Norbury Capital  B.V. d/b/a “Norbury” understands that your privacy is important to you. We are committed to protecting the privacy of your personally-identifiable information as you use this website. Norbury is the data controller and we are responsible for your personal data.

This Privacy Policy tells you how we protect and use information that we gather from you. By using this website, you consent to the terms described in the most recent version of this Privacy Policy. You should also read our Terms of Service to understand the general rules about your use of this website, and any additional terms that may apply when you access particular services or materials on certain areas of this website. 

“We,” “our” means Norbury and its affiliates. “You,” “your,” visitor,” or “user” means the individual accessing this site.

PERSONAL AND NON-PERSONAL INFORMATION

Our Privacy Policy identifies how we treat your personal and non-personal information.

Non-personal information is information that cannot identify you. If you visit this website to read information, such as information about one of our services, we may collect certain non-personal information about you from your computer’s web browser. Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information. 

Personal information is information that identifies you as an individual, such as your name, mailing address, e-mail address, telephone number, and fax number. We may collect personal information from you in a variety of ways: 

• When you send us an application or other form 

• When you conduct a transaction with us, our affiliates, or others 

• When we collect information about you in support of a transaction, such as credit card information 

• In some places on this website, you have the opportunity to send us personal information about yourself, to elect to receive particular information, to purchase access to one of our products or services, or to participate in an activity.

USE OF COOKIES

We may use cookies and related technologies, such as web beacons, to collect information on our website. 

A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you register with us, a cookie helps Norbury to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Norbury website, the information you previously provided can be retrieved, so you can easily use the features that you customized. 

A web beacon is a small graphic image that allows the party that set the web beacon to monitor and collect certain information about the viewer of the web page, web-based document or e-mail message, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small and invisible to the user, but, in general, any electronic image viewed as part of a web page or e-mail, including HTML based content, can act as a web beacon. We may use web beacons to count visitors to the web pages on the website or to monitor how our users navigate the website, and we may include web beacons in e-mail messages in order to count how many messages sent were actually opened, acted upon or forwarded.

Third-party vendors also may use cookies on our website. For instance, we may contract with third parties who will use cookies on our website to track and analyze anonymous usage and volume statistical information from our visitors and members. Such information is shared externally only on an anonymous, aggregated basis. These third parties use persistent cookies to help us to improve the visitor experience, manage our site content, and track visitor behaviour. We may also contract with a third party to send e-mail to our registered users/members.

To help measure and improve the effectiveness of our e-mail communications, the third party sets cookies. All data collected by this third party on behalf of Norbury is used solely by or on behalf of Norbury and is shared externally only on an anonymous, aggregated basis. From time to time we may allow third parties to post advertisements on our website, and those third-party advertisements may include a cookie or web beacon served by the third party. This Privacy Policy does not cover the use of information collected from you by third-party ad servers. We do not control cookies in such third-party ads, and you should check the privacy policies of those advertisers and/or ad services to learn about their use of cookies and other technology before linking to an ad. We will not share your personal information with these companies, but these companies may use information about your visits to this and other websites in order to provide advertisements on this site and other sites about goods and services that may be of interest to you, and they may share your personal information that you provide to them with others

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Norbury websites you visit.

INFORMATION THAT WE COLLECT, WHY AND HOW WE PROCESS IT

In running and maintaining our website we may collect, keep and process Customer Data, User Data, Technical Data and Marketing Data to provide you with access to this website or other products or services, to respond to your requests, to bill you for products/services you purchased, and to provide ongoing service and support, to contact you with information that might be of interest to you, including information about products and services of ours and of others, or ask for your opinion about our products or the products of others, for record-keeping and analytical purposes and to research, develop and improve products, services and content.

Communication Data, including any communication that you send to us through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record-keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data, including data relating to any purchases of products and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the products and/or services that you have purchased, and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data, including data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data, including data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business, grow our business and decide our marketing strategy.

Marketing Data, including data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions, to deliver relevant website content and advertisements to you, and to measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interest in studying how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

Personal information collected online may be combined with information you provide to us through other sources. 

We may also remove your personal identifiers (your name, email address, social security number, etc). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and we may treat it like other non-personal information. 

Finally, we may use your personal information to protect our rights or property, or to protect someone’s health, safety or welfare, and to comply with a law or regulation, court order or other legal processes.

CHILDREN’S PRIVACY

Norbury will not intentionally collect any personal information (such as a child’s name or email address) from children under the age of 18 (eighteen). If you think that we have collected personal information from a child under the age of 18 (eighteen), please contact us at thijs@norburycapital.com.

USE OF PERSONAL INFORMATION FOR COMMUNICATIONS

We may contact you periodically by e-mail, mail or telephone to provide information regarding products, services and content that may be of interest to you. In addition, some of the features on this website allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via e-mail. The e-mail response or confirmation may include your personal information. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.

HOW WE HANDLE SENSITIVE DATA

We often carry out surveys to better understand you/our audience, so that we can help you achieve your financial goals. Some of the questions we ask may provide us with sensitive data about you.

We require your explicit consent for processing sensitive data.

Where we are required to collect personal data by law or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver products or services to you). If you do not provide us with the requested data, we may have to cancel a product or service you have ordered, in which case, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at thijs@norburycapital.com.

In case we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We will not share your personal information collected from this website with an unrelated third party without your permission, except as otherwise provided in this Privacy Policy. In the ordinary course of business, we may share some personal information with companies that we hire to perform services or functions on our behalf. In all cases in which we share your personal information with a third party for the purpose of providing a service to us, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition. For some sorts of transactions, in addition to our direct collection of information, our third-party service vendors (such as credit card companies, clearinghouses and banks) who may provide such services as credit, insurance, and escrow services may collect personal information directly from you to assist you with your transaction. We do not control how these third parties use such information, but we do ask them to disclose how they use your personal information before they collect it.

We may cooperate with law enforcement authorities in investigating and prosecuting website visitors who violate our rules or engage in behaviour, which is harmful to other visitors (or illegal). We may disclose your personal information to third parties if we feel that the disclosure is necessary to protect our rights or property, protect someone’s health, safety or welfare, or to comply with a law or regulation, court order or other legal processes. As discussed in the section on cookies and other technologies, from time to time we may allow a third party to serve advertisements on this website.

If you share information with the advertiser, including by clicking on their ads, this Privacy Policy does not control the advertisers use of your personal information, and you should check the privacy policies of those advertisers and/or ad services to learn about their use of cookies and other technology before linking to an ad.

DATA SECURITY

We have implemented generally accepted standards of technology and operational security in order to protect personally-identifiable information from loss, misuse, alteration, or destruction. Only authorized personnel and third party vendors have access to your personal information, and these employees and vendors are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding how long to keep the data for, we consider its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure and its processing purposes.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they stop being customers.

In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS  

Under data protection laws, you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. You can learn more about these rights here.

HOW TO ACCESS, CHANGE, AND/OR DELETE YOUR PERSONAL INFORMATION

You may access, correct, update, and/or delete any personally-identifiable information that you submit to the website. You may also unsubscribe from mailing lists or any registrations on the website. To do so, please either follow instructions on the page of the website on which you have provided such information or subscribed or registered or contact us at thijs@norburycapital.com.

PUBLIC DISCUSSIONS

This site may provide public discussions on various business valuation topics. Please note that any information you post in these discussions will become public, so please do not post sensitive information in the public discussions. Whenever you publicly disclose information online, that information could be collected and used by others. We are not responsible for any action or policies of any third parties who collect information that users disclose in any such forums on the website. Norbury does not agree or disagree with anything posted on the discussion board. Also, remember that you must comply with our other published policies regarding postings on our public forums.

THIRD-PARTY LINKS

This site may contain links to other sites that provide information that we consider to be interesting. Norbury is not responsible for the privacy practices or the content of such websites.

CHANGES

Norbury reserves the right to modify this statement at any time. Any changes to this Privacy Policy will be listed in this section, and if such changes are material, a notice will be included on the homepage of the website for a period of time. If you have any questions about privacy at any websites operated by Norbury or about our website practices, please contact us at: thijs@norburycapital.com.