The terms and conditions of use set forth herein apply to each of the pages of this website (the "Site"). Please read these terms and conditions of use carefully before using this Site.

By using this Site, you signify your agreement with the following terms and conditions of use without limitation or qualification. Discerene Group LP, its subsidiaries and affiliates (collectively referred to herein as "Discerene," or "we") may at any time revise these conditions by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then-current terms and conditions of use to which you are bound.

Not an Offer of Advisory Services or Securities

This Site is limited to the dissemination of general information about the services provided by Discerene. This Site and the information contained herein do not constitute and should not be construed as an offering of advisory services or an offer to sell or solicitation to buy any securities or related financial instruments in any jurisdiction. Responses to any inquiry that may involve the rendering of personalized investment advice or effecting or attempting to effect transactions in securities will not be made absent compliance with applicable laws or regulations (including broker dealer, investment adviser, applicable agent, or representative registration requirements), applicable exemptions, or exclusions therefrom.

Jurisdictional Issues

Unless otherwise specified, the materials in or accessible through the Site are directed at residents of the United States, its territories, possessions, and protectorates. The Site is controlled and operated by Discerene from its offices within the state of Connecticut, United States of America.  Discerene makes no representation that material in or accessible through the Site is appropriate or available for use in other locations or that access to them where their content is located is not illegal and prohibited. Those who choose to access the Site from other locations do so on their own initiative and are responsible for establishing the legality, usability and correctness of any information or materials under any or all jurisdictions and the compliance of that information or material with local laws, if and to the extent local laws are applicable. You may not use or export the information or material in violation of U.S. export laws and regulations. The information provided in or accessible through the Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Discerene to any registration or other requirement within such jurisdiction or country.

​Investment Risks

Discerene makes no representation, and it should not be assumed, that past investment performance is an indication of future results. Moreover, wherever there is the potential for profit there is also the possibility of loss. Certain of Discerene’s strategies involve investments that are illiquid, are subject to a substantial risk of loss and are not suitable for many investors.

​Restrictions on Use of Materials

Except as otherwise permitted by Discerene, no materials from www.discerene.com or any website owned, operated, licensed, or controlled by Discerene may be copied, reproduced, republished, uploaded, posted, transmitted or distributed in any way. You may download material displayed on this Site for non-commercial, personal use only, provided you also retain all copyright and other proprietary notices contained on the materials. You may not distribute, modify, transmit, reuse, report, or use the content of this Site for public or commercial purposes, including the text, images, audio, and video, without Discerene’s prior written permission.

​Trademarks and Copyrights

This Site and all its content including, all trademarks, service marks, trade names, logos, and icons are proprietary to Discerene. Nothing contained on the Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark displayed on this Site without the prior written permission of Discerene or such third party that may own the trademarks
displayed on this Site. Your use of the trademarks displayed on this Site, or any other content on this Site, except as provided herein, is strictly prohibited.

Inquiries concerning use of Discerene’s trademarks, service marks, trade names, logos, icons, copyrights, or other intellectual property should be addressed to Discerene Group LP, attn. Legal Department, 2777 Summer Street, Suite 301, Stamford, CT 06905.

Images displayed on this Site are either the property of, or used with permission by, Discerene. The use of these images by you, or anyone else authorized by you, is prohibited unless specifically permitted herein. Any unauthorized use of the images may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes.

Login ID and Passwords

Access to specific areas of this Site may require the usage of a login ID and associated password. If you have a login ID and password, you are responsible for the activities which occur in connection with their usage and as such should take steps to protect them from misuse. If you become aware of any unauthorized use of, loss, or theft of your login ID and password, immediately inform a representative of Discerene.

Links to Other Websites

This Site may contain links to other websites. Discerene does not review or monitor any websites linked from or to the Site and will not be responsible for the content of any such linked website. If you decide to access the linked website, you do so at your own risk. Discerene is not responsible for the information, materials, or services obtained on or from such other websites and will not be liable in any respect for any damages arising from your access of such websites. Any such links are provided merely for the convenience of the users of the Site and the inclusion of the links does not imply any endorsement, representation, or warranty by Discerene with respect to any such website or the content or services contained through such websites. Furthermore, you agree not to link any websites to this Site without the express prior written consent of Discerene.

Discerene makes no warranties or representations as to the accuracy of this Site. Under no circumstances shall Discerene or any party involved in creating, producing, or delivering the Site be liable for any direct, incidental, consequential, indirect, or punitive damages that result from the use of, or the inability to use, the materials on this Site, even if a Discerene authorized representative has been advised of the possibility of such damages. Applicable law may not allow the limitation or exclusion of liability or incidental or consequential damages, so the above limitation or exclusion may not apply to you.

Discerene also assumes no responsibility, and shall not be liable for, any damages to, or viruses that may infect, your computer equipment or other property on account of your access to, use of, or browsing in this Site or your downloading of any materials, data, text, images, video, or audio from this Site.

Not an Offer‍

The information contained on this Site is for informational purposes only and is not intended as an offer or solicitation with respect to the purchase or sale of any security or of any fund or account that Discerene manages or offers.  No offer or solicitation will be made prior to the delivery of an offering document.  The information is subject to change without notice and Discerene has no obligation to update you.

Not the Basis for an Investment Decision‍

The information on this Site should not be the basis of an investment decision.  An investment decision should be based on your customary and thorough due diligence procedures, which should include, but not be limited to, a thorough review of all relevant term sheets and other offering documents as well as consultation with legal, tax, and regulatory experts.  Any person subscribing for an investment must be able to bear the risks involved and must meet the relevant suitability requirements.  Some or all alternative investment programs may not be suitable for certain investors.  No assurance can be given that any investment vehicle will meet its investment objectives or avoid losses.  A discussion of some, but not all, of the risks and apparent and potential conflicts of interest associated with investing in an investment vehicle can be found in such vehicle’s private placement memoranda, subscription agreement, limited partnership or limited liability company agreement, articles of association, or other offering documents as applicable, together with any supplements thereto (“Offering Documents”).

Future-Looking Statements and Opinions‍

The information on this Site is NOT intended to contain or express exposure recommendations, guidelines or limits applicable to any investment vehicle. The information on this does not disclose or contemplate our hedging or exit strategies. While investors should understand and consider risks associated with position concentrations when making an investment decision, the information on this Site is not intended to aid an investor in evaluating such risk. The terms set forth in the Offering Documents are controlling in all respects should they conflict with any other term set forth in other materials, and therefore, the Offering Documents must be reviewed carefully before making an investment and periodically while an investment is maintained.  Statements made on this Site include forward-looking statements which can be identified by the use of forward-looking terminology such as “may,” “will,” “should,” “expect,” “anticipate,” “target,” “project,” “estimate,” “intend,” “continue,” or believe,” or the negatives thereof or other variations thereon or comparable terminology.  These statements, including those relating to future financial expectations, involve certain risks and uncertainties that could cause actual results to differ materially from those in the forward-looking statements. Such statements, models, forecasts, estimates and analyses reflect various assumptions concerning anticipated results, which are subject to many inherent limitations, including business, economic and competitive uncertainties, and contingencies, many of which are beyond control, and which may or may not prove to be correct. In fact, there are frequently sharp differences between hypothetical performance results and the actual results subsequently achieved by any particular investment. Any projections expressed in this communication may differ or be contrary to opinions expressed by others. Financial projections are subjective in many respects and thus are susceptible to multiple interpretations and market conditions, which will fluctuate and may be superseded by subsequent market events or for other reasons. The information contained herein includes or is based upon various assumptions and opinions concerning various matters, the accuracy of which cannot be assured. Discerene does not take responsibility for such projections or forward-looking statements. No person or entity should rely on these forward-looking statements when making any investment decision. Certain information contained on this Site constitutes the opinions, intentions or beliefs of Discerene or its employees, which may be preceded by the terms “belief,” “opinion,” “consider,” “anticipate,” “seek,” or other similar terms. Such statements of “opinion” merely represent the state of mind of Discerene or its employees and should not be construed as a material statement of fact.

Performance Data and Strategy-Level Reporting‍

Unless otherwise indicated, performance data presented is estimated and unaudited. The performance information presented on this Site may have been generated during a period of extraordinary market volatility or relative stability in a particular sector.  Accordingly, the performance is not indicative of results that Discerene may achieve in the future. Past performance is not indicative of future results and there can be no guarantee that Discerene will achieve comparable results or be able to avoid losses. Any case studies discussed are intended to highlight the primary investment strategy, analysis and value add resources that Discerene employs and believes will be common between the case studies presented and future investments. Further, The Discerene will promptly, upon the request of a current or prospective investor, share performance results of the total portfolio from which the performance was extracted. If index information is included, it is merely to show the general trend in the markets in the periods indicated and is not intended to imply that the portfolio was similar to the indices in either composition or element of risk.  Material on this Site may indicate that it contains hypothetical or actual performance of specific strategies employed by Discerene, such strategies may comprise only a portion of any specific investment vehicle portfolio, and, therefore, the reported strategy level performance may not correspond to the performance of any investment vehicle for the reported time period.

Investment Risks‍

An investment in an investment vehicle managed by Discerene is not a complete investment program, is highly speculative and involves significant risk, including the risk of a complete loss of invested capital. Such investment vehicle may be leveraged and may engage in other speculative investment practices, including hedging, that may increase the risk of investment loss.

Not Legal, Accounting, or Regulatory Advice‍

The material on this Site is not intended to represent the rendering of accounting, tax, legal, or regulatory advice, and is not, and under no circumstances is to be construed as, a prospectus, a public offering, or an offering memorandum as defined under applicable securities legislation. A change in the facts or circumstances of any transaction could materially affect the accounting, tax, legal or regulatory treatment for that transaction. The ultimate responsibility for the decision on the appropriate application of accounting, tax, legal and regulatory treatment rests with the investor and his or her accountants, tax and regulatory counsel. Potential investors should consult, and must rely on their own professional tax, legal, and investment advisors as to matters concerning any investment vehicle managed by Discerene. Prospective investors should inform themselves as to: (1) the legal requirements within their own jurisdictions for the purchase, holding or disposal of investments; (2) and applicable foreign exchange restrictions; and (3) any income and other taxes which may apply to their purchase, holding and disposal of investments or payments in respect of the investments made by any Discerene investment vehicle.

WITHOUT LIMITING THE FOREGOING OR ANYTHING ELSE SET FORTH HEREIN, THE SITE AND ALL OF ITS CONTENTS ARE MADE AVAILABLE BY DISCERENE "AS IS"; WITH ALL FAULTS, AND WITHOUT ANY WARRANTIES WHATSOEVER, EXPRESS OR IMPLIED. ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR ANY PARTICULAR PURPOSE, NON-INFRINGEMENT, TITLE, UNINTERRUPTED USE, QUIET ENJOYMENT, SYSTEM INTEGRATION, OR ACCURACY, SECURITY OF INFORMATION, OR RELIABILITY, ARE SPECIFICALLY EXCLUDED AND DISCLAIMED. DISCERENE MAKES NO WARRANTY THAT THE SITE, IN WHOLE OR IN PART, WILL MEET USERS’ REQUIREMENTS. USERS OF THE SITE ASSUME ALL RISK AS TO THE QUALITY, ACCURACY, SUITABILITY, AVAILABILITY AND PERFORMANCE OF THE SITE AND ITS CONTENTS AND ACKNOWLEDGE THAT THE SITE AND ITS CONTENTS MAY BE REVISED, ALTERED AND CHANGED FROM TIME TO TIME IN THE SOLE DISCRETION OF DISCERENE. DISCERENE DOES NOT REPRESENT OR WARRANT THAT ANY SITE CONTENT WILL OPERATE CONTINUOUSLY OR WILL BE UNINTERRUPTED OR ERROR-FREE, OR THAT ANY DEFECTS WILL BE CORRECTED, OR THAT THIS SITE OR ANY SITE REFERRED OR LINKED TO HEREIN IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.

​Limitation of Liability

DISCERENE ASSUMES NO LIABILITY FOR LOSS OR DAMAGE RESULTING FROM ANY USE OF OR RELIANCE UPON THE SITE OR ITS CONTENTS. IN NO EVENT WILL DISCERENE BE LIABLE FOR ANY LOST PROFITS, LOST SAVINGS, LOST DATA, BUSINESS INTERRUPTION, OR OTHER DIRECT, INDIRECT, EXEMPLARY, PUNITIVE, SPECIAL, CONSEQUENTIAL OR INCIDENTAL DAMAGES, OR CLAIMS (WHETHER IN CONTRACT, IN TORT, OR OTHERWISE) ARISING OUT OF OR RELATING TO THE SITE, ITS CONTENTS, THE USE THEREOF, OR THE INABILITY TO USE THE SITE, EVEN IF DISCERENE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH LOSS OR DAMAGE. IF ANY WARRANTY DISCLAIMER OR LIMITATION ON LIABILITY IN THIS AGREEMENT IS FOUND TO BE INVALID OR UNENFORCEABLE FOR ANY REASON, THEN THE AGGREGATE LIABILITY OF DISCERENE UPON ANY CLAIM (WHETHER IN CONTRACT, IN TORT, OR OTHERWISE) ARISING OUT OF THE SITE, ITS USE, OR ITS CONTENTS SHALL NOT EXCEED ONE THOUSAND DOLLARS
($1,000.00).

​Indemnification

You agree to defend, indemnify, and hold Discerene and its directors, officers, members, partners, principals, employees, agents, and representatives harmless from any and all claims, liabilities, costs, and expenses, including, without limitation, reasonable attorneys; fees, arising in any way from (i) your use of the Site, in whole or in part, or (ii) your breach or violation of law or any provisions contained herein. We reserve the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, and in such case, you agree to cooperate with any such defense.

Governing Law and Consent to Jurisdiction

These terms and conditions of use shall be governed by and construed in accordance with the laws of the state of New York applicable to agreements made and to be performed wholly within such state. You agree that any dispute or action at law or inequity arising out of or relating to these terms and conditions of use or your use of the Site shall be commenced only in the state or federal courts located in New York City, New York and you hereby consent and submit to the personal jurisdiction of such courts for the purposes of any such dispute or action.

​Waiver

No waiver by Discerene of any right under or term or provision of these terms and conditions of use will be deemed a waiver of any other right, term, or provision of these terms and conditions of use at that time or a waiver of that or any other right, term, or provision of these terms and conditions of use at any other time.

Integration and Severability

If any provision of these terms and conditions of use is found to be invalid, unlawful, void or for any reason unenforceable then that provision shall be deemed severable from these terms and conditions of use and shall not affect the validity and enforceability of any remaining provisions. These terms and conditions of use represent and constitute the entire agreement between Discerene and you relating to the subject matter discussed herein.

Termination

These terms and conditions of use are effective until terminated by Discerene, provided that you may terminate the terms and conditions of use at any time by destroying all information and materials obtained by you or on your behalf from the Site and all related documentation, copies, and installations whether made under these terms or otherwise. Such termination by you will not be effective if Discerene, in its sole discretion and without notice to you, determines that you failed to comply with any term or condition stated herein. Upon termination of these terms you must destroy all information and materials obtained by you or on your behalf from the Site and all associated documentation, copies, and installation whether made under these terms or otherwise.

This Privacy Policy sets forth how Discerene Group LP, its affiliates, and the investment vehicles under their management collect and process personal information about you. We are providing this Privacy Policy to you to satisfy disclosure requirements required under data protection and privacy regulations adopted by regulatory authorities in the jurisdictions in which Discerene conducts business. These regulations require that Discerene (as a data controller) ensures that you understand how we collect, use, process, and share your personal information. Please note that certain of these disclosures may not apply to you.

​This Privacy Policy applies to visitors to this Site, including job applicants, as well as visitors to our offices, individuals who call Discerene personnel in certain of our offices, third-party service providers, vendors and suppliers, business contacts, prospective clients, and investors. If you provide personal information to us about any person other than yourself, you must ensure that the other person understands how their information will be used. You may only provide us with that person's details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.

If you visit this Site, you should review this Privacy Policy carefully and in conjunction with the Terms and Conditions of the Site, which detail other important information surrounding your use of the Site.

Collection of Personal Information

We collect, and have collected over the last twelve (12) months, the following information from the following categories of individuals.

Website Visitors

Depending on how you choose to use the Site, we may need you to provide the following information:

• to contact us - name, address, e-mail address, telephone number, and other contact details along with any other information you choose to provide;
• to login to our client/investor portal - username and password (if applicable); and
• to subscribe to certain communications - email address and country of residence (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication).

For information on technology and cookies used on the Site, see the section entitled “Use of Technology and Cookies” below.​

‍Office Visitors and Callers

When you visit Discerene offices or telephone certain Discerene employees, we may collect certain personal information such as:

• name, organization, and other contact details;
• video images of you in certain areas of the buildings in which our offices are located from CCTV footage;
• date and time of your visit to Discerene offices; and
• voiceprints and telephone numbers

Third-Party Service Providers, Vendors, and Suppliers

In the process of engaging third-party service providers, vendors, and suppliers, Discerene may collect certain personal information about them and/or about their individual representatives and associates including:

• name, job title, telephone number, email address, and other contact details;
• the name of the third-party service provider, vendor, or supplier with whom you are associated and its address; and
• information required to process payments, such as a tax ID number and wire instruction details.

We may also collect personal information about you from companies who maintain anti-money laundering and terrorism sanction screening and know your customer databases.

​Recruitment (if applicable)​

When you submit a job application through our Site or a third-party website for an open job position, we will process your personal information for purposes of recruitment.

​Business Contacts, Prospective Clients, and Investors (if applicable)

Discerene may collect personal information about individuals or representatives of organizations with whom Discerene has a business relationship (or with whom Discerene seeks to establish a business relationship), as well as prospective clients and investors. Such information may include:

• name, address, telephone number, email address, and other contact details;
• organization name and address, job title; and
• investor type, strategy, product, and communication preferences (if you choose to receive marketing communications, you will have the option to opt out of receiving such communications at any time by contacting us or unsubscribing via a link in the particular communication).

Use of Personal Information

Your personal information will be processed: (i) in order to comply with our legal and regulatory obligations; (ii) because we need the information for reasons of substantial public interests; (iii) in order to comply with our obligations under contract; and/or (iv) because we have a legitimate business interest in processing it, including for the following purposes (as applicable):

• to respond to your questions and handle and resolve complaints;
• to perform research with respect to the usage of the Site (applicable to Site visitors);
• to personalize and enhance your experience on our Site (applicable to Site visitors);
• to fill open job positions as part of a recruiting process (if applicable);
• to maintain the security of our premises, personnel, assets, systems, and intellectual property, and to manage access to our premises and our disaster recovery procedures (applicable to office visitors);
• to pay you for your services (applicable to third-party service providers, vendors, and suppliers);
• in order to comply with our obligations in connection with record-keeping requirements and applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of jurisdictions in which Discerene conducts business (applicable to office callers, third-party service providers, vendors, and suppliers);
• to maintain and provide appropriate management of our relationship with you;
• to exchange mail correspondence or documentation which may involve providing your contact details to couriers and service providers in charge of the delivery service;
• to engage your services in the future (applicable to third-party service providers, vendors, suppliers, and business contacts);
• to contact you to set up meetings and/or phone calls between you and your Discerene business contact(s); and
• to process your subscription requests and to send marketing communications about Discerene to you (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication) (applicable to Site visitors, business contacts, prospective clients, and investors).

​​Where required by applicable law, we will obtain your prior consent before sending you direct marketing communications. For information on how we use and process technology and cookies on the Site, see the section entitled “Use of Technology and Cookies” below.

Where Discerene is relying on its legitimate interests as the ground for processing your personal information, we must carry out an assessment to ensure our interests do not override any rights you may have.

​Sharing and Transfer of Personal Information

We may share, and have shared over the last twelve (12) months, the personal information we receive about you with the following categories of recipients:

• Discerene affiliated entities;
• third-party service providers, vendors, contractors, and agents of Discerene as part of normal business operations, including providers:
  • engaged to assist in know your customer and identity verification and anti-money laundering and terrorism screening (applicable to third-party service providers, vendors, and suppliers);
  • of accounting, banking, and other data processing services;
  • of information technology services and platforms/applications;
  • of courier services or other package delivery services;
  • of call recording and storage services (applicable to office callers);
• third-party outsourcing providers;
• building security personnel (applicable to office visitors);
• third parties acting on your behalf such as consultants and other agents;
• governmental authorities and/or law enforcement officials where required;
• financial institutions to wire payments to you (applicable to third-party service providers, vendors, and suppliers);
• advisors who provide audit, financial and legal advice to Discerene; and
• other parties to a merger, acquisition, reorganization, funding/investment round or similar transaction or proceeding involving Discerene, or steps in contemplation of such activities.

Discerene may also disclose your personal information to particular parties pursuant to your express consent, to fulfill your instructions, to comply with applicable laws and regulations or to fulfill other applicable requirements.

Personnel employed by service providers generally may have access to your personal information for the purpose of performing duties for Discerene but are prohibited from using such information for other purposes.​

Your personal information may be transferred to or shared with entities in countries where data protection laws might not exist or be of a lower standard than in the United States. This includes the transfer of personal information among Discerene affiliated entities and the jurisdictions in which they operate. As of the date of this notice, Discerene has affiliates within the United States and the Cayman Islands. In addition, we may transfer or share your personal information with non-affiliated parties located in the same jurisdictions as Discerene entities as well as other jurisdictions and information may be stored and processed manually and electronically through global systems and tools for the purposes outlined in this Privacy Policy.​

We do not, and will not, sell personal information collected about you.

Safeguarding of Personal Information​

Discerene maintains established internal policies and procedures, as well as physical and electronic safeguards that comply with applicable standards to safeguard access to personal information in our possession from accidental or unlawful destruction, loss, alteration, unauthorized use, or disclosure. We endeavor to limit access to personal information about you to those employees, agents, and other authorized parties who need to know the information to enable Discerene to provide products or services to you. Please note that such safeguards, however, do not guarantee that personal information transmitted via the Internet or stored in our systems or is otherwise under Discerene’s care will be absolutely safe from unauthorized use or intrusion from third parties due to the inherent nature of the Internet.

​Retention of Personal Information

​We will retain your personal information only for as long as we consider necessary in connection with the purposes set out in this Privacy Policy, unless applicable law or regulations require or permit a longer retention period, as described further in our document-retention policies. In addition, we may retain your personal information for the duration of any period necessary to establish, exercise, or defend any legal rights.

​Your Rights

The rights described in this paragraph are applicable to you only if you reside in a jurisdiction where the provision of such rights is required by the data protection, privacy laws, and regulations of the governing regulatory authority. As such, where required by applicable law or regulation, you may ask Discerene for a copy of your personal information, to correct it, to erase it or to transfer it to other organizations. You may also have rights to object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent. In particular, you have rights to object to direct marketing at any time.

You should also be aware that these rights may be limited (for example, access to personal information may be denied if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information). In addition, Discerene may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your personal information. Where we must collect and process personal information in order to comply with applicable law or enter into and perform services under an agreement with you, if you do not provide the personal information we may not be able to enter into the agreement or provide services as contemplated by any agreement we have in place. Where we are not able to fulfill a request you make because your rights are limited, we will inform you of the reasons as to why when responding.

​Depending on the type of personal information processing described in this Privacy Policy, we may be operating as a sole or joint controller. If operating as joint controllers, the entities jointly determine the means and purposes of the processing of your personal information. However this has no impact on your rights and how you can exercise them against either of the joint controllers by contacting us as set out below.

​Should you have any questions or requests in relation to your rights, please contact us with this inquiry form.  We will attempt to deal with all requests at the earliest opportunity. In addition, if you have unresolved concerns you have the right to complain, where permitted, to competent data protection authorities.

​Where applicable, if you are a California resident you may have the following rights under the California Consumer Privacy Act of 2018 (the “CCPA”) in relation to “personal information” we have collected about you as defined in the CCPA; these rights are, to the extent required by the CCPA and subject to verification and any applicable exceptions:

• Right to Know/Access: You have the right to request that we disclose certain information to you about our collection and use of certain personal information about you as described below:
  • the specific pieces of personal information collected;
  • the categories of personal information collected;
  • the categories of sources from whom the personal information is collected;
  • the purpose for collecting the personal information; and
  • the categories of third parties with whom we have shared the personal information.
• Right to Delete: You have the right to request that we delete your personal information.  To do so, please submit a request to us by using this web form.
• Freedom from Discrimination: You have 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 your request.

​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.

Use of Technology and Cookies

Technology

When you visit our Site or open our emails, we may collect certain information by automated means (such as by cookies, web-server logs, web beacons and JavaScript). The information we may collect in this manner includes your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our Site, and dates and times of Site visits. We also may use these and similar technology in emails we send you to collect certain information, such as whether you opened or clicked on links in our email.

​We may use third-party web analytics services on our Site. These service providers help us analyze how visitors use the Site. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers.

​The providers of third-party plugins and widgets on our Site, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Site and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.

​Cookies

Discerene may collect certain information about you through the use of cookies. Cookies are pieces of information or files placed on your device’s disk that provide information including how and when pages on the Site are accessed by users. To find out more about cookies please visit www.allaboutcookies.org, or see www.youronlinechoices.com which contains further information about behavioral advertising and online privacy.

We use the following types of cookies on our Site (note that some cookies may fall into multiple categories):​

Test Cookies

‍These cookies are simply to test whether or not your browser supports cookies. It stores a simple “True” or “False” value. If True, then the below cookies are applied.

Tracking Cookies

‍These cookies are used to track anonymous user movement throughout the site for statistical purposes. For example, it may track the duration of a user’s visit to a certain page or for example, to allow Discerene to determine the number of users that visited a given page of the Site, or that read a certain press release.

Required Cookies‍

‍These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for, such as remembering your login details, cannot be provided.

Analytics Cookies

‍These cookies remember choices you make, such as the duration of your session. These can then be used to provide you with an experience more appropriate to your selections, and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized (such as the IP address through which you visit the Site) and they cannot track your browsing activity on other websites. Discerene uses a Google Analytics cookie to collect this information; you have the right to opt-out of having the Google Analytics cookie placed on your browser.​

When visiting the Site, you may receive a pop-up banner informing you of our use of cookies.

You may also be asked to agree to allow us to use particular analytics cookies while you browse the Site. If you receive our cookie consent banner, you may click “Cookie Consent Tool” to see which cookies we have on our Site and choose whether to accept or opt-out of certain cookies while on the Site. Should you choose not to give your consent for us to use some or all of the analytics cookies on our Site, these cookies will not be placed on your browser while you browse the Site.

You may configure your browser to set preferences regarding cookies such that you can have your computer warn you each time a cookie is sent. Note that you may decline placement of cookies if your internet browser permits, though this may impact your experience of using the Site, and certain portions of the Site may be inaccessible to you if you choose to do so. You may at any time delete any cookies from your hard drive. Aggregated data gathered from cookies is used by Discerene to help maintain and improve the information provided on this Site for users. Discerene may also employ other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We take seriously the protection of your personal information and have contracts in place with these authorized third parties to protect your personal information. We may also use these technical methods in HTML e-mails that we send Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. Discerene may collect the information from use of these technical methods in a form that is personally identifiable.

During some Site visits, Discerene may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page. Discerene may use this information to measure Site activity, to develop ideas for improving the Site and for any other purpose to the extent permitted by applicable law.

It is always your choice to decide what cookies are stored on your device and whether you choose to delete them. By accepting cookies that are stored on your computer when you visit our Site, we infer that you have accepted the use of cookies as explained in this Privacy Policy. Please note that while you are free to decline cookies, certain features of this site may be difficult or impossible to use and offerings will not be personalized.

Managing Cookies

You can manage cookies using various means:

Browser Setting

‍Your browser likely supports a variety of settings to control the cookies that are set on your computer or device and to delete cookies. These settings are typically found under the “Tools”, “Settings”, or “Options” menus. You can also check the “Help” menu of your browser to learn how to change the cookie preferences through your browser settings. Note that you will need to manage the settings for each browser and device you use. Further information from several popular browsers can be found at the following sites:

• Apple Safari
• Google Chrome
• Microsoft Internet Explorer
• Microsoft Edge
• Mozilla Firefox

Online Tools

Some third parties allow you to manage cookies through online tools such as Network Advertising Initiative, Digital Advertising Alliance, Your Online Choices, Adobe Flash, and the Interactive Advertising Bureau (IAB) Europe. In order to opt out of Adobe and Google Analytics cookies across our Site, visit Adobe Analytics, Google Analytics, and Yandex Metrica. If you choose to do so, you will not necessarily see fewer ads. However, the ads you see may be less relevant to your interests.

Browser Extensions

‍Some third parties have created software that can be added to your web browser to manage their or third-party cookies such as Google Analytics and Evidon, Inc.

Our reference to any third party or their software, products, and/or services is not an endorsement by us of such third party, software, products, and/or services and we disclaim any liability for the use or operation of any third-party software, products, and/or services.

Do Not Track

We do not track visitors of the Site over time and across third-party websites to provide targeted advertising and therefore the Site does not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

​Links to Third-Party Websites

The Site may contain links to third-party websites which, in some cases, may be integrated into and appear to be part of the Site. Discerene encourages you to read the privacy policies of other websites you link to from this Site and disclaims any responsibility for the privacy policies and procedures of any third-party websites that you reach via a hyperlink contained on this Site. Such hyperlinks are provided for your convenience only, and you access them at your own risk.

​Children’s Online Privacy Protection Rule (“COPPA”)

The Site is not intended for or targeted towards, and we do not knowingly collect personal information via the Site from, children under 13 years of age. If we learn we have collected or received personal information via the Site about a child under 13, we will delete that information.

Updates to this Privacy Policy​

Discerene reserves the right in its sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting and we will indicate in the Privacy Policy when it was most recently updated. You should review this Privacy Policy periodically for changes applicable to you. Additionally, note that by accessing this Site subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended.