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First Principles Capital Management, LLC

Last Updates: April 12, 2017

First Principles Capital Management, LLC (“FPCM”) is a wholly-owned, indirect subsidiary of American International Group, Inc. (“AIG”).

AIG and its subsidiaries and affiliates (each an “AIG Company”, “AIG Companies”, “we” or “us”) is committed to protecting the privacy of the individuals we encounter in conducting our business.  We respect the confidentiality of our clients’ non-public, personal information. It is our intention to ensure that this information is safeguarded to protect against its misuse. To that end, we are providing you with a copy of our current Privacy Policy to remind you of our concern for and our efforts related to the protection of your personal, non-public information.

All information given to us and all recommendations and advice furnished by us will be kept confidential and will not be disclosed to anyone, except as we may agree in writing or as may be required to do so by law.  We will only retain Personal Information for as long as it is needed in accordance with applicable laws.

We will collect “Personal Information” about you as part of this engagement.  “Personal Information” is information that identifies and relates to you or other individuals (such as your dependents).  Our aim is responsible handling of Personal Information, balancing the benefits of activities like research and data analytics with our other commitments, including transparency and non-discrimination. This Privacy Policy describes how we handle Personal Information that we collect through this website.

 By using this website, you signify your acceptance of this Privacy Policy.  

Please note: This Privacy Policy is supplemented by Privacy Notices tailored to our specific relationships with you, including Privacy Notices that are sent to individuals as required under applicable laws and regulations.  

Other websites and services of AIG Companies both within and outside of the United States of America contain different privacy statements to this Privacy Policy, and you are advised to review the privacy statement on each AIG Company website.

More Information

If you have any questions about our use of your Personal Information you can call 212-380-2282 or write to: 

First Principles Capital Management, LLC
140 Broadway, 21st Floor
New York, NY 10005

Depending on your relationship with us, Personal Information collected about you and your dependents may include:

  • General identification and contact information 
    Your name; address; e-mail and telephone details; gender; marital status; family status; date of birth; and educational background.
  • Identification numbers issued by government bodies or agencies
    Social Security or national insurance number; passport number; tax identification number; military identification number; or driver’s or other license number.
  • Financial information and account details
    Bank account or other financial account number and account details; assets; income; and other financial information.

We use this Personal Information to:  

  • Communicate with you and others as part of our business.
  • Send you important information regarding changes to our policies, other terms and conditions, and other administrative information.
  • Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; data analytics; business continuity; and records, document and print management.
  • Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering, sanctions and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).
  • Establish and defend legal rights; protect our operations or those of any of our group companies or business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

AIG may make Personal Information available to:  

  • Our group companies
    Other AIG group companies may have access to and use of Personal Information in connection with the conduct of our business where appropriate.
  • Our service providers
    External third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; banks and financial institutions that service our accounts; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
  • Governmental authorities and third parties involved in court action
    AIG may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.
  • Other Third Parties
    We may share Personal Information with purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock.

We will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws.  Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us.  (See the “Who to Contact About Your Personal Information” section above.)

When AIG provides Personal Information to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information.

If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.

It is our policy to protect customer and employee Social Security Numbers that we collect in the course of our business as confidential. This includes maintaining physical and electronic security procedures to guard against unauthorized access to Social Security Numbers. We also limit access to Social Security Numbers, by among other means, only granting access to Social Security Numbers to our employees who use that information to perform their job-related duties. In addition, we do not disclose Social Security Numbers to third parties, except where required or permitted by law.

Please contact us as set out in the “Who to Contact About Your Personal Information” section above with any such requests or if you have any questions or concerns about how we process Personal Information.

“Other Information” is any information that does not reveal your specific identity, such as information collected through cookies, pixel tags and other technologies.

We and our third-party service providers may collect Other Information in a variety of ways, including the use of cookies.  Cookies are pieces of information stored directly on the device you are using. Cookies allow us to recognize your device and to collect information such as internet browser type, time spent on the website, pages visited, language preferences, country website preference. We may use the information for security purposes, to facilitate navigation, to display information more effectively, or to personalize your experience while using the website. In addition, we may use the information to gather statistical information about the usage of the website in order to understand how it is used, continually improve the design and functionality, and assist us with resolving questions about it.

Below is a description of some of the cookies we may use on the Site, what they do, what data about you they collect and what we may use them for:

  • Geo Location cookie  – When a visitor visits the Site for the first time we read their location from their IP address and use this information to  assume the country site that they want to visit. This method is not entirely accurate, however, so when they navigate to a particular country site we use a cookie to store this information and to store the language that they chose to view the site. The next time they visit the Site we read the cookie and present the same country and language version they used on their last visit. This has the intended benefit that they don’t need to reselect the country site they need each time they visit an affiliate site.  No Personal Information is collected or used by the cookie.
  • Site Catalyst cookie (by Adobe) – This cookie enables us to collect and analyze data about how visitors arrive at the Site and then how they interact with the Site, including products they may search and content they may view.  We use this aggregated information to adapt the Site to better serve their and other users’ needs and interests, and to provide more relevant and useful information. The cookie is placed on a visitor’s PC on a temporary basis only.  The cookie does not collect or use their Personal Information. Instead, it logs an anonymous code which identifies users and this code “follows” the user in their journey through the Site.  We use the aggregated and anonymous information for statistical analysis.
  • Optimost cookie – Optimost is a service provided by Hewlett-Packard to analyze customer behavior when visiting the Site.  This service allows us to test variations of our website pages or elements within the pages.  The tests will usually result in improvements to the website and the user experience. The cookie has an anonymous “visitor ID” which is a random number generated to identify a visitor, to distinguish between unique and/or repeat visitors. These cookies do not collect Personal Information. To view the Optimost privacy policy, please visit: https://asp.optimost.com/avatar/privacy-policy .
  • Oracle Cookie - We may use the services of www.oracle.com to serve a persistent cookie on visitors’ browsers when they first visit our web pages, unless there is already an Oracle cookie on their browser because they have visited a non-affiliated site which is also using Oracle’s services.  However, visitors’ browsing activity on our web pages will not be combined with visitors’ browsing behavior on other websites using Oracle’s services. We use visitors’ browsing activity on our web pages to understand which pages and content our visitors use or do not use so that we can monitor Site content to best meet our visitors' needs.  For further information please read the Oracle privacy policy. 

You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties.

The website is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information through the website.

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements.  We will place updates on our website and recommend that you visit this page periodically for updates to the policy.

Please take a look at the “LAST UPDATED ” date at the top of this Privacy Policy to see when it was last revised.