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
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.
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.
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/2023/06/GDPR-Privacy-Notice.pdf. If you wish to exercise any of these rights, you should contact SVP’s General Counsel at firstname.lastname@example.org. 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 email@example.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 www.svpglobal.com/wp-content/uploads/2023/06/SVP-Cayman-Islands-Privacy-Notice.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/2023/06/SVP-Global-DIFC-Website-Privacy-Notice.pdf. If you wish to exercise any of these rights, you should contact SVP’s General Counsel at firstname.lastname@example.org, 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/ccpa-privacy-policy/.
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 email@example.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.
Strategic Value Partners, LLC
100 West Putnam Avenue
Greenwich, CT 06830
Attn: Investor Relations
Copyright © 2023 Strategic Value Partners, LLC. All rights reserved.
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.