Website Privacy Policy
Our Commitment to Privacy
Visitors who are residents of the United Kingdom, the European Union or the European Economic Area should refer to our EU Privacy Notice supplement.
Your privacy is important to Clearstream Capital LLC and its affiliates (together, “Clearstream,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
This Website Privacy Policy (this “Privacy Policy”) describes how we gather and use information for visitors of this website. Please read this Privacy Policy carefully. If you do not agree with any of the terms and conditions contained herein, please do not access or otherwise use this website.
This Privacy Policy constitutes a legally binding agreement between Clearstream and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, the Privacy Policy stated herein, our Terms and Conditions and all additional terms incorporated by reference herein. If you do not agree to this Privacy Policy, please do not access or use this website.
The Information We Collect and How We Use It
We may collect various types of information from users of this website. Clearstream generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” page.
To the extent that you provide us with any personally identifiable information through or in connection with this website, we may use such information for Clearstream’s business purposes, but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to Clearstream, you consent to Clearstream’s use of such personally identifiable information for the purposes described in this Privacy Policy.
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.
Capacity
You represent to Clearstream that you have the authority to visit this website. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
Cookies
You may access any personally identifiable information we have about you by contacting Andrew Ward, Chief Compliance Officer of Clearstream, at compliance@clearstreamcapital.com.
This website uses Google Analytics and Google Tag Manager, which collects information on site visitors and usage through cookies. For more information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners. By using the website you hereby understand and consent to Google’s collection and processing of any data submitted by you to Clearstream (including personally identifiable information such as IP address, domain name, webpage, the length of time spent on the site, or the pages accessed while visiting the site).
Notifications of Changes
We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.
Miscellaneous
The provisions in our Terms and Conditions are hereby incorporated by reference.
Contact Us
If you have any questions or concerns about this Privacy Policy, please contact Andrew Ward, Chief Compliance Officer of Clearstream, at compliance@clearstreamcapital.com.
EU Website Privacy Policy
Our Commitment to Privacy
Your privacy is important to Clearstream Capital LLC and its affiliates (together, “Clearstream,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
This EU Website Privacy Policy describes how we gather and use information for visitors of this website, or investors who use our online investor portal, in each case, that are from the EU and supersedes the Privacy Policy of Clearstream linked to this website with respect to EU users, as applicable. Please read this EU Website Privacy Policy carefully.
For the purposes of applicable EU laws, Clearstream and its affiliated general partners and managing members will each be a data controller of any personal data collected by us. If you have any questions regarding our use of your personal data, or this EU Website Privacy Policy, please contact Andrew Ward, Chief Compliance Officer of Clearstream, at compliance@clearstreamcapital.com.
We rely on various legal bases under applicable data protection legislation in order to process your personal information (e.g., name, title, address, email, date of birth, IP address, financial data, etc.), including our legitimate interests, contractual necessity and as required by law. We use the personal information we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Further information about the legal bases under which we process your personal information is included in the section headed “Why we use your personal information.” You do not need to take any action as a result of this EU Website Privacy Policy, but you do have certain rights as described below in the section headed “Your rights.”
How We Obtain Your Personal Information
Information you provide to us
We collect your personal information when you decide to interact with us and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal information via online form, email, post, telephone and this website and when you log into the investor online portal. We also collect information about you through automated technology.
Information provided by third parties or publicly available sources
We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. In this situation, your personal data will be provided to us by third parties involved in that potential transaction (including the target of any investment).
Why We Use Your Personal Information
To the extent that you provide us with any personal information, through or in connection with this website (i.e., via online form, telephone, email or post) or the investor online portal, we may use such information for the following purposes:
| Purpose | Legal Basis |
|---|---|
| To provide you with the services or products you have requested | Contractual necessity |
| To keep a record of your relationship with us | Legitimate interest |
| To verify your identity | Legal requirement |
| To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to | Legitimate interest |
| Fraud and abuse prevention | Legitimate interest |
| Litigation management and conducting internal audits and investigations | Legitimate interest |
| To administer and protect our business and this website | Legitimate interest |
| To make suggestions and recommendations to you about goods or services that may be of interest to you. | Legitimate interest |
No automated decision-making, including profiling, is used when processing your personal information.
Marketing
We may send you direct marketing communications to keep you informed of our products and services in which you might be interested either where we have obtained your prior consent or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in to certain kinds of marketing, and all forms of marketing at any time, by emailing Andrew Ward, Founder and Managing Partner of Clearstream, at info@clearstreamcapital.com. You can also click on the “opt-out”/unsubscribe link provided in our marketing emails, if applicable, or by contacting Andrew Ward, Founder and Managing Partner of Clearstream, at info@clearstreamcapital.com.
Disclosure And Transfer Of Personal Information
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through this website; any transmission of information or data by you to or through this website is at your sole risk.
Your personal information will be shared with and processed by our affiliates and certain service providers as necessary to fulfill the purposes set out in this policy, including service providers, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them. We seek assurances that our standards for data security are met by anyone who enters into an agreement providing a service to, or for us, involving personal data. To the extent your personal information is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable data privacy laws. For further information about the safeguards/derogations used, please contact Andrew Ward, Chief Compliance Officer of Clearstream, at compliance@clearstreamcapital.com.
We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal information to the new owner of the relevant business and their advisors on the basis of our legitimate interest.
Security And Retention Of Personal Information
We are committed to protecting the personal information you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this EU Website Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact Andrew Ward, Chief Compliance Officer of Clearstream, at compliance@clearstreamcapital.com.
Capacity
This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
Cookies
This website uses Google Analytics and Google Tag Manager, which collects information on website visitors and usage through cookies. For more information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners. Information regarding how you access this website (e.g., browser type, access times and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.
Your Rights
You have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact Andrew Ward, Chief Compliance Officer of Clearstream, at compliance@clearstreamcapital.com.
- Access: You have the right to ask for a copy of the personal information that we hold about you free of charge; however, we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
- Correction: You may notify us of changes to your personal information if it is inaccurate or it needs to be updated.
- Deletion: If you think that we should not be holding or processing your personal information any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
- Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
- Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Notification of Changes
We reserve the right to amend this EU Website Privacy Policy from time to time by updating this EU Website Privacy Policy. If we decide to change our EU Website Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with this EU Website Privacy Policy under which the information was collected.
Contact Us
If you have any questions or concerns about this EU Website Privacy Policy, please contact Andrew Ward, Chief Compliance Officer of Clearstream, at compliance@clearstreamcapital.com.
Complaints
Should you wish to lodge a complaint with regards to how your personal information has been processed by us, please contact your local supervisory authority.
