Effective July 30, 2024
(This Policy may be updated from time to time.)
CC Capital Partners LLC (“CC Capital” or “we”) is committed to protecting your privacy. Our Privacy Policy (the “Policy”) governs the way in which we treat personal information that we collect and receive from our clients in connection with our provision of services and related communications, including but not limited to by means of third-party SMS services or email.
“Personal Information” is information that individually identifies you; examples include your mobile phone number, email address, name, mailing address, phone number, birthdate, social security number, driver’s license number, bank account information, IP address, sensitive economic information, etc.
The types of personal information we collect and share depend on the relationship we have with the personal information owner (e.g., client, employee, contractor). Such information can include:
• Business and Personal Contact Information (e.g., name, postal and email addresses, phone numbers)
• Demographic Information (e.g., age, race, gender, citizenship)
• Financial and Other Client Information (e.g., date of birth, banking information, account numbers, taxpayer identification numbers, jurisdiction of tax residence, investment-related information, income, employment information)
• Background and Security-Related Information (e.g., government-issued identifiers, passport information and licenses)
• Information From Third-Party Data Providers and Public Sources (for compliance obligations, screening and other legal and regulatory obligations)
• Security Video or Photo Footage on our premises
• Electronic Communications with Us and Related Information (e.g., IP addresses)
• Employment Data Provided in Connection with Job Inquiries or Applications
• Other Information You Provide
We use personal information to:
• Provide you with our services, products and analysis
• Respond to inquiries
• Communicate information to you
• Contact you with important announcements or messages
• Create and manage your account with us
• Operate, evaluate, develop, advance and improve our business
• Manage our premises
• Manage your investments
• Perform internal functions such as audit and regulatory compliance
• Protect against financial and business crimes such as theft of intellectual property or proprietary materials
• Protect against, identify and prevent fraud, money laundering, cyber attacks, and breach of confidence
• Compliance with legal and regulatory obligations related to the Patriot Act
• Providing promotional and/or marketing materials
• Manage employment applications
• Perform data analysis
• Operate, schedule and hold online meetings, conferences and webinars through online platforms (e.g., Zoom)
• Record audio and video content (where permitted by law)
• Record and monitor details of your electronic interactions with CC Capital and our service providers
We may also use collected information in other ways for which we provide specific notices.
Unless otherwise indicated, if we request personal information from you, we need it for our business or regulatory compliance purposes. In some limited instances we may request personal information for legal compliance reasons. In addition, we may request that you provide personal information on a purely voluntary basis. If our request for information is for legal compliance or voluntary reasons, we will so advise you of that.
We only process personal information we collect as required for the purposes listed above. Where we process your personal information in connection with our legitimate business interests or those of a third party, we do so after concluding that our doing so does not prejudice you or your privacy in a way that would override our legitimate interests in doing so for such purposes.
If you are a former employee, contractor, officer or partner of CC Capital, we will continue to process your personal information for a reasonable period following the end of your relationship with us for our legitimate business, legal compliance purposes and/or for the establishment or defense of a legal claim. In addition, we may process your personal information to perform our contractual obligations to you, such as paying final salary or severance. We only process your personal information after we have concluded that doing so does not prejudice you or your privacy in a way that would override our legitimate interests in doing so for such purposes. Your personal information will be retained and deleted in accordance with our retention policies and procedures.
We may share personal information with affiliates in connection with administering funds or other investment vehicles managed by us or our affiliates.
We only share personal information with third parties as permitted by applicable federal and state law.
We do not rent or sell personal information to other companies or individuals. We may use or disclose personal information in any of the following limited circumstances:
• We have your consent
• We need to enforce agreements between us
• We provide personal information to third parties with whom we have nondisclosure agreements
• We provide personal information to third parties/businesses that we have engaged for the purpose of processing such information on our behalf, where the terms of engagement oblige those parties to process such information only on our instructions and in compliance with this Policy and appropriate confidentiality and security measures. If such parties fail to comply with our terms, CC Capital is not liable for any reimbursement or losses.
• We respond to subpoenas, court orders, regulatory requests and other legal processes
• We believe that it is necessary to share personal information to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats to the physical safety of any person
• We may transfer personal information in the event CC Capital is merged with or acquired by another company.
• We may share anonymous information with service providers, including benchmarking services, to facilitate our business operations.
• We may transfer personal information about you to recipients in countries other than the country in which it was collected. Those countries may have different data protection laws from the country in which you initially provided the information. When we transfer personal information across borders, we comply with applicable laws and regulations.
• No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
We maintain administrative, technical and physical safeguards to protect personal information we obtain from you against accidental, unauthorized, or unlawful, access, destruction, loss, alteration, disclosure or use. In the event of a security breach, we will comply with applicable laws regarding notification and remediation of the breach.
We endeavor to keep your personal data accurate and up-to-date. We retain personal information for as long as it is required for our legitimate business purposes or as required by law or regulation (which may be longer than our ongoing relationship with you).
We will delete your personal information (and other information) that we hold when we no longer need to retain it. We will retain your personal information in accordance with our retention policies and, in any event, for no longer than it is necessary for the purposes for which it was collected or retained, after which it will be deleted or anonymized.
Certain jurisdictions provide consumers with the right to request deletion of their personal information. We comply with such laws where applicable.
Please note that we may retain some limited information about you so that we can maintain a continuous relationship with you if and when we are in contact again.
Limitations on Sharing
Federal law gives you the right to limit sharing of your personal information only in connection with certain purposes:
• Sharing with affiliates to market to you
• Sharing for affiliates’ everyday business purposes (creditworthiness)
• Sharing with nonaffiliates to market to you
State or non-U.S. laws may give you additional rights to limit sharing.
We follow state or non-U.S. law if it provides you with additional privacy protections, including:
CALIFORNIA residents - If you do not want us to share your information with our affiliates regarding your creditworthiness or to market their products and services to you, please let us know by contacting us at the email address below.
VERMONT residents - we automatically treat customers with a Vermont mailing address as having limited our sharing with affiliates unless you give us authorization for such sharing by contacting us at the email address below.
NORTH DAKOTA residents - We will not disclose information we collect about you to unaffiliated third parties to market to you, other than as permitted by North Dakota law, unless you authorize us to make those disclosures by contacting us at the email address below.
NEVADA residents - We are providing you this notice under state law. You may be placed on our internal Do Not Call List by contacting us at operations@cc.capital. Nevada law requires we provide the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Avenue, Suite 3900, Las Vegas, NV 89101;
Phone number: 702-486-3132; email: AgInfo@ag.nv.gov.
TEXAS residents – We do not sell personal information. You may have additional rights regarding your personal information under the Texas Data Privacy and Security Act. If you have questions or requests regarding the processing, storage or use of your personal information or you wish correct or delete it, please contact our Compliance Department at operations@cc.capital or by mail at CC Capital Partners LLC, 200 Park Avenue, 58th Floor New York, NY 10022, Attn: Compliance Dept.
Rights of Access
You may have a right of access to the personal information that we have collected from or about you and some related information. You may also have the right to require correction or deletion of any inaccurate personal information.
Data Portability
In some circumstances, you may have a “data portability right” to require us to transfer your personal information to a third party in a data portable format.
Contact
To limit our sharing of your information or exercise any of the other rights outlined above, please contact us at operations@cc.capital or by mail at CC Capital Partners LLC, 200 Park Avenue, 58th Floor New York, NY 10022, Attn: Compliance Dept.
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