Privacy & Terms

PRIVACY NOTICE

Last Updated: January 26, 2023

Note for California Residents: This Privacy Notice and Cookie Statement describes how we process your Personal Information and your rights and choices over our processing. Please see Section XI below for specific details on your rights under California law.

Note for Residents of the European Economic Area, Switzerland, and the United Kingdom. Please see Section XII below for specific details on your rights under applicable law.

I. Introduction

This document (“Privacy Policy”) describes how we process your Personal Information.

By accessing, visiting or using thewebsite, you acknowledge your understanding of this Privacy Policy. If you do not agree with the contents of this Privacy Policy, you should not access, visit and/or use the website.

This Privacy Policy may be modified at any time without prior notice to you. Your continued access, visitation and/or use of the website, will constitute your acceptance of any changes or revisions to this Privacy Policy.

II. Definitions of Terms Used in this Policy

“CCPA” means the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. and its implementing regulations.

“Device” means any computer, tablet, mobile phone, or any other device capable of accessing the website.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, Device, or household. Anonymous, de-identified, or aggregate information is not Personal Information.

“Sensitive Personal Information” means personal information that reveals (a) consumer’s Social Security or other state identification number; (b) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) consumer’s genetic data. In addition, “sensitive personal information” includes processing of biometric information for purposes of identifying a consumer; personal information collected and analyzed concerning a consumer’s health, and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

“Service Provider” has the same meaning as set forth in the CCPA, which in general means a for-profit legal entity to whom we disclose Personal Information for processing on our behalf for a “business purpose” (as defined in the CCPA) pursuant to a written contract.

“Third-Party Business” means any third party unaffiliated with us to whom we disclose Personal Information for their own purposes.

“We,” “Us,” “Our” and “Ridgebury,” whether capitalized or not, means R2 Management LLC, its subsidiaries and affiliates (collectively referred to herein as “Ridgebury”).

“You” or “Your,” whether capitalized or not, means all those who access, visit and/or use the website.

III. Categories of Your Personal Information that We May Acquire

We may collect, obtain or otherwise acquire the following types of Personal Information about you, and we may make and retain inferences drawn from such information:

IV. How We Obtain Your Personal Information

From Personal Information You Provide. We may receive Personal Information directly provided by you. For example, through registering with us, you may be asked or prompted to provide identifiers or establish a password and/or User ID.

V. How We Use Your Personal Information

We use your Personal Information to process your requests and providing services to you.

VII. Sharing of Your Personal Information with Third Parties.

Third Parties with Whom We May Share Your Personal Information. We may disclose your Personal Information to the following categories of third parties:

• Service Providers
• Affiliates
• Governmental and law enforcement officials
• Persons involved in an acquisition of our business or assets

Service Providers. We may share your Personal Information with Service Providers that perform services for us, but only for the purpose of and to the extent necessary to perform those services.

Affiliates. We may share your Personal Information with our subsidiaries, affiliates and other related entities, and our advisors, including lawyers, consultants, accountants, and others, for all purposes described in this Section VII.

Health, Safety, and Legal Requests. We may share your Personal Information for purposes of health, safety and other matters in the public interest. We may also share your Personal Information to cooperate with official investigations or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We may also use Personal Information to protect our rights and property and those of our agents, customers, and others including to enforce our agreements, policies, and terms of use.

Transfer or Sale of Our Business. If Ridgebury or its subsidiaries, affiliates or other related entities is involved in a business transaction, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Ridgebury or its subsidiaries, affiliates or other related entities, we may share your Personal Information in connection with such transaction. We may also share your Personal Information to legal, financial, insurance, or other advisors in connection with such business transaction or management of all or part of our business or operations.

VIII. Cookies and Related Technologies

Cookies are small text files temporarily stored on your device that can be used by websites to make a user’s experience more efficient. When you use the website, certain third parties may place cookies in your browser. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used.

Session cookies are temporary and expire when you close your browser and end your session. Persistent cookies remain on a hard drive, depending on cookie category and jurisdictions; it could remain stored from 30 min to up to two years. In practice, cookies could remain on your device longer if you do not take action (i.e. clear your browsing data and cache).

The following is a list of the types of third-party cookies used on the website. If you would like more information about these cookies, together with information on how to reject or delete the cookies, please see their individual privacy policies.

The content of this document is for your general information and use only. These cookies are subject to change without prior notice. We do not provide any warranty or guarantee as to the accuracy of the information included above. You acknowledge that this information may contain inaccuracies or errors and is subject to change and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.

If you want to learn more about cookies, please visit http://www.aboutcookies.org for detailed guidance. In addition, certain third-parties, including Google, permit users to opt-out of or customize preferences associated with your internet browsing.

You may elect to disable cookies on your Device or browser. Please note that if you do elect to disable your browser’s ability to accept cookies, you may not be able to access or take advantage of many features of the website.

IX. Transfer of Your Personal Information Among Jurisdictions

Your Personal Information may be processed, transferred to, and maintained on, servers and databases located outside of the jurisdiction in which you are based and where the privacy laws may not be as protective as your jurisdiction. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

X. Protection of Your Personal Information

Security Measures. We take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, Personal Information.

No Liability for Breach. Because no security system is impenetrable, we cannot guarantee the security of your Personal Information. You agree to assume all risk in connection with your Personal Information. We are not responsible for any loss of such Personal Information or the consequences thereof.

Breach Notification. If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you subject to applicable laws and regulations governing such notifications.

XI. Notice to California Customers – Your Privacy Rights

Rights of California Residents. The CCPA grants residents of California certain rights with respect to their Personal Information.

California residents have the following rights under the CCPA:

• The right to know the categories of personal information we have collected about you;
• The right to know the categories of sources from which the personal information is collected, sold or shared, and to whom;
• The right to know our business or commercial purpose for collecting, selling, or sharing personal information;
• The right to know the categories of third parties to whom we business discloses personal information
• The right to request specific pieces of your Personal Information that we hold;
• The right to request the deletion of your Personal Information, subject to several exceptions;
• The right to opt out of the sale of your Personal Information; and
• The right not to be unlawfully discriminated against for exercising these rights.
• The right to request that we correct inaccurate personal information that  we have about you; and
• The right to request that we limit the use and disclosure of sensitive personal information collected about you.

We may take reasonable steps to verify your identity before fulfilling your request to know or delete. For example, we may seek to establish your identity by matching information that you submit alongside your request with information that we have on our records. We may also ask for supplemental information as needed to establish your identity.

Exercising Your Privacy Rights Under the CCPA. California residents, as well as authorized agents seeking to submit requests on behalf of California residents and parents or guardians seeking to submit requests on behalf of their minors who are residents of California, may exercise the rights described below by contacting us at DMadden@ridgeburytankers.com or by calling us at 203-304-6130.

You have the right to request that we delete or correct inaccurate Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete or correct (and direct our service providers) your Personal Information from our records, unless an exception applies. We may deny your deletion or correction request if retaining the information is necessary for us or our service provider(s) to:

• 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.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

You have the right to request that we limit the use and the sharing of your Sensitive Personal Information to what is reasonably commercially necessary to perform services. We do not collect Sensitive Personal Information about you.

If you opt out of the sale of your Personal Information, we may still share your Personal Information with third parties if those transfers are not sales, such as with our Affiliates or our Service Providers.

Response Timing and Procedures

We endeavor to respond to a verifiable consumer request to correct inaccurate personal information, or delete personal information, within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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.

Do Not Track

California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (“DNT”) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, visit All About DNT.

Shine the Light

California’s “Shine the Light” law, Cal. Civil Code §1798.83, gives California customers the right to prevent our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place.

XII. Notice to Residents of the European Economic Area (“EEA”), Switzerland and the UK

Purposes of Processing

We process your Personal Information to process your requests, to provide services to you, facilitate access by the website, make marketing communications, facilitate health, safety and legal requests, transfer or sell our business, and to combine data sets.

Legal Basis for Processing

Under applicable data protection laws, we may only use your personal information if we have a proper reason for doing so, for example:

• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering into a contract;
• For our legitimate interests; or
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

Transfers

Your Personal Information may be processed in or transferred to the U.S. or elsewhere in the world. We will ensure that transfers of Personal Information to a third country or an international organization are subject to appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact the Data Protection Officer by email at DMadden@ridgeburytankers.com or as described at the end of this section.

Erasure and Restriction of Personal Data

Unless otherwise provided for in this data protection declaration for individual cases, your Personal Information may be erased if this data is no longer necessary for the purposes for which it was collected or was in any other way processed and if there are no legal obligations that require us to keep it. We will also erase your Personal Information processed by us upon request, in accordance with Art. 17 GDPR, if the conditions described therein are met. If your Personal Information is required for other legally permissible purposes, the data will not be erased, but its processing will be restricted in accordance with Art. 18 GDPR. In the event of a restriction, the data will not be processed for other purposes. This applies, for example, to Personal Information that we must keep for commercial or tax reasons.

Individual Rights

If you are a resident of the EEA, Switzerland or the United Kingdom, you are entitled to the following rights. Please contact our Data Protection Officer to exercise these rights by email at DMadden@ridgeburytankers.com or as described at the end of this section. In order to verify your identity, we may require you to provide us with Personal Information prior to accessing any records about you.

• Right to access and rectify your Personal Information. You have the right to obtain information about our processing of your Personal Information and a copy of your Personal Information that we store. You have the right to request that we update your Personal Information if it is inaccurate or incomplete.

• Right to request erasure of your Personal Information. You have the right to have your Personal Information erased from our systems if the Personal Information is no longer necessary for the purpose for which it was collected or you withdraw consent and no other legal basis for processing exists.

• Right to restrict our processing of your Personal Information. You have the right to restrict our processing if you contest the accuracy of the Personal Information we store about you, our processing is deemed unlawful and you oppose erasure of your Personal Information, or we no longer need the Personal Information for the purposes for which we collected it but we must store it to comply with our legal obligations.

• Right to portability of your Personal Information. You have the right to receive your Personal Information and to transmit it to another controller where our processing is based on consent you gave us and was carried out by automated means.

• Right to object to our processing of your Personal Information. You have the right to object to our processing where we process Personal Information based on legitimate interest.

• Right to lodge a complaint. You have the right to lodge a complaint about our collection and processing of your Personal Information to your Data Protection Authority. Contact details for Data Protection Authorities are available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

• Data Protection Officer. If you are a Data Protection Authority in the EEA or UK with questions about this Privacy Policy or the Service, please contact us directly by contacting our Data Protection Officer by email at DMadden@ridgeburytankers.com. Alternatively, you can contact our Data Protection Officer at the following address:

Data Protection Officer
33 Riverside Avenue, 3rd Floor
Westport, Connecticut  06880
DMadden@ridgeburytankers.com

XIII. Privacy Policy Coordinator

If you have any concerns or questions about any aspect of this Privacy Policy, please feel free to contact our Privacy Policy Coordinator by email or as follows:

Privacy Policy Coordinator
33 Riverside Avenue, 3rd Floor
Westport, Connecticut  06880
DMadden@ridgeburytankers.com

Please include your name, contact information, and the specific website, mobile site, application, and/or other service in your request.

Only inquiries about this Privacy Policy or your Personal Information should be sent to the Privacy Policy Coordinator. No other communications will be accepted or responded to.