Privacy Policy

This Policy describes how 13D Global Strategy & Research (“13D”, “we” or “us”), as the data controller, collects, processes, uses, shares and secures the personal information you provide. It also describes your choices regarding use, access, and correction of your personal information. For purposes of this Policy, personal information shall mean any information relating to an identified or identifiable natural person. By using this site, you signify your acceptance of our Privacy Policy.


Your confidential use of this site cannot be guaranteed by us. We shall not be responsible for any harm that you or any person may suffer as a result of a breach of confidentiality in respect to your use of this site.


In addition to the rights and duties under the 13D GLOBAL STRATEGY & RESEARCH SERVICES AGREEMENT, if you use this site, you are responsible for maintaining the confidentiality of your account information and your password. You agree to accept responsibility for all activities that occur under your account or password. You understand that you are financially responsible for all uses of this site by you and those using your login information.


3.1 Data You Provide Us.

  3.1.1  If you choose to complete one of the forms on our website requesting information on 13D’s products or services, you will be asked to provide your name, company name, country in which you are located and contact information, such as an email address or phone number at which we can reach you. We also ask for, but don’t require, additional information related to the type of investor that you are. This information helps us service you more effectively.

  3.1.2  In the event that you become a 13D client, we collect additional information such as your billing address, for accounting purposes.

3.2 Data From Others

  3.2.1  13D partners with 3rd parties who collect employment data and fund management information. This information allows us to provide a higher level of service when supporting your account.

3.3 Service Use

  3.3.1  We log usage data when you visit or otherwise use our Services, including our sites and mobile application, such as when you view or click on content, print an article and share content. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

3.4 Cookies And Other Similar Technologies

  3.4.1  To allow our website to function properly and enhance your experience with our site, we may need to use “cookies”. Cookies are text files we place in your computer’s browser to store your log-in information during a session. You are welcome to delete any cookies placed on your computer by our server. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information unless you choose to provide this information to us. However, once you choose to furnish us with personally identifiable information, this information may be linked to the data stored in the cookie.

  3.4.1  We use cookies to understand site usage and to improve the content and offerings on our sites. For example, we may use cookies to personalize your experience at our web pages (e.g., to recognize you by name when you return to our site) or to save your password in password-protected areas.


4.1 Customer Support

  4.1.1  We use the data (which can include your communications) to investigate, respond to and resolve issues related to the Services.

4.2 Marketing

  4.2.1  We use data and content about our site visitors for invitations and communications promoting subscribership, engagement and our Services.

4.3 Sales Inquiries

  4.3.1  We may use the information you provide about yourself to fulfill your requests for our products and services, and to respond to your inquiries about our offerings, and to offer you other products or services that we believe may be of interest to you.

4.4 Communications

  4.4.1  We sometimes use this information to communicate with you, such as to notify you of when we make changes to our Terms of Use, to the 13D Global Strategy & Research Services Agreement, to fulfill a request by you, or to contact you about your membership with us. As explained below, you may opt-out of this service.

4.5 Aggregate Insights

  4.5.1  We also sometimes use the non-personally identifiable information that we collect to improve the design and content of our site and to enable us to personalize your Internet browsing experience. We also may use this information in the aggregate to analyze site usage.


5.1 Third Parties

  5.1.1  We do not sell or otherwise provide personally identifiable information to third parties except as noted below. We do use 3rd party systems to store and otherwise process data about our users.

  5.1.2  We may disclose personally identifiable information to a nonaffiliated third party to perform services or functions on our behalf (such as for third party payment arrangements). These third parties include, but may not be exclusive to:

  • we use Salesforce as our Customer Relationship Management system.
  • Rackspace: we host our website at Rackspace. Therefore minimal data pertaining to our subscribers is stored on those servers so that we can apply the appropriate site permissions.
We may also disclose such information to a consumer reporting agency in accordance with the Fair Credit Reporting Act (15 U.S.C. § 1681 et seq.).

  5.1.3  We may disclose personally identifiable information if required to do so by law or court order, as requested by a government agency or by law enforcement authorities, or in the good faith belief that disclosure is otherwise necessary to protect the safety of our customers, employees or property.


6.1 Data Retention

  6.1.1  We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services.

6.2 Data Retention

  6.2.1  We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls.

  6.2.2  For personal data that we have about you:

  • Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
  • Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
  • Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
  • Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

  6.2.3  Visitors can learn more about how to make these requests by emailing us at, and we will consider your request in accordance with applicable laws.

6.3 Account Closure

  6.3.1  If you choose to close your 13D account, we generally delete closed account information within 12 months of account closure. We will retain de-personalized information after that period of time.


7.1 Security

  7.1.1  We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.

  7.1.2  Agents and contractors of 13D who have access to personally identifiable information are required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using the information for any purpose other than to carry out the services they are performing for 13D.

  7.1.3  We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

7.2 Lawful Bases for Processing

  7.2.1  We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the LinkedIn Services you have requested)) and “legitimate interests”.

  7.2.2  Your personal information will be processed on the basis of our legitimate interests:

  • to exercise and comply with our rights and obligations at law or under regulation, where such obligations are set out under the laws of countries outside the European Economic Area (“EEA”), or under a contract to which we are a party;
  • to manage and administer our business and to analyze and improve our business relationships;
  • to communicate with you in respect of any products offered by us;
  • to undertake risk assessment and operational control exercises; for statistical and trend analysis; for systems administration, operation, testing and support and to manage and ensure the security of our information systems;
  • to help detect, prevent, investigate, and prosecute fraud and/or other criminal activity;
  • to disclose information to a governmental, tax or regulatory body, financial market, broker or other intermediaries, counterparties, court, auditors or other third parties and to undertake compliance activities, when this is in our interests, or in the interests of any of our clients, including where the laws of the European Union or a member state of the European Economic Area do not require us to do the same;
  • to establish, exercise or defend legal claims; and in order to protect and enforce the rights, property, or safety of the Manager, our clients, or to assist our clients or investors or others to do the same;
  • to investigate and respond to any complaints about the Manager and its business or any incidents relating to the Manager and to help maintain quality and to deal with complaints and disputes; and
  • to make certain assessments about you in order to assess your eligibility for investing in investment products offered by us.

7.3 Monitoring

  7.3.1  We reserve the right to monitor and review any information transmitted or received through this site and sensor, edit, remove or prohibit the transmission or receipt of any information that we, in our sole discretion, deem inappropriate or a violation of the Terms of Use for this site.

7.4 Rights As To Materials You Provide

  7.4.1  By uploading or submitting any suggestions, ideas, comments, questions or other materials to us you automatically grant (or warrant that the owner of such rights has expressly granted) us a worldwide, perpetual, royalty-free, irrevocable, non-exclusive and assignable right and license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute and display such materials or incorporate such materials into any form, medium, or technology. In addition, you warrant that all “moral rights” (as defined by the US Copyright Act) in those materials have been waived – unless otherwise directly coordinated with a 13D Research staff member.

7.5 Collection of Information by Third Party Sites and Sponsors

  7.5.1 contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.

  7.5.2  13D sometimes may offer content that is sponsored by or cobranded with identified third parties. By virtue of these relationships, the third parties may obtain personally identifiable information that visitors voluntarily submit to participate in the site activity. 13D has no control over these third parties’ use of this information and thus 13D will not be liable for any such third parties’ use or misuse of such information. At the time you provide personally identifiable information to 13D, 13D will notify you if these third parties may obtain such information. 13D will then provide you the opportunity to opt-out of sharing such information with such third parties.

7.6 How to Contact Us

  7.6.1  If you have any questions or concerns about the 13D Privacy Policy or its implementation, please contact us at