Privacy Policy

This privacy policy describes how Strategic Value Partners, LLC and its subsidiaries and affiliates (collectively, “SVP”, “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 our website (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 SVP).

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 Personal Information to us, including your name, email address, mailing address, phone number or other information. You may provide such 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” below.

Information Collected from Our Website

When you visit our website, we may use “cookies” or related technologies for a variety of purposes, including improving your website experience and understanding how individuals interact with our website. We may also use cookies to collect technical information from your computer, including your IP address and other information about your computer. No information directly identifying you is collected in the process; however, cookies and other online identifiers may be considered Personal Information under certain data protection laws. As is typical for most websites, we do not change our practices, described elsewhere in this privacy policy, in response to Do Not Track browser settings or signals.

If you communicate with us through this website (e.g., through email), SVP 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 SVP has collected about you.

Sensitive Personal Information

We may collect information that is considered “sensitive” under some data protection laws. For example, we may collect Social Security numbers or other government identifiers related to individuals who are investors in our funds, as well as from our employees and contractors when they provide them to us. In order to administer the employment relationship or provide benefits, we may collect health related information from employees and contractors. We may also collect information about race and ethnicity or similar information that candidates for employment or our employees or contractors voluntarily provide for equal opportunities monitoring. We, or our vendors on our behalf, store account log-in information from users of our investor portal.

When we collect sensitive Personal Information, we use such information only for lawful purposes in compliance with applicable data protection laws, such as to perform the services or provide the goods requested by you and to resist malicious, deceptive, fraudulent or illegal actions. Where required by applicable law, we will obtain your consent prior to processing such information.

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; and managing and evaluating the effectiveness of our communications);
process your subscription materials, provide information you have requested, create and administer your account, administer your investments and maintain registers;
maintain and enhance the safety and security of our website and prevent misuse;
protect against identify theft 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 SVP

In order to provide you with efficient and reliable services, SVP 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 the administration and management of an investment account you hold with us (or one of our funds) and 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 SVP 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.

In addition, we may disclose Personal Information about you (a) to others, if we are required or permitted to do so by law or legal process, for example due to a court order, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity and (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). If we disclose your information to a private non-regulatory organization, SVP 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 those choosing to opt-out can be excluded from the communications those companies send on SVP’s behalf.

Children’s Privacy

Our services are not intended for and may not be used by children under the age of 16. We do not knowingly collect information from children under the age of 16 and we do not target children under the age of 16.

Region-Specific Disclosures

Notice to Persons Located in the European Economic Union

Under applicable EU and United Kingdom data protection laws and regulations, if you are a person who is located in the EEA or the United Kingdom, you are entitled to certain rights. Please see our GDPR Privacy Notice at https://www.svpglobal.com/wp-content/uploads/SVP-EU-and-UK-GDPR-Privacy-Notice-Final-6.30.2023.pdf. If you wish to exercise any of these rights, you should contact SVP’s General Counsel at generalcounsel@svpglobal.com. 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 prospective 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 SVP’s General Counsel at generalcounsel@svpglobal.com. 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 at https://www.svpglobal.com/wp-content/uploads/Data-Protection-SVP-Cayman-Islands-Website-Privacy-Notice-Final-6.30.2023.pdf.

Notice to Persons Whose Personal Information is Processed by Us in the Dubai International Financial Centre (“DIFC”)

Under Data Protection Law DIFC Law No. 5 of 2020, if you are a person whose Personal Information is processed in the DIFC, you are entitled to certain rights. Please see our DIFC Privacy Notice at https://www.svpglobal.com/wp-content/uploads/Data-Protection-SVP-DIFC-Website-Privacy-Notice-Final-6.30.2023.pdf. If you wish to exercise any of these rights, you should contact SVP’s General Counsel at generalcounsel@svpglobal.com, or via any of the methods set out in our DIFC Privacy Notice. You also have the right to lodge a complaint about the processing of your Personal Information with the DIFC data protection authority.

Notice to Persons Located in California

Under the California Consumer Privacy Act, if you are a person who is located in California, you may be entitled to certain rights. Please see our CCPA Privacy Notice at https://www.svpglobal.com/wp-content/uploads/SVP-California-Consumer-Privacy-Act-Privacy-Notice-Final-6.30.2023.pdf.

You may have certain rights under the CCPA. These include the right to: (i) know the categories of Personal Information we collect or maintain about you along with other information or obtain a portable copy of such Personal Information; (ii) request the deletion of your Personal Information that we collect or maintain; (iii) correct inaccurate Personal Information that we maintain about you; (iv) opt out of the sale or sharing of Personal Information; and (v) limit the use of sensitive Personal Information in some circumstances. If you wish to exercise any of these rights, you should contact SVP’s General Counsel at generalcounsel@svpglobal.com.

Safeguarding of Information

SVP 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 SVP employees who need to know your Personal Information are authorized to access such information, and SVP 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 SVP in the United States of America or other countries which do not have strict data protection laws.

Changes to this Privacy Policy

SVP 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, SVP 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 SVP believes that you have violated or threatened to violate any of SVP’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 SVP 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 SVP’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 InvestorRelations@svpglobal.com or write to us at:

Strategic Value Partners, LLC
100 West Putnam Avenue
Greenwich, CT 06830
Attn: Investor Relations

This Privacy Policy is dated and effective as of June 30, 2023.

Disclosure Related to Our Representative Office in Dubai

Strategic Value Partners, LLC is regulated as a representative office by the Dubai Financial Services Authority (“DFSA”). These marketing materials relate to a financial product, which is not subject to any form of regulation or approval by the DFSA. The DFSA has no responsibility for reviewing or verifying any prospectus or other documents in connection with this financial product. Accordingly, the DFSA has not approved this document or any other associated documents, nor taken any steps to verify the information set out in this document and has no responsibility for it. The financial product to which this document relates may be illiquid and/or subject to restrictions on its resale. Prospective purchasers should conduct their own due diligence on the financial product. If you do not understand the contents of this document, you should consult an authorized financial adviser.