Our Online Privacy Policy explains how Crescent Cove Advisors, LP, or its legal affiliates (“Crescent Cove,” “we” or “us”) and some of the companies we may work with collect, use, or disclose personal information and data we receive through use of our website, mobile applications, and any other online services we offer (collectively, the “Services”).  The policy also gives you choices about the collection and use of your information.

Please read the Online Privacy Policy carefully before you start to use our Services. By using the Services, you represent and warrant that you are of legal age to form a binding contract with us, meet any eligibility requirements in the Terms of Use, and agree to be bound and abide by the Terms of Use and our Online Privacy Policy.  If you do not agree to the Terms of Use and our Online Privacy Policy, or if you violate them in any way, your right to access or use the Services is terminated.

If you are a customer of Crescent Cove, we may receive additional personal information from or about you, which will be subject to the terms set forth in a separate agreement with us and/or a Consumer Privacy Notice that we provide to you.

Please see Sections 11 through 13 of the Terms of Use regarding restrictions on your legal rights in any dispute involving our Services, Terms of Use or Online Privacy Policy.

We may revise and update the Online Privacy Policy from time to time in our sole discretion.  Where appropriate, we may provide advance notice of an update. You agree that we may provide notice of updates by posting a new policy on the Services, and that your subsequent use of the Services constitutes agreement to the updated policy.

1. INFORMATION WE COLLECT

We may collect the following categories of information.

• Information you voluntarily provide, such as your name, email, address, and phone number, login credentials, profile information, and communications between you and Crescent Cove.  For example, you may submit comment forms on the website, subscribe to our mailing list, use our investor portal, or communicate with us via email regarding our business or the Services.
• Information that is passively collected:
• Analytics information: We may use third-party analytics tools to help us measure website traffic and usage, and these tools may collect information sent by your device or the Services, including the web pages you visit, add-ons, and other information that assists us in improving the Services.

• Cookies and similar technologies: When you visit the Services, we may use “cookies” which are small files stored as text on a computer hard drive.  These “cookies” and other similar technologies like pixels, web beacons (also known as “clear GIFs”, and local storage may be used to collect information about how you use the Services and provide features to you.  If a visitor does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies.
• Mobile Device Unique Identifier: When you use a mobile device to connect to our Services via a service provider that uniquely identifies your mobile device, we may receive this unique identifier.
• Log file information:  Log file information may be automatically recorded when you use the Services, such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to individuals which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.

2. THE PURPOSES FOR WHICH YOUR INFORMATION IS USED

In general, we use personal information to:

• Provide investment services to you, if you are a customer;
• Contact you regarding our business and provide customer support;
• Help you efficiently access information after you sign in and remember information so you will not have to re-enter it during your visit or the next time you visit the Services;
• Monitor metrics such as total number of visitors, traffic, and demographic patterns; and
• Diagnose or fix technology problems, and develop improvements to the Services.

3. SHARING OF YOUR INFORMATION

We are not in the business of sharing or selling personal information about the users of our Services to third parties, and have not done so in the past 12 months.  However, we may share your information to affiliates, service providers we engage to provide the Services (e.g., website hosting and maintenance), or third parties as necessary to facilitate business functions or transactions on your behalf (e.g., investment activities).

In addition, we will access, preserve, and share any information about you, without your consent, to government regulators or law enforcement officials or private parties as we in good faith believe necessary or appropriate to respond to claims and legal process (including, but not limited to, subpoenas), to comply with applicable laws, to protect the property and rights of Crescent Cove, you or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to pose a risk of being, or is illegal, unethical or legally actionable. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.  We may also share you information as reasonably necessary in connection with a merger, acquisition, bankruptcy or other transaction in which a third party assumes control of all or part of our business provided that information will be used or shared consistent with this policy.

4. HOW WE STORE YOUR INFORMATION

By using the Services you consent to the transfer of information to anywhere in the U.S. where we or our service providers maintain facilities.  We generally retain information as needed for business and legal purposes, but your information may potentially be retained indefinitely to the extent consistent with the Terms of Use and applicable law.  Although we implement reasonable security measures designed to protect personal information from unauthorized access, we cannot ensure the security of any information you transmit to or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures of any breach of personal information.  To the extent the law of your jurisdiction allows for notification of a breach via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

5. YOUR RIGHTS ABOUT YOUR INFORMATION

• You may have the right under applicable law to make certain requests about the personal information we maintain about you, and who we disclose it to.  This may include:

• Request disclosure of use: You may have the right under applicable law to request a copy of the following regarding your personal information:  (1) The categories of personal information we collected about you; (2) The categories of sources from which the personal information is collected; (3) The business or commercial purpose for collecting or selling the personal information; (4) The categories of third parties with whom we share personal information; and (5) The specific pieces of personal information we have collected about you.
• Request disclosure of sales or sharing: To the extent we have sold or shared your personal information (excluding service providers, facilitating transactions, legal purposes and other such circumstances), you may have the right under applicable law to request a copy of the following information: (1) The categories of your personal information that we collected; (2) The categories of your personal information that we sold and the categories of third parties to whom it was sold; and (3) The categories of personal information that we disclosed for a business purpose.
• Request correction or deletion of personal information:  You may have the right under applicable law to request that we correct or delete your personal information (subject to certain exceptions).
• Right to object to sales:  To the extent we sell or share your personal information with third parties (excluding service providers, facilitating transactions, legal purposes and other such circumstances), you may have the right under applicable law to direct us not to do so.

To exercise any of these rights, please contact us at 415-795-8597, ir@crescentcove.com or by mail at: 530 Bush Street, Suite 703, San Francisco, CA 94108.  We will respond as required by applicable law and as otherwise deemed appropriate in our reasonable discretion under the circumstances.

We do not discriminate against individuals who exercise such rights, and do not offer financial incentives in connection with the exercise of such rights.

• To the extent we use text messaging to contact you, you may opt-out of receiving text messages by replying “STOP” to any text message received.
• Emails:
  • In all promotional emails, you will be given the opportunity to opt-out of receiving such messages in the future by clicking on the link at the bottom of the email that says “unsubscribe.” It may take up to ten (10) business days for us to process your opt-out request.
  • Please note, we reserve the right to send you Services-related communications (e.g., account verification, payment confirmations, technical and security notices) that you may not opt out of.
  • Even if you have unsubscribed from receiving promotional emails from us, we may send you other types of important email communications without offering you the opportunity to opt-out of receiving them, such as customer service announcements and administrative notices.
• If you do not want information collected through the use of cookies, most web browsers allow you to reject cookies within the available settings.

6. CHILDREN’S PRIVACY

We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such individuals to use the Services. The Services and their content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.

7. HOW WE RESPOND TO DO NOT TRACK SIGNALS

We do not track users over time and across third party websites to provide targeted advertising.  We does not respond to Do Not Track (DNT) signals and handle all user information consistent with our Terms of Use and this Online Privacy Policy.

8. OTHER WEB SITES AND SERVICES

The Services may contain links to other websites or services that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the Services, including the information or content contained within them. Your browsing and interaction on any third-party website or service, including those that have a link on our Services, are subject to that third party’s own rules and policies, not ours.

You agree that we are not responsible and do not have control over any third-parties that you authorize to access your personal information or login credentials, and you do so at your own risk.

9. INTERNATIONAL CONSIDERATIONS

Crescent Cove operates in the United States. While our primary data centers are in the United States, we may transfer personal information or other information outside of the United States. In addition, we may employ other companies and individuals to perform functions on our behalf. If we disclose personal information to a third party or to our employees outside of the United States, we will seek assurances that any information we may provide to them is safeguarded adequately and in accordance with this Online Privacy Policy. By providing your personal information, you consent to any transfer and processing in accordance with this policy.

10. HOW TO CONTACT US

Please direct questions or concerns about this Online Privacy Policy or the Services to us at compliance@crescentcove.com or by mail at: 1700 Montgomery Street, Suite 240, San Francisco, CA 94111

The effective date of this Online Privacy Policy is April 30, 2019.