MAKARORA
WEBSITE PRIVACY POLICY
Last Updated: July 25, 2025
This Website Privacy Policy (“Privacy Policy”) describes how Makarora Management LP (“Makarora,” or “we,” “us,” or “our”) collects, uses, shares, retains, and otherwise processes your personal information, what choices you have relating to your personal information, and how you can contact us. It applies to information collected when you visit our website (the “Website”). Please note that we may provide you with different or additional privacy notices when we collect personal information in certain other contexts or for specific purposes.
By browsing, accessing, or using our Website, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.
This Privacy Policy may be updated by us from time to time with or without notice to you.
Please visit Sections 11, 12 and 13 for additional privacy rights and disclosures relevant to, respectively: (1) EU, Swiss, and UK residents; (2) residents of particular U.S. states, and (3) California residents.
1. The Personal Information We Collect
Makarora collects personal information directly from you, and automatically when you use our Website. For purposes of this Privacy Policy, “personal information” means information that identifies, relates to, or describes an individual. This does not include aggregated or de-identified information that is maintained in a form that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual.
a) Personal Information Collected Directly From You
We will ask you for certain personal information to provide you with the products or services you request. The personal information we collect from you depends on how you interact with us or how you use our Website, and may include contact information, such as your name, email address, postal address, and phone number, as well as any other information you disclose in your interactions with us.
b) Personal Information Collected Automatically
We and our third-party service providers automatically collect personal information related to your use of our Website and interactions with us and others, including when you enable certain features within our Website. This information may include:
Device information. When you interact with our Website, we may collect technical information about your device including your IP address; unique identifiers; unique device identifier and device type; domain, browser type, version, and language; operating system and system settings; general location information and time zone; and similar device and usage information.
Location information. We may collect or derive approximate or precise location information about you. How we collect this information depends on how you use and interact with our Website and on your device settings. For example, we may derive your general location through your IP address. We may collect your precise geolocation (GPS) information from your device or browser. You may turn off precise location information sharing through your device settings.
Online Activity and Browsing Information. We may use cookies, log files, pixel tags, software development kits (“SDKs”) and other tracking technologies to automatically collect information about your interaction on our Website and with the communications you receive from us. This information includes links clicked, page views, purchases, searches, features used, items viewed, time spent on the Website, and information uploaded.
3. How and Why We Use Your Personal Information
Makarora collects, uses, discloses, and otherwise processes your personal information to provide the Website and services you request, such as responding to your inquiries, to communicate with you, and to improve the functionality of the Website.
4. How We Disclose and Share Personal Information
Makarora may disclose and share the personal information we collect with the following types of entities and recipients:
Agents, Administrators, Affiliates, Providers and Other Third Parties. We may share your information with third-party service providers who assist us in operating our Website, conducting business, or providing services to you. These other companies will have access to personal information only as necessary to perform their functions and to the extent permitted by law. We may also share your personal information with any of our parent companies, subsidiaries, or other companies under common control with us.
Aggregated Information. We may share aggregate data with our affiliates, agents, and business partners, and may share this aggregate information to other unaffiliated third parties.
Business Transfers. As we develop our company, we might sell or buy other assets or businesses. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, your personal information may be part of the transferred assets associated with such transactions.
Legal Requirements and Enforcement of Our Policies. To the extent permitted by law, we may also disclose your personal information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of Makarora or others. We may disclose your personal information to enforce our rights arising from any contracts entered into between you and us, including our Terms of Use and this Privacy Policy or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Makarora, our users, or others.
With Your Consent. We may also disclose your personal information to fulfill any purpose for which you provide it or for any other purpose disclosed by us when you provide this information.
5. Children's Privacy
We do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian and you believe we have collected your child’s personal information, please contact us as outlined in Section 15 below.
6. Protection of Personal Information
We use a variety of technical, administrative, and organizational security measures that are intended to protect your personal information. Please be aware that despite our efforts, no data security measures can guarantee security. You can help keep your data safe by taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.
7. Retention of Personal Information
We will retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected and processed, including to satisfy any legal, regulatory, accounting, or reporting requirements. To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk from unauthorized use or disclosure, the purposes for which we process personal information, and whether we can achieve those purposes through other means, and applicable legal requirements.
8. Managing Your Privacy Rights and Choices
a) Updating Your Information
If you would like us to update the information we have about you, please contact us as outlined in Section 15 below.
b) Managing Your Cookie Preferences
There are several ways that you can manage your preferences for cookies and advertising by us and on our Website. You can review or change your preferences for most cookies and tags on our Website, other than those that are necessary for operation and functionality, by adjusting your cookie settings in your browser. These preferences are browser- and device-specific, so you will need to set your preferences for each browser and device you use, and if you subsequently delete or block cookies, you may need to reapply these settings. Please note that if you decide not to accept cookies from us, certain aspects of the Website may not be available or function properly.
c)Do Not Track
Some web browsers may give you the ability to enable a “do not track” setting that is an HTTP header field indicating your preferences regarding user tracking or cross-site tracking. We do not recognize web browser “do not track” signals at this time, and we do not alter our Website’s data collection and use practices when we see a do not track signal from your browser. Instead, information collection and disclosure practices and the choices that we provide to users will continue to operate as described in this Privacy Policy, whether or not a “do not track” signal is received. For more information about “do not track,” please see http://donottrack.us.
9. External Sites
The Sites may contain links to other third-party websites, products or services not owned or controlled by Makarora (“External Sites”). Makarora has no control over the privacy practices or the content of these External Sites. As such, we are not responsible for the content or the privacy policies of those External Sites, and you should check the applicable third-party privacy policy and terms of use when visiting any External Sites.
10. Notice for International Users
Makarora is based in the United States. However, our service providers or business partners may process data both in and outside the United States, where the privacy laws may differ from those in your country of your residence. Please be aware that your personal information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. To lawfully conduct the transfer in such instances, we may, depending on the circumstances: (i) rely on an “adequacy decision” from the European Commission; (ii) put in place safeguards deemed appropriate under applicable law, a copy of which you may request by contacting us as set forth under Section 15; (iii) rely on your explicit and informed consent; or (iv) after providing prior notice of our intent to transfer your personal information, conduct the transfer as necessary for the performance of a contract or the implementation of pre-contractual measures.
11. Additional Privacy Notice for EU, Swiss and UK Residents
a) Legal Bases for Processing Your Personal Information. When we process your personal information, we will only do so in the following situations:
As a matter of “contractual necessity,” meaning that we need to process the data in order to provide you with requests made through the Website. When we process data due to contractual necessity, failure to provide such personal information will result in your inability to use some or all portions of the Website or requested services that require such data.
When processing such information furthers the legitimate interest of us or third parties. For example, we process the personal information we collect from you to communicate with you about changes to the Website or services, and to help provide, secure, and improve the Website or our services.
Your Right to Object: Where we are using your information because we have a legitimate interest in doing so, you have the right to object to that use.
When you give us express consent. When we process personal information based on your consent, it will be expressly indicated to you at the point and time of collection. You can withdraw your consent at any time. You can do this by contacting us through the methods provided in Section 15.
In response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
b) Your Privacy Rights. If you are in the EU, Switzerland, or the UK, you have the right to:
Request a copy of the personal information Makarora holds about you (including in a structured, commonly used, machine-readable format where applicable under the right of data portability),
Request that Makarora transmit your personal information to another controller (where applicable under the right of data portability),
Request that Makarora correct your data,
Request that your data be deleted,
Withdraw your consent, if you have consented to our use of personal information for a specific purpose,
Request that your data be restricted, and
Object to the processing of your personal information.
c) How to Submit Privacy Rights Requests.
If you wish to exercise your right to know, delete, or correct inaccuracies in your personal information, please submit a request to us by contacting us as outlined in Section 15 below.
If you are in the EU and have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside.
For contact details of your local Data Protection Authority, please see: https://edpb.europa.eu/about-edpb/board/members_en.
If you are in Switzerland and have such concerns, please see the Federal Data Protection and Information Commissioner website at https://www.edoeb.admin.ch/edoeb/en/home.html.
If you are in the UK and have such concerns, please see the Information Commissioner’s Office website at https://ico.org.uk/.
12. Privacy Notice for California Residents
This California Privacy Notice and Notice at Collection (“California Privacy Notice”) is only applicable to California residents (“you”) and supplements our general Website Privacy Policy. “Personal information” means, in this context, any information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with you or a household.
a) Collection, Use, and Disclosure of Personal Information During the Preceding 12 Months
Categories of Information. In the past 12 months, we have collected personal information about California residents in the following categories:
Identifiers and Categories in Cal. Civ. Code 1798.80(e), such as name, unique personal identifier, online identifier, IP address, email address, account name, phone number or signature;
Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories of tendencies;
Internet or other electronic network activity information, such as browsing history, search history or information regarding interaction with a website, app, or advertisement; and
Geolocation data, such as the state or country associated with your IP address.
Sources. In the past 12 months, we have collected personal information about California residents from the following categories of sources:
Directly from you (if you are a California resident), when you provide it to us digitally or physically (e.g., where you contact us via email or telephone, or by any other means); and
Via cookies and other tracking technologies.
Purposes. In the past 12 months, we have collected and used personal information about California residents for the following business and/or commercial purposes:
To present our Website and its contents to you;
To deliver the information, products, and services you requested from us;
To communicate with you;
To verify or maintain the quality or safety of our services and to improve, upgrade or enhance our services; and
To carry out our obligations and enforce our rights.
Recipients. In the past 12 months, we have disclosed the categories of California residents’ personal information to some or all of the following categories of recipients:
Our affiliates;
Our business partners, service providers and vendors;
Governmental, legal, regulatory, or other similar authorities and/or local government agencies, upon request or where required;
Other third parties to comply with legal requirements or to protect the rights, property, or security of our customers or third parties;
Other parties, if you specifically directed or expressly consented to us disclosing your personal information to them.
b) Sale or Sharing of Personal Information
We do not sell or share, for purposes of cross-context behavioral advertising, your personal information and have not done so in the past twelve months.
c) Minors Under the Age of 16
We do not have actual knowledge that we sell or share the personal information of minors under the age of 16.
d) Your Rights as a California Resident
As a California resident, you may have certain rights in relation to your personal information.
Right to Know. You may have the right to know how we have collected, used, and disclosed your personal information. Specifically, you may have the right to know:
The categories of personal information we have collected about you;
The categories of sources from which we have collected your personal information;
The business or commercial purpose for which we collect, sell, or share your personal information;
The categories of third parties to whom we have disclosed your personal information;
The categories of personal information that we have sold or shared about you and the categories of third parties to whom it was sold or shared; and
The categories of personal information we have disclosed about you for a business purpose and the categories of persons to whom we have disclosed it.
In addition, you may have the right to know the specific pieces of personal information we have collected about you.
Right to Make a Deletion Request. You may have the right to request that we delete the personal information about you that we have collected or received. Subject to certain exceptions, we must delete your personal information and direct our service providers and contractors to do so.
Right to Correct Inaccurate Personal Information. You may have the right to request that we correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
Right to Opt-Out of Sales of Personal Information. If we sold your personal information (as defined by CCPA), you would have the right to opt-out of the sale of your personal information.
Right to Opt-Out of Sharing of Personal Information. If we shared your personal information (as defined by CCPA), you would have the right to opt-out of us sharing your personal information for cross-context behavioral advertising purposes.
Right to Limit Use and Disclosure of Sensitive Personal Information. If we collected sensitive personal information about you (as defined by CCPA), you would, subject to certain exceptions, have the right to limit our use and disclosure of your sensitive personal information. Please note, however, that we do not do so.
Right to Non-Discrimination. You have the right not to be discriminated against by us for choosing to exercise your rights under the CCPA.
e) How to Exercise Your California Privacy Rights
If you wish to exercise your right to know, delete, or correct inaccuracies in your personal information, please submit a request to us by contacting us as outlined in Section 15 below.
f) Information for Authorized Agents
You can authorize a person (“Authorized Agent”) registered with the California Secretary of State to exercise your California privacy rights on your behalf. An Authorized Agent can also include a person who has power of attorney or is acting as a conservator. To submit a request to Makarora on behalf of another person as an Authorized Agent, please submit a request to us by contacting us as outlined in Section 15 below.
g) Verifying Your Requests
We only respond to your requests to know, access the specific pieces of personal information we have about you, delete and correct inaccurate personal information when we can verify that you are a California resident exercising your rights regarding your personal information. We may need to ask you for personal information to verify your request so we can match it with the personal information we already have about you. We may also need to obtain additional information about you that we do not already have. If you provide us with new personal information that we do not already have about you, we will use it solely for the purpose of verifying your request. We will let you know via email if we need more information from you to verify your request. Please reply to our requests promptly. We will communicate with you about your requests via email. We will use the email address you provided when submitting your request. If we cannot verify your identity, we will let you know.
h) Responding To Your Requests
We aim to promptly verify and respond to your requests within 45 days of receipt but may require a total of up to 90 days to respond to your requests. If we require additional time beyond the initial 45 days after we receive your request, we will let you know within the first 45 days. We do not ordinarily charge a fee for our response to your requests. However, we may do so to the extent your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s). If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and of any rights you may have to appeal the decision. Unless you tell us that you would like to receive a response via postal mail, we will respond to you via email regarding your requests to know and to access the specific pieces of personal information we have about you. We will contact you at the email address you provided when submitting your request(s). If you would like to receive responses to a request to know or access personal information via postal mail rather than email, please let us know when submitting your request(s).
i) Other California Privacy Rights
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, call or email us as outlined in Section 15 below, and include in your request a current California address and your attestation that you are a California resident. Please note, however, that we do not, nor have we in the past, shared any personal information with third parties for such purposes.
j) Changes to the California Privacy Notice
From time to time, Makarora may update or revise this California Privacy Notice. If there are changes to the terms of this California Privacy Notice, the documents containing the revised policy on the Website will be updated. If you have any questions or concerns about this California Privacy Notice, please contact us as outlined in Section 15 below.
13. Additional U.S. State Privacy Rights
Depending on your place of residence, you may have certain rights regarding how we collect, use, and share your personal information. Please be aware that some of these rights are subject to limitations, and your request may be declined in specific situations—for instance, if providing the information would compromise another individual’s privacy or if we are legally obligated to withhold such information. These rights may include:
The right to confirm whether we are processing your personal information, and to access your personal information.
The right to request we correct inaccuracies in your personal information.
The right to request we delete your personal information.
The right to request a copy of the personal information you provided to us.
The right to opt out of processing of your personal information for targeted advertising purposes.
The right to opt out of profiling and automated decision-making in furtherance of decisions that produce legal or similarly significant effects.
The right to opt out of the sale of personal information.
The right to designate an agent to submit a request on your behalf.
The right to appeal a decision regarding your rights request.
You can submit a request to exercise these rights by contacting us as outlined in Section 15 below with the subject line “U.S. State Privacy Rights Request” and providing us with your name and the email address associated with your account. Please note, however, that we do not, nor have we in the past, sold any personal information to third parties.
14. Changes to This Privacy Policy
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you, and any such changes will be posted on the Website. Please be aware that, to the extent permitted by applicable law, our use of your personal information is governed by the version of this Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.
15. How to Contact Us
If you have questions about this Privacy Policy, if you would like to exercise any of the rights afforded to you under your state’s privacy statute (to the extent your state affords you such rights), or if you would otherwise like Makarora to change or discontinue the use of your personal information, please contact us via e-mail at info@makarora-lp.com with “Privacy Policy” in the subject line, or call us at
646-647-4133.