Privacy Policy

This privacy policy describes how Strategic Value Partners, LLC and its subsidiaries and affiliates (collectively, “SVPGlobal”, “we”, “us” or “our”) collects and uses personal information (i.e., information that directly or indirectly identifies a person, including any investor, prospective investor, employee, consultant, job applicant or visitor to www.svpglobal.com, collectively, such information, “Personal Information”).  In particular, this privacy policy describes (a) the type of Personal Information that we may collect, (b) how we use that Personal Information and (c) the conditions under which we may disclose that information to affiliates and to non-affiliated third parties.

By completing a subscription agreement, visiting our website or providing us with your Personal Information in any way, you agree that we may collect and use the information as set forth in this Privacy Policy. You should review this Privacy Policy carefully, because if you do not agree with our practices, you should not provide us with your Person Information (which includes completing a subscription agreement, visiting our website or conducting business with SVPGlobal).

 

Types of Personal Information That We May Collect

Information You Provide to Us

In order to receive our services or interact with us (e.g., as an investor, job applicant or third-party service provider), you may provide us Personal Information, including your name, email address, mailing address, phone number or other information.  You may provide that Personal Information to us by various means, including our website, via email directly or through a subscription process.

Information We Collect or Generate About You

We may produce a record of our relationship with you and any Personal Information that you provide during telephone and email communications with us.  We may update and maintain that record for a period of time.

Information We Obtain From Other Sources

We may obtain information from your agents and advisers and from third parties and public sources that we use to verify your identity or to confirm your eligibility to use our services in accordance with our legal obligations. If you visit our website, we may also obtain information through our website.  See “Information Collected from Our Website.”

Information Collected from Our Website

When you visit our website, we may use “cookies”.  We may use cookies for a variety of purposes, including improving your website experience.  We may also use cookies to collect technical information from your computer, including your IP address and other information about your computer. No Personal Information is collected in the process.

If you communicate with us through this website (e.g., through email), SVPGlobal may receive Personal Information that you choose to share with us. Additionally, if you elect to enter the password-protected area of the website, then (a) our website will recognize who you are and will collect all information that you submit and (b) any information collected about you from our website may be associated with other information that SVPGlobal has collected from other sources about you.

 

How Do We Use Your Personal Information?

We may use the information we obtain about you to:

  • communicate with you (and, where required by applicable law, we will obtain your explicit consent to do so);
  • personalize your experience on our website;
  • operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving our website, products and services; developing new products and services; managing and evaluating the effectiveness of our communications;
  • maintain and enhance the safety and security of our website and prevent misuse;
  • protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
  • comply with and enforce applicable legal requirements, relevant industry standards and policies.

In compliance with relevant law, we may retain information as needed or appropriate to serve our legitimate business purposes or as required by law.

Disclosure of Your Personal Information within SVPGlobal

In order to provide you with efficient and reliable services, SVPGlobal may share your Personal Information with our affiliates as required or permitted by applicable law.

Disclosure of Your Personal Information to Non-Affiliated Third Parties

We do not disclose Personal Information to non-affiliated third parties, except as permitted by law.  In the normal course of providing services, we may disclose certain Personal Information to:

  • broker-dealers that provide trade execution services, custodians that provide custody services and other business services providers in connection with investment decisions, with respect to an investment account that you hold with us (or one of our funds) and/or to enable us to provide services and operate our business;
  • advisers (e.g., auditors, legal counsel and tax advisers) to SVPGlobal relating to or in connection with the operation of our business, compliance with our legal, regulatory or contractual obligations and/or your investments with us; and
  • law enforcement agencies, regulatory or tax authorities and other governmental or public agencies or authorities in order to comply with our legal or regulatory obligations or at their request in furtherance of their objectives.

If we disclose your information to a private non-regulatory organization, SVPGlobal requires that these companies agree to (a) maintain the confidentiality of your Personal Information and (b) limit the use of such Personal Information to the purposes for which it was provided. Furthermore, in compliance with privacy laws, we also provide our opt-out lists to non-affiliated third party companies so that they can be suppressed from the communications those companies send on SVPGlobal’s behalf.

 

Notice to Persons Located in the European Economic Union

Under applicable EU data protection laws and regulations, if you are a person who is located in the EEA, you are entitled to certain rights. Please see our GDPR Privacy Notice. If you wish to exercise any of these rights, you should contact SVPGlobal’s Legal and Compliance Department at the address below.  You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority.

Notice to Investors and Prospective Investors in Cayman Islands-domiciled Funds

Under The Cayman Islands Data Protection Law, 2017 (the “Cayman Islands DPL”), if you are an investor or a perspective investor who has submitted Personal Information to one of our funds incorporated or formed in the Cayman Islands, you are entitled to certain rights under the Cayman Islands DPL. If you wish to exercise any of these rights, you should contact SVPGlobal’s Legal and Compliance Department at the address below.  You also have the right to lodge a complaint about the processing of your Personal Information with the Cayman Islands data protection authority.  Please see our Cayman Islands Privacy Notice.

Safeguarding of Information

SVPGlobal maintains reasonable standards of confidentiality and security for this website and the Personal Information collected from this website. These standards are designed to safeguard such information against loss or theft, and unauthorized access, disclosure, copying, use or modification.  Only SVPGlobal employees who need to know your Personal Information are authorized to access such information, and SVPGlobal also requires its affiliates and service providers to limit employee access to the data. Despite our reasonable efforts, it is possible that someone may intercept or access communications, transmissions and/or Personal Information. Furthermore, if you access this website from a country with strict data protection laws you should be aware that, by interacting with this website, you may be sending information about yourself to SVPGlobal in the United States of America or other countries which do not have strict data protection laws.

 

Changes in this Privacy Policy

SVPGlobal reserves the right in its sole discretion to modify or amend this Privacy Policy in any way and at any time. Any such modifications or amendments are effective upon posting unless we indicate otherwise. You should review this Privacy Policy periodically for changes applicable to you. Please see the bottom of this Privacy Policy for the date of the latest version. Additionally, note that by using or accessing this website subsequent to any modification or amendment, you are deemed to have agreed to this Privacy Policy as modified or amended.

Governing Law

Use of this website and this Privacy Policy shall be governed by the laws of the State of Connecticut of the United States of America, without regard to its conflict of law provisions.

Any dispute concerning this Privacy Policy or your use of this website shall be submitted to binding arbitration in Greenwich, Connecticut within one (1) year from the date that the cause of action arose (or, if multiple cause of actions are involved, from the date that the first cause of action arose), with such arbitration conducted pursuant to the then prevailing rules of the American Arbitration Association. To the fullest extent permitted by law, no arbitration brought pursuant to this Privacy Policy shall be joined to any other arbitration initiated pursuant to this Privacy Policy.

Notwithstanding anything to the contrary set forth in this Privacy Policy, SVPGlobal may at any time seek injunctive or other appropriate relief against you and/or against others, in any state or federal court in the State of Connecticut or in any other court having jurisdiction, in the event that SVPGlobal believes that you have violated or threatened to violate any of SVPGlobal’s intellectual property rights and, in such case, you hereby consent to the exclusive jurisdiction and venue of such court.

In the event that any portion of this Privacy Policy is deemed unenforceable, unlawful or void by a court of competent jurisdiction, in any jurisdiction for any reason, including but not limited to the scope, duration or area of its applicability, unless narrowed by construction, such provision shall for purposes of such jurisdiction only, be construed as if such invalid, prohibited or unenforceable provision had been more narrowly drawn so as not to be invalid, prohibited or unenforceable (or if such language cannot be drawn narrowly enough, the court making any such determination shall have the power to modify, to the extent necessary to make such provision or provisions enforceable in such jurisdiction, such scope, duration or area or all of them, and such provision shall then be applicable in such modified form in such jurisdiction). If, notwithstanding the foregoing, any such provision would be held to be invalid, prohibited or unenforceable in any jurisdiction for any reason, such provision, as to such jurisdiction only, shall be ineffective to the extent of such invalidity, prohibition or unenforceability, without invalidating the remaining provisions. No narrowed construction, court-modification or invalidation of any provision shall affect the construction, validity or enforceability of such provision in any other jurisdiction. No waiver by SVPGlobal of any term or condition of this Privacy Policy shall be deemed a further or continuing waiver of such term or condition or of any other term or condition, and SVPGlobal’s failure to assert any right or demand compliance with any provision of this Privacy Policy shall not be deemed to constitute a waiver of any such right or provision.

 

Contact Us

If you have any questions concerning this Privacy Policy, you may contact us at compliance4@svpglobal.com or write to us at:

Strategic Value Partners, LLC
100 West Putnam Avenue
Greenwich, CT 06830
Attn: General Counsel

This Privacy Policy is dated and effective as of September 30, 2019.

Copyright © 2019 Strategic Value Partners, LLC. All rights reserved.