Privacy Policy

This Privacy Policy was last updated in January of 2020.

Dorilton Capital Management LLC (“Dorilton Capital”) and its parents, subsidiaries and affiliates (hereinafter the “Company”, “we”, “us” or “our”, as appropriate) knows the privacy of your personal information is important to you. This Privacy Policy covers the information that we collect about you both online and offline, including information that you provide to us online or that we collect when you interact with us through our website located at (“Website”) or through any other Company website, mobile app or online service that links to this policy (collectively, the “Services”); information that you provide to us or that we collect when you interact with us offline, such as email communications made in the course of business or other circumstances where we may collection information from you or about you. It also explains how we use various technologies.

If you do not understand any aspects of our Privacy Policy, please feel free to contact us at or 212-929-0358and request to speak to Dorilton Capital’s Privacy Officer or Legal Department.

This Privacy Policy will inform you of:

  • Collection and Use of Personal Information;
  • Sharing of Personal Information;
  • Access to Your Personal Information and Choices;
  • Privacy Policies of Third Parties;
  • Information About Minors;
  • Security of Personal Information;
  • California Privacy Rights;
  • Changes to The Privacy Policy; and
  • How to Contact Us.
  • Collection and Use of Personal Information
  1. In relation to your use of the Services or your interactions with us, we collect and use certain personal information about you. Personal information is information about you through which you can be identified (including where you can be identified by combining the information with other information). Note that we may be required by law to collect certain personal information about you, or as a consequence of our contractual relationship with you. Failure to provide this personal data may prevent or delay the fulfillment of these obligations. We will inform you at the time your personal information is collected whether certain information is compulsory and the consequences of the failure to provide such information.

  2. Information Obtained from Third Parties. In some cases, we may also receive certain categories of personal information from third parties. We will use this information to supplement information we may already have about you and to communicate with and inform you of our products and services and those of our affiliates. Our basis for processing this personal information is our legitimate interest in communicating with you and personalizing marketing communications (where applicable).

  3. Do Not Track. Please note that we do not currently respond to web browser “do not track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Privacy Policy.

  4. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.
  • Sharing of Personal Information. The Company may share your personal information as follows:
    1. The Company may share your personal information with our affiliates, including our subsidiaries, our parent company, and its subsidiaries (collectively, our “affiliates”). We may share information with our affiliates so that they can communicate with you and provide information to you about their products and services.
    2. Third party or affiliated service providers. We may share your personal information with our service providers that perform services for us. For example, we may partner with companies to optimize services, or manage email communications and newsletters, etc.
    3. Business Partners. Where we partner with third parties for various business purposes such as joint offerings, we may share your information with the third party consistent with the business relationship.
    4. As Permitted or Required by Law. From time to time, we may be required to provide personal information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies or others any activities that we, in good faith, believe to be unlawful or in violation of our Terms of Use. We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property, and safety of others and ourselves, or to detect, prevent, or otherwise address fraud, security, or technical issues.
    5. Business Transactions. In the event that we intend to sell or transfer ownership or control of any or all of our business, operations or services to a third party, we reserve the right to disclose your personal information to a potential buyer both before and after the purchase. In the event the sale does not go through, we will require the potential purchaser to not use or disclose your personal information in any manner whatsoever and to completely erase the same.

  • Access to Your Information and Choices
    1. Where applicable under local law, you may have the following rights regarding your personal information: the right to access personal information we hold, and in some situations, the right to have that personal information corrected or updated, deleted, restricted, or delivered to you or a third party in a usable electronic format (i.e., the right to data portability). Where applicable, you may also object to how we use your personal information if the legal basis for processing that information is our legitimate interest.
    2. Where we are using your personal information on the basis of your consent, and where applicable under local law, you may have the right to withdraw that consent at any time. Where you have granted consent to receive direct marketing communications from us, and where applicable under local law, you may withdraw that consent at any time. You also have the right to register a complaint to the appropriate data protection authority, where applicable.
      • If you wish to exercise these rights, or to notify us of a change in your details, or if you have any questions about the content of this policy, please contact us at or 212-929-0358 and request to speak to Dorilton Capital’s Privacy Officer or Legal Department.
      • Please note that we may require additional information from you in order to honor your requests.
      • You can limit the communications that the Company sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. Please note that even if you opt-out of promotional emails, we may still need to contact you with important information about your account, in accordance with applicable data protection laws (and for Canadian residents only, such will be in accordance with the Canadian anti-spam legislation). If you have any questions about your choices or if you need any assistance with opting-out, please contact us via email to You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.
  • Privacy Policies of Third Parties This Privacy Policy only addresses the use and disclosure of information by Dorilton Capital. Other websites that may be accessible through this Website have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the Privacy Policies provided by all third parties prior to providing them with information.

  • No Information from Minors This Website is not directed to children under the age of 13. If you are a U.S. resident and under the age of 13 or a Canadian resident and you are a minor (persons under the age of majority in their province or territory of residence) (“Minor”), please do not attempt to register with us at this Website, or provide any personal information about yourself to us. If we learn that we have collected personal information from a Minor, we will promptly delete that information. If you believe we have collected personal information from a Minor, please contact us at or 212-929-0358, and request to speak to Dorilton Capital’s Privacy Officer or Legal Department.

  • Security of Personal Information We will use physical, technical, and administrative security measures designed to protect your personal information against unauthorized access and provide for the ongoing integrity and confidentiality of your personal information. However, since the internet is not a 100% secure environment, we cannot warrant, guarantee, or ensure the security of any information you transmit to us. There is no guarantee that the information may not be accessed, disclosed, altered, or destroyed by a breach of our physical, technical, or administrative safeguards. We retain your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
    • Comply with record retention requirements under applicable law;
    • Defend or bring any existing or potential legal claims; and
    • Resolve or otherwise address any complaints or queries relating to our Services or our business.

  • California Privacy Rights Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the consumer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2016 will receive information regarding 2015 sharing activities).  To obtain this information, please send an email request to with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and we may only include information on covered sharing in our response.
  • Changes to the Privacy Policy Our Privacy Policy may change from time to time. We will post any privacy policy changes on our Website and, if the changes are significant, we will provide a more prominent notice. The date the privacy policy was last revised is identified at the top of the page.
  • How to Contact Us If you have questions or concerns regarding this Privacy Policy, or to exercise any rights you may have under applicable law with regard to your personal information, please contact: 212-929-0358 and request to speak to Dorilton Capital’s Privacy Officer or Legal Department. You may also write us at 32 Avenue of the Americas, 17th Floor, New York, NY 10013, Attention: Legal Department/Privacy or email us at If you send us a letter, please provide your name, address, email address, and detailed information about the change you would like to make.