Privacy Policy

Last Updated: March 17, 2025

Introduction

This website privacy policy (the “Policy“) describes how Anneal Investment Management LP and its affiliates (“Anneal“, “we“, “us“) treat personal information collected on the anneal.co site (“Website“). This Policy does not apply to information that Anneal may collect through other means.

Personal Information Collected

When you visit our Website, we may collect certain personal information about you, such as your name, company name, address, phone number, and email address, as well as any other personal information that you may provide, for example, through submission of forms or other documents.

Nonpersonal Information Collected

We will also collect the following nonpersonal information about your visit(s): the IP address and domain name used (the IP address is a numerical identifier assigned either to your internet service provider or directly to your computer); the type of browser and operating system you use; and the date, time, and duration for which you visit a Website, the number of times you have visited a Website, and where you come from.

For purposes of collecting some of the above-referenced information, we use tracking tools on our Website, such as browser cookies and web beacons. A cookie and a web beacon are pieces of data stored on your device containing information about your visit.

How We Use Your Information 

We use the information we collect in the following ways: to respond to your requests or questions; to inform you about Anneal and our affiliates; to communicate with you about your relationship with us; to improve the Website and the services provided; and for security purposes. In the case of SMS/MMS messaging, you may reply STOP to prevent further messaging from Anneal.

We do not share or sell your information with third parties for the purpose of marketing or advertising.

In addition, we may use your information as otherwise permitted by law.

Information Shared in Limited Circumstances

We may share your information with our employees, agents, or third-party service providers who need to know such information for purposes of performing their jobs, including to respond to requests or questions that you may have. In addition, we may share your information with third parties for purposes of complying with legal requirements or to respond to legal requests, such as in the case of a court order or subpoena or in connection with a regulatory investigation. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property, or safety of others.

Cookies and Tracking Tools

A cookie is a small text file stored on your computer or mobile device when you visit a website. It allows the Website to retain your preferences and actions (e.g., login credentials, language, font size, and other display settings) over time, eliminating the need to re-enter this information each time you return to the site or navigate between pages. To learn more about cookies, please visit aboutcookies.org.

We utilize two types of cookies on our Website: session cookies and persistent cookies. Session cookies are temporary and remain on your device only while you navigate the Website; they are essential for proper functionality, allowing you to seamlessly browse and use various features. In contrast, persistent cookies remain on your device for an extended period or until manually deleted. The duration of their storage depends on the specific cookie’s designated lifespan and your browser settings. These cookies enable us to recognize returning users, facilitating a more convenient and personalized browsing experience. Additionally, persistent cookies help us gather insights into your browsing behavior throughout their lifespan.

We use cookies on our Website to enhance and personalize your browsing experience, ensuring that future visits are more efficient and seamless. Additionally, cookies enable us to track, compile, and analyze usage patterns, navigation data, and other statistical insights. This information helps us better understand how visitors interact with our Website and allows us to refine its structure and content for improved usability. Importantly, cookie-related data is not used to personally identify you. 

Your browser may offer options to manage cookies, with controls varying based on the type of cookie. Some browsers allow you to reject cookies entirely, but the settings you choose are specific to your browser and device. Please note that blocking or deleting cookies may not fully prevent the tracking methods described in this Policy.

Certain other sites provide “do not track” settings that signal a preference not to be tracked; however, these features are not standardized. At this time the Website does not respond to such signals. Additionally, blocking cookies may impact the functionality of certain features on our Website. If you block or reject cookies, not all of the tracking described herein will stop.

Retention of Personal Information

We retain personal information to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules, and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety and the rights, property, and safety of our users and other third parties.

Business Transfer and Successors

In the future, Anneal may merge with, be acquired by, or transfer some or all of its business, operations, or assets to a third party. This could occur through a merger, acquisition, divestiture, change of control, or liquidation, for example. If such a transaction takes place or is anticipated, we may share your personal information as part of the process.

Links to Other Sites or Third-Party Services Outside of Our Control

If a link to a third-party site is included on our Website and you click on it, you will be taken to a site that we do not control. This Policy does not apply to the privacy practices of those websites outside of the anneal.co domain. Read the privacy policy of other websites carefully, especially before you submit any personal information to these third-party sites. We are not responsible for actions, omissions, or practices of any third-party sites.

Google reCAPTCHA Usage

We utilize Google’s reCAPTCHA service to safeguard internet submission forms on this Website, ensuring that submissions are made by humans rather than automated bots. This service helps prevent spam and unauthorized use of certain website functions, such as comments.

This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service. On behalf of the operator of this Website, Google will use this information to evaluate your use of this service.

This data collection is subject to the data protection regulations of Google. For more information about Google’s privacy policy, please visit:

https://www.google.com/intl/en/policies/privacy

By using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

We Follow Reasonable Cyber Security Practices but Provide No Guarantees

We are committed to protecting any personal information collected through a Website against unauthorized access, use, or disclosure. We will not sell or otherwise disclose any personal information collected from a Website, other than as described herein.

This Policy should not be construed as giving business, legal, or other advice or warranting as failproof the security of information provided through the Website. We maintain reasonable cyber security procedures and practices, but the internet is not 100% secure. Anneal cannot guarantee that your use of our Website or software will be completely safe. We encourage you to use caution when transmitting personal information over the Internet. In addition, you should be aware that internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Website is or will be secure.

Personal information we collect may be transferred to and stored within the United States. Our Website is subject to U.S. laws, which may not afford the same level of protection as those in your country. We will take reasonably necessary steps to ensure that your personal information is treated securely and in accordance with this Policy. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. 

Anneal disclaims any liability with respect to any information obtained by a third party through illegal entry into or breach of its Website and supporting services. Anneal will maintain all information as long as needed to comply with internal policies or applicable laws or for record-keeping purposes.

Children and Website Usage

This Website is intended for and applicable only for individuals 18 years of age or older. By using the services provided by this Website, you represent that you are 18 years of age or older.

We do not knowingly collect personal information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us personal information, please contact us at the address below and mark your inquiries “Legal / COPPA Information Request.”. Parents and guardians may learn more about how to protect children’s privacy on-line here.

Rights for Individuals in the European Economic Area and United Kingdom

Individuals who are located in or residents of countries in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain data subject rights that may be subject to limitations and/or restrictions.

You have the right to access, rectify and, subject to our other legal obligations and business considerations, erase your personal information. You also have the right to ask us to restrict the purpose or to object to the processing of your personal information as well as a right to data portability.

Please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing.

You may have the right to lodge a complaint about the processing of your personal information with your local data protection authority.

If you wish to exercise any of your rights under this Policy, please send us your request via email to the contact below.

For the purposes of EEA and UK data protection laws, we are the data controller of your personal information collected on the Website. This means that we are responsible for, and control the processing of, your personal information.

For the purposes of EEA and UK data protection laws, the legal basis for the processing of your personal information is when it is necessary for the performance of any contractual relationship with you, and where in our legitimate interests for the purposes described in this Policy.

Rights for Individuals in California

If you are a California resident, California law requires us to provide you with certain information about how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”). Please note that this California Privacy Notice (“Notice”) applies only to information we collect from California users of the Website, and does not apply to any individual in their capacity as an Anneal investor or employee.

A. Categories of Personal Information we collect, use and disclose

We collect the following categories of personal information defined under the CCPA from California consumers and that we may, as discussed throughout this Policy, use and disclose for our business purposes:

Identifiers (such as name, address, email address); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history); general geolocation data derived from IP addresses; any user-generated content or feedback that you provide; professional, educational or employment related data; and username and password.

We collect such information: directly from you (such as when you apply for a job with Anneal, submit your business contact information, or send us questions or otherwise communicate with us); and through automated technology (such as cookies on our websites) or online platforms.

B. How we use and disclose these categories of personal information

We and our service providers may use the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law):

  • Our or our service providers’ operational purposes;
  • Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
  • Bug detection and error reporting;
  • Customizing content that we or our service providers display on the Services;
  • Providing Services (e.g., maintaining our Website and communicating with you about programs and products);
  • Improving our existing Services and developing new services (e.g., by conducting research and analysis to develop new products or features);
  • Evaluating job applicants, individuals, and/or business opportunities;
  • Onboarding and paying contractors;
  • Other uses that advance our commercial or economic interests, such as third-party advertising (consistent with any privacy choices you have communicated to us) and internal statistical analysis and research purposes; and
  • Other uses about which we notify you.

We may also use and disclose personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any user or device, and use such aggregate and de-identified information for any purpose.

We may also disclose this information to third parties for legal, compliance or security purposes or based on your elections, in connection with a business transfer or successor to all or part of the business, or our affiliates.

C. Sale/Sharing of Personal Information

The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes with third parties who do not act as service providers to that business. We make personal information available to non-service provider third parties only when individuals have affirmatively agreed to such disclosure (for example, where a site visitor has opted in to our use of advertising cookies) or where the disclosure of personal information is otherwise exempt from the CCPA (such as disclosing information to secure the Services). As such, Anneal does not “sell” or “share” personal information within the meaning of the CCPA.

Please note, in the limited circumstances that we process sensitive personal information as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.

D. Your Personal Information Rights

California residents may make certain requests about their personal information under the CCPA, subject to certain limitations and/or restrictions. Specifically, under California law you have the right to:

  • Request that we disclose information about the personal information that we have collected, used, disclosed or sold,
  • Request access to a copy of the personal information we maintain about you;
  • Request correction of inaccurate personal information;
  • Request that we delete personal information collected from you; and
  • Not receive discriminatory treatment for exercising your privacy rights.

A consumer may use an authorized agent to submit a request on their behalf. When using an authorized agent, we require that you provide the authorized agent written permission to do so and verify their own identity and agent status with us. If you would like to designate an authorized agent to make a request on your behalf, please email us at the address below.

If you require this notice in an alternative accessible format or to exercise any of your rights under this section, please email us at the address below..

E. Shine the Light

California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

Modifications and Updates to this Policy

This Policy replaces all previous disclosures we may have provided to you about our information practices with respect to your use of the Website. We reserve the right, at any time, to modify, alter, and/or update this Policy, and any such modifications, alterations, or updates will be effective upon our posting of the revised Policy. Your continued use of the Website following our posting of any revised Policy will constitute your acknowledgement of the amended Policy.

Contact Information regarding this Policy

For questions regarding this Policy, please contact [email protected]. 

Anneal will notify you of any material changes in this Policy by posting an updated copy on the Website. Please check the Website periodically for updates.