Menlo Equities Privacy Policy

Last Revised: April 18, 2018

This Privacy Policy describes (i) what information Menlo Equities (“Menlo”, “us” or “we”) collects from users of and the services offered thereon (collectively, the “Website”), (ii) how we protect such information, (iii) how we may use and disclose that information, and (iv) what choices you have about how that information is used and disclosed.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING OUR WEBSITE. When you use our Website, you understand that we may collect, use and disclose data and information about you in various ways subject to the terms of this Privacy Policy.

If you do not agree with our Privacy Policy, you are not authorized to access or use or provide information through our Website. The most recent effective date of this Privacy Policy is listed at the top of this page. Please periodically link to and review this Privacy Policy as we reserve the right to make updates to our Privacy Policy at any time. Your continued use of our Website subsequent to the posting of any updated Privacy Policy means you agree to comply with any such updated terms. If you have questions about this Privacy Policy, please contact us at the contact information listed in Section X (How to Contact Us).

I. What Information We Collect From You

A. Information You Voluntarily Provide
We will collect information that identifies you (“Personal Information”) when you voluntarily provide such information to us through our Website. If you choose to provide us with Personal Information, you consent to the transfer and storage of that information on our servers.

B. Cookies and other Information Collected through Technology
You should be aware that in some cases, your computer needs to accept cookies from a website to take full advantage of its services. This is especially true on sites that require a user ID or a password. In order to provide better service, Menlo may use “cookies” in connection with the Website. Cookies are small files that your web browser places on your computer’s hard drive.

We may use cookies to let us know that you are a prior user of the Website and to retrieve certain information previously provided by you. We also may use cookies to keep track of information about your current “session” which will be discarded as soon as you log out or close your web browser. This information also allows us to statistically monitor how many people are using our Website and for what purpose. However, if you do not wish to receive cookies, or want to be notified of when they are placed, your internet browser may permit you to do so. In many internet browsers, you can change the browser settings to warn you before accepting cookies or to block cookies. If you block cookies, you may not be able to use certain web site features or functions, or the Website may not operate in an optimal mode.

We do not track our users across third party websites and thus our Website does not respond to the Do Not Track (“DNT”) settings in your web browsers. However, some third party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, certain website browsers allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

We may also use services hosted by third parties, such as Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to assist in providing the services on or through our Website. Google Analytics uses cookies to help us analyze how users use such services. The information generated by the cookies about your use of our Website (including your IP address) will be transmitted to, and stored by, Google on their servers. Google will use this information for the purpose of evaluating your use of our Website, compiling reports on Website activity for us and providing other services relating to Website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Website. By using our Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

II. How We Use Your Information That We Collect Online

A. To Provide Information and Services
We use the information that we collect from you to provide you with the information and services offered through our Website, to support and enhance your use of our Website, to monitor which features of the Website are used most and to allow us to determine which features of the Website we need to focus on improving.

By providing an email or telephone number, you consent to us contacting you at that number for the purposes outlined in this Privacy Policy. You may revoke your consent by emailing us at We will use commercially reasonable efforts to respond to your access request within 30 days.

We may also use non-Personal Information collected from users of the Website in the aggregate, so that we can improve our Website and for business and administrative purposes.

B. Diagnose Website Problems
Menlo may use your Internet Protocol (IP) address and other non-Personal Information to help diagnose problems with our computer server, and to administer the Website. Your IP address is also used to gather broad demographic data. It is not stored or linked to your personal profile information, such as name or contact information.

III. Disclosure of Your Information to Third Parties

A. To Provide Services
We will not give, sell, rent, loan or otherwise disclose any of your Personal Information to any third party, unless (1) you have specifically authorized us to do so, (2) we are legally required to do so, for example, in response to a governmental subpoena, court order or other legal process, (3) it is necessary to do so in order to protect and defend our or a third party’s rights or property, or to protect the safety of the public or any person or (4) pursuant to a business transfer as discussed in Section.

B. Third Party Service Providers
We may employ third party companies and individuals to facilitate our provision of the service offered through our website, to provide such services on our behalf, provide customer support, perform Website related services (e.g., maintenance services, database management and login and password verification, web analytics and improvement of the Website’s features) or to assist us in analyzing how our Website is used. These third parties may have access to your Personal Information, but only to the extent needed to perform these tasks on our behalf, and we will contractually require them to protect and safeguard your Personal Information to at least the same extent that we do under this Privacy Policy.

C. Business Transfer
In the event that all or a substantial portion of the assets, business or equity of Menlo is acquired by, merged with or transferred to another party, or in the event that Menlo goes out of business or enters bankruptcy, your Personal Information may be one of the assets that is transferred to or acquired by the third party. You acknowledge that such transfers may occur, and that any acquirer of Menlo or its assets may continue to use your Personal Information as set forth in this Privacy Policy. If any acquirer of Menlo or its assets will use your Personal Information contrary to this Privacy Policy, you will receive prior notice.

D. Law Enforcement
Menlo cooperates with public authorities, government and law enforcement officials, and governmental agencies to enforce and comply with the law. We will disclose any information about you to public authorities, government or law enforcement officials, or governmental agencies as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas and lawful government requests), to protect the property and rights of Menlo or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical or legally actionable activity.

E. Aggregated or De-Identified Information
Menlo may share aggregated and/or de-identified data collected from users of the Website (i.e., data that is not Personal Information) with third parties for various business purposes including product and service development and improvement activities related to our services.

IV. How We Secure Your Information

We have procedures that limit Menlo’s employees and contractors’ access to Personal Information. Only those employees and contractors with a business reason to know have access to such information. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, mandatory training programs, and internal policies on data privacy and corporate integrity. We take appropriate disciplinary measures to enforce employee privacy responsibilities.

Please bear in mind, however, that no Internet transmission is ever 100% secure or error-free. More specifically, information transmitted to or from the Services may not be via a secure connection. As a result, you should take particular care in deciding what information you send via our Website.

Any information you provide to Menlo through use of the Website may be stored and processed, transferred between and accessed from the United States and other countries which may not have the same level of protection of personal information as the one in which you reside. Menlo will handle your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is stored or accessed.

We will retain your Personal Information as long as necessary to provide you the services offered there through and the other permitted uses specified in Section II above, and for a reasonable transition time thereafter. We may store aggregated and anonymized information (i.e., information that is not Personal Information) indefinitely.

V. About Minors

Our Services are not directed at or intended for use by minors. Therefore, we do not wish to receive, nor do we knowingly collect, Personal Information from minors via our Website. No one under age 13 may provide any Personal Information to Menlo on or through our Website. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at

VI. Transfer Across Jurisdictions

We are a US-based company so the Personal Information that we collect from you may be transferred to, and stored at, a destination outside of your country and the European Economic Area (“EEA”) and, in particular, the United States, which may have different or less protective privacy laws than those in your country. Personal Information may also be processed by any service providers appointed by us who operate outside the EEA and their staff, and/or our own staff based outside of the EEA. By using our Website and providing Personal Information to us, you consent to such transfer to, and processing in, the United States.

If you have a complaint or dispute regarding this privacy policy or our processing of your Personal Information, and you are not satisfied by our response, you have the right to lodge a complaint with a supervisory authority.

VII. Links to Other Sites

This Privacy Policy covers the treatment of Personal Information gathered when you are using or accessing our Website. This Privacy Policy does not apply to practices of third parties that we do not own or control, including but not limited to, any third party sites.

Menlo does not control these third party sites and is not responsible for the content or the privacy policies or practices of any third party site. If you connect to third party sites from a link on our Website, we encourage you to consult the privacy policy of each site you visit.

VIII. Access, Deletion and Opt-Out Rights

You have the right to access, correct or delete Personal Information held about you by Menlo. To the extent allowed, any requests to exercise such rights may be subject to a small fee to meet our costs in providing you with details of the Personal Information we hold about you. Should you wish to access the Personal Information held about you, please let us know by contacting us at the contact information provided below.

You may also request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes or choose to opt out of such disclosure. Our policy is not to disclose Personal Information collected online to a third party for direct marketing without your approval. To make a request or to opt out at any time, please contact us at the contact information provided below.

IX. Your Consent
By using our Website, you consent to the collection, use and disclosure of information as described in this privacy policy.

X. How to Contact Us

If you have any questions, comments, or concerns about this Privacy Policy as it pertains to the collection and use of your Personal Information provided to us online, please contact us at:

Menlo Equities
2765 Sand Hill Road, Suite 200
Menlo Park, CA 94025
Telephone: (650) 326-9300

XI. Changes to this Privacy Policy

This Privacy Policy was last updated as of the “Last Revised” date listed above. Menlo reserves the right to change this Privacy Policy from time to time. We will let you know that the policy has been changed by changing the “Last Revised” date listed below. If the changes are material, we will provide you additional, prominent notice as appropriate under the circumstances. Minor changes to our Privacy Policy may occur that will not significantly affect our use of Personal Information without notice or consent. We encourage you to refer to this Privacy Policy on an ongoing basis to ensure you are aware of any updates. If revisions to the Privacy Policy are unacceptable to you, you must cease using our Website.