Privacy Policy

Reckoner Capital Management LLC and its affiliates (“Reckoner,” “our,” “us,” or “we”) respect your privacy and are committed to protecting it through our compliance with this policy. To better protect your privacy, we are providing information explaining our online information practices.

This privacy policy (“Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.reckoner.com (the “Site”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to information we collect on the Site and through email and other electronic messages between you and the Site. It does not apply to information collected by us offline or through any other means, including on any other website operated by Reckoner or any third-party, including through any application or content that may link to or be accessible from or on the Site. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should not access the Site.

This Privacy Policy constitutes a legally binding agreement between Reckoner and you, the user of the Site. By entering and using the Site, you acknowledge your acceptance of, and agree to be bound by, the Privacy Policy stated herein and the terms of use of the Site (“Terms of Use”) and all additional terms incorporated by reference herein. This policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of the Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

We rely on various legal bases under applicable data protection legislation in order to process your personal information (e.g., name, title, address, email, marital status, date of birth, IP address, financial data, username, password, etc.), including our legitimate interests, contractual necessity, and as required by law. We use the personal information we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal information, and the possible consequences of you failing to provide this personal information. Failure to provide this information means that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Information We Collect About You and How We Collect It

We may collect various types of information from users of the Site. For example, knowing how users use the Site – tracking their movement through the Site – helps us improve website design and usefulness. As a result, Reckoner’s server collects general data pertaining to users, including the length of time spent on the Site, the pages accessed while visiting the Site, and IP addresses. Reckoner generally does not, however, collect any personally identifiable information such as names, home addresses, or email addresses from users of the Site.

To the extent that you provide us with any personally identifiable information through or in connection with the Site, we may use such information for Reckoner’s business purposes but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to Reckoner, you consent to Reckoner’s use of such personally identifiable information for the purposes described in this Privacy Policy.

Unfortunately, the transmission of information and data via the internet is not completely secure. Although we employ certain safeguards to protect your personal information, we cannot guarantee the security of any information or data transmitted to or through the Site; any transmission of information or data by you to or through the Site is at your sole risk.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present the Site and its contents to you.
To provide you with information, products, or services that you request from us (e.g., to respond to you).
To fulfill any other purpose for which you provide it.
To notify you about changes to the Site or any products or services we offer or provide through it.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Reckoner, our clients, or others.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Reckoner’s assets.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.
Retention of Personal Information As applicable, we retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to operate the Site, respond to inquiries, improve our services, or comply with legal obligations. We may also retain personal information for longer periods where permitted or required by law, where necessary to establish, exercise, or defend legal claims, or in connection with audits, investigations, and proceedings. When personal information is no longer required for these purposes, we will take appropriate steps to delete, de-identify, or anonymize it in accordance with applicable laws and our internal policies. Note that Reckoner currently does not and does not intend to sell or share for the purposes of cross-context behavioral advertising any personal information collected.

Your European Privacy Law Rights

If you are located in Europe, subject to applicable law, you may, in accordance with European privacy laws, have the following rights in relation to personal information that we hold about you. To exercise these rights and controls, please contact legal@reckoner.com.

Access: You have the right to ask for a copy of the personal information that we hold about you free of charge; however, we may charge a reasonable fee, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
Correction: You may notify us of changes to your personal information if it is inaccurate or it needs to be updated.
Deletion: If you think that we should not be holding or processing your personal information anymore, you may request that we delete it. Please note that this may not always be possible due to our legal obligations.
Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information override your own rights.
Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
Automated decision-making: You have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

These rights are not absolute and in certain circumstances, their exercise may not be possible, including when personal information must be maintained to comply with applicable laws. We may also need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you believe that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you have the right to lodge a complaint with the data protection supervisory authority in your country. You can find details for your relevant EU national data protection authority at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080, and for the UK, please contact the UK Information Commissioner’s Office at https://ico.org.uk/global/contact-us.

Your California Rights

If you are a natural person who is resident in the state of California, you may have the following rights in relation to personal information that we collect about you. Information we collect has already been conveyed above. To exercise these rights and controls, please contact legal@reckoner.com.

We do not collect or use sensitive personal information other than:

To perform services or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
For short-term, transient use (but not in a manner that discloses such information to another third-party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
To perform services on behalf of our business;
To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Capacity

You represent to Reckoner that you have the authority to visit the Site according to the Terms of Use. The Site is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to the Site who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

Accessing and Correcting Your Information

You may also send us an email at legal@reckoner.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Policy under which the information was collected. Your continued access or use of the Site following the posting of changes to this Privacy Policy means that you accept such revisions, changes, and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing the Site. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.

Contact Information

To ask questions about this Privacy Policy and our privacy practices, contact us at: legal@reckoner.com.

Miscellaneous

The provisions in our Disclosures & Terms of Use are hereby incorporated by reference.

Last modified: April 2026