behavioral advertising, to you (7) Undertaking internal research for technological development and demonstration. (8) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the us, and to improve, upgrade, or enhance the Website or device that is owned, manufactured, manufactured for, or controlled by us.	No
Geolocation data, such as physical location or movements.	2 years	(1) Auditing. (2) Helping to ensure security and integrity. (3) Debugging. (4) Short-term, transient use. (5) Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments. (6) Providing advertising and marketing services, except for cross-context behavioral advertising, to you (7) Undertaking internal research for technological development and demonstration. (8) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the us, and to improve, upgrade, or enhance the Website or device that is owned, manufactured, manufactured for, or controlled by us.	No
Sensory data None	N/A	N/A	No
Professional or employment-related information None	N/A	N/A	No
Non-public education information None	N/A	N/A	No
Inferences drawn from other personal information, None	N/A	N/A	No

Your Rights and Choices

The CCPA provides consumers with specific rights regarding their personal information. This section describes certain potentially applicable rights and explains how to exercise those rights.

Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:
· The categories of personal information we collected about you.
· The categories of sources for the personal information we collected about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
· sales, identifying the personal information categories that each category of recipient purchased; and
· disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
· The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete or Correct
You have the right to request that we delete, erase, correct, or object to or restrict processing of any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will verify the request, and review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if permitted by applicable law, including without limitation if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete
To exercise your rights to know or delete, or correct or restrict or object to processing described above, please submit a request by emailing us at: info@lazearcapital.com.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, submit a request by emailing us at info@lazearcapital.com.
You may also make a request to know or delete on behalf of your child by emailing us at info@lazearcapital.com.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at info@lazearcapital.com.
We endeavor to substantively respond to a verifiable consumer request within thirty days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
For the avoidance of doubt, Nevada consumers who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A, as amended, may submit a request by emailing us at info@lazearcapital.com.

Right to Non-Discrimination
The CCPA prohibits discrimination against you because of your exercise of any of the foregoing privacy rights, or any other rights under the CCPA, including by:
• Denying you goods or services;
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; or
• Providing you a different level or quality of goods or services; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
If you have any questions about this policy or need to access it in an alternative format due to having a disability, please contact us at any of the below methods:

(614) 502-1411, or write to us at:

info@lazearcapital.com, or

Lazear Capital Partners, Ltd.
401 N. Front Street, Suite 250
Columbus, OH 43215