Last Updated and Effective October 2023
When you visit the Site and during our ordinary business activities, the Firm may collect or ask you to provide certain nonpublic personal information (“Personal Information”) in order to help us manage our relationship with you and serve your investment needs.
The categories of Personal Information we may collect will depend on the nature of our relationship with you and the purpose for which information is being collected. The Personal Information we may collect from you may include personally identifiable information, including names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, information on investment activities or other personal information.
We may carry out background checks in the context of pre-employment screening or in connection with customer due diligence checks that we are required to undertake in compliance with our anti-money laundering and financial sanctions compliance obligations and obtain information on your credit history, criminal and administrative offences, or other special categories of personal data (including ethnic origin, health and disability) that may be contained in relevant documents or materials.
We may collect Personal Information from:
Your communications with us;
Your transactions with us;
Publicly available information (including publications and social media); and
We use Personal Information for the following business purposes:
To provide our products and services;
To administer our contractual relationship;
To process your requests and inquiries;
To offer new products and services;
To process transactions;
For account maintenance;
To confirm your identity;
To communicate with you;
To improve the Site;
To protect the security and integrity of the Site;
To prevent or investigate fraud or other unlawful activity, and detect security incidents; and
To comply with and enforce applicable legal requirements.
Your privacy is important to us. The Firm does not disclose any Personal Information to nonaffiliated third parties, except to service or manage a client’s account or as permitted by law. We do not sell any Personal Information.
The Firm seeks to carefully safeguard Personal Information. We will use commercially reasonable efforts to ensure that Personal Information is kept secure and safe from any loss or unauthorized disclosure or use. We restrict access to our client’s Personal Information to employees who require that Personal Information in order to provide products or services to our clients.
You have certain rights in respect of the personal data we hold about you and which you may exercise. These rights are:
to request access to your information;
to request rectification of inaccurate or incomplete information;
to request erasure of your information (a “right to be forgotten”);
to restrict the processing of your information in certain circumstances;
to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
where relevant, to request the portability of your information;
where you have given consent to the processing of your data, to withdraw your consent; and
to lodge a complaint with the competent supervisory authority.
If you are in the United Kingdom, you have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO’s website.
Due to the international nature of our business, your personal data may be transferred to countries outside the United Kingdom and EEA, including countries that may not have the same level of data protection as that afforded by the UK General Data Protection Regulation or EU General Data Protection Regulation (collectively, “GDPR”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of GDPR, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.
Last updated: October 2023
This notice contains disclosures required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”). Terms defined in the CPRA have the same meaning when used in this notice. This notice is only relevant to California residents (“consumers” or “you”), including job applicants and employees.
Identifiers. Examples: a real name, alias, email address, postal address, account name, social security number, driver’s license number, passport number, or other similar personal identifiers.
Other personal information categories, as listed in the California Customer Records Statute. Examples: a signature, telephone number, employment, employment history, bank account number, or other financial information.
Protected classification characteristics under California or federal law. Examples: age, citizenship.
We collect Personal Information from the following categories of sources:
Your communications with us;
By observing your actions on our website;
Service providers, including, but not limited to: administrators, lenders, banks, brokers, auditors, law firms, consultants, placement agents, employment agencies, benefit and payroll providers, credit bureaus;
Affiliates not under the Diameter Capital Partners LP brand;
Nonprofit organizations; and
We do not knowingly sell or share Personal Information of consumers under the age of 18.
Providing you with information about our products and services;
Providing you with performance and other updates;
One or more of the following business purposes:
Performing services (for us or our service provider or contractor) such as account servicing, processing orders and payments, and analytics;
Auditing related to our interactions with you;
Detecting and protecting against security incidents, fraud, and illegal activity;
Internal research for technological improvement;
Activities to maintain and improve our services;
Short-term, transient use, such that the personal information is not disclosed to another third party and is not used to build a profile about you; and
Employment related interactions and activities, including those relating to: natural persons in the role or former role of job applicant, employee, director, officer, medical staff member, or independent contractor processing job applicants; the administration of benefits and payroll; and maintaining emergency contact files.
The use of sensitive personal information is limited to only those purposes authorized under the CPRA.
Legal or government regulatory authorities as required by applicable law;
In connection with a potential business transfer; and
Third parties to whom you or your agents authorize us to disclose such information in connection with services we provide to you.
In the past 12 months, we have not sold or shared (for cross-context behavioral advertising) Personal Information to third parties.
Length of Time. We will keep your Personal Information for as long as necessary to comply with our regulatory obligations.
The right to request: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our business or commercial purposes for collecting, selling or sharing your Personal Information; (d) the categories of Personal Information disclosed for a business purpose or shared with third parties (for cross-context behavioral advertising) and the categories of persons to whom it was disclosed or shared; (e) the categories of your Personal Information (if any) that we have either sold, shared, or disclosed.
The right to request that we delete your Personal Information, subject to certain exceptions.
The right to opt out of our sale(s) (if any) of your Personal Information to third parties or sharing with such third parties for the purpose of cross-context behavioral advertising.
The right to request we correct any inaccurate Personal Information maintained about you.
The right to limit our use of your sensitive personal information to only use that is necessary to perform the services expected or provide the goods reasonably expected.
The right not to receive discriminatory treatment for exercising your CPRA rights.
You may submit requests relating to your exercise of CPRA rights to us via [email protected].
You may only make a verifiable request for access or data portability twice within a 12-month period. All verifiable requests must provide (1) enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent and (2) sufficient detail that allows us to properly evaluate and respond to it. We may need to request additional information from you to verify your identity or understand the scope of your request. If we are unable to verify your identity, we will need to deny your request. You may designate an authorized agent to make a CPRA request on your behalf and we reserve the right to seek proof that you have given the authorized agent signed permission to act on your behalf.
We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
If you have questions regarding this Notice, please contact us at [email protected].