Privacy Notice

Effective: January 26, 2019


Introduction

This privacy notice applies to Prime Clerk LLC (“we” or “Prime Clerk”) and describes how we collect, use and share information about you collected via this web site (the “Site”). If you as a visitor choose to register or submit information to Prime Clerk via the Site, you agree to the use of such data in accordance with this privacy notice.

Client Websites and Information Collection

We provide administrative-support services and solutions, including bankruptcy administration, for our clients in the legal and financial industries. As part of our services, we create, configure and host pages on the Site on behalf of our clients.  Site visitors may access information and, in certain circumstances, submit claims, ballots, rights offering subscription forms or similar voting or participation documents, or inquiries relating to the matters for which we are providing administrative-support services and solutions for our clients on such client-dedicated pages.

We collect certain personal information, oftentimes from the client or a site visitor, before allowing a site visitor to access certain information provided on a client-dedicated page hosted on the Site. Among other things, we may collect the following data: (i) name; (ii) personal identification information (including mailing addresses and/or telephone numbers); (iii) password; (iv) email address; and (v) position within the client or agent organization. We may also collect information about visitor usage of the Site, including, without limitation, the amount of time a visitor spends on the client-dedicated page, the reports the visitor accesses, and other activities in which the visitor engages while on the Site. This information may be collected through the use of log files and/or cookies, web beacons, local shared objects (or Flash cookies), and similar tools.

Use of Personal Information

Personal information submitted via the Site is used only for limited purposes. For example, when you register to gain access to a client-dedicated page, the information you submit may be used to manage our relationship with you, such as to provide you with information we feel would be of interest to you; to facilitate responding to further requests or inquiries from you; or to otherwise personalize your Site experience. We may also send you emails and communications regarding our products and services. Information that is contained in documents accessible via links on case websites is made available by order of the Bankruptcy Court and cannot be removed, modified, or otherwise altered, without further order of the Bankruptcy Court.

You may at any time request to be removed from emails or other communications generated in response to your registration on the Site by following the unsubscribe instructions included in these emails, or by contacting us at webmaster@primeclerk.com.

Use of Aggregate Information

From time to time, we may gather general statistical information, such as how many visitors visit a specific page, how long they remain on that page, and the hyperlinks, if any, on which they “click.” We may use that kind of information to determine which areas of the Site are visited most frequently, and to enhance and refine the functionality of the Site for visitors. Any such data will be aggregated, and will not personally identify any individual visitor to the Site.

Disclosure of Information to Third Parties

Our arrangements with our clients may require us to provide all visitors’ information in our possession, including personal information, directly to the client with which the visitor is associated.

Personal information may also be provided to third-party service providers. These companies are authorized to use your personal information only as necessary, and in accordance with applicable law, to provide the applicable services to us. Personal information will also be disclosed to law enforcement, judicial bodies, regulatory or other government agencies, or third parties where necessary, in our judgment, to comply with legal or regulatory obligations.

Personal information may also be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and we may transfer personal information to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy or receivership. You will be notified via email and/or a prominent notice on the Site of any such event.

Except as set forth above, we will not make any of your personal information available to third parties.

We may share with third parties aggregated, non-personally identifiable information concerning Site usage, as we deem appropriate as part of our ongoing business activities.

Information Security

We have put in place physical, technological and operational security procedures designed to protect personal information provided by visitors via the Site from unauthorized third-party access. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee absolute security. You can also take additional measures to protect yourself and your information, such as keeping your anti-virus software up-to-date and keeping log-in credentials and passwords secure. Please contact us immediately at webmaster@primeclerk.com if you suspect or experience any security-related issues.

Links to Third Party Websites

The Site may contain hyperlinks to other websites. This privacy notice does not apply to those websites. The use of any such other website may be subject to a privacy statement, terms of use, disclaimer or similar legal condition which may significantly differ from those set forth in this privacy notice or elsewhere on the Site. We strongly encourage you to review the privacy notice of any website you visit via the Site before supplying personal information through that website and to familiarize yourself with the terms, conditions and policies implicated by the use of those sites. We are not responsible for the privacy practices or the content of any such other sites.

Changes to the Privacy Notice

We reserve the right to modify or amend this privacy notice at any time and for any reason. We encourage you to periodically review this page for the latest information on our privacy practices. You can determine when this privacy notice was last modified or amended by checking the Effective Date at the start of the privacy notice.

Information for Visitors from the European Economic Area

We understand that in certain circumstances you may have certain rights available under certain laws, including the EU’s General Data Protection Regulation (“GDPR”), relating to your personal information. To the extent these laws apply to the processing of any data by us, we are operating as a data processor and are processing such data on behalf of our clients, the data controllers. Our clients, acting as the data controllers, determine the purposes and means by which we process such data. At the direction of, and in accordance with, the instructions of our clients, we may allow visitors to access their personal information in our possession and to correct, amend, or delete inaccurate information. If you wish to exercise any rights under these laws, including the GDPR, or obtain additional information regarding the processing of data about you that we conduct on behalf of our clients, please refer to the privacy notice of the data controller or contact the data controller directly.

Questions

If you have any questions or concerns regarding your privacy while using the Site, please direct them to the webmaster of the Site at webmaster@primeclerk.com.