Collection of Personal Information
Depending on how you choose to use the Site, we may need you to provide the following information:
- to contact us - name, address, e-mail address, telephone number and other contact details along with any other information you choose to provide;
- to login to our client/investor portal - username and password; and
- to subscribe to certain communications - email address and country of residence (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication).
We also collect IP address, network location, and other technical information outlined in the section entitled “Use of Technology and Cookies.” For information on technology and cookies used on the Site, see the section entitled “Use of Technology and Cookies” below.
Office Visitors and Callers
When you visit SCP offices or telephone certain SCP employees, we may collect certain personal information such as:
- name, organization and other contact details;
- date and time of your visit to SCP offices; and
- voice prints and telephone numbers during the recording of telephone calls (recording of telephone calls made to or from certain personnel in SCP’s London office is required by MiFID II)
- Third-Party Service Providers, Vendors and Suppliers
In the process of engaging third-party service providers, vendors and suppliers, SCP may collect certain personal information about them and/or about their individual representatives and associates including:
- name, job title, telephone number, email address and other contact details;
- the name of the third-party service provider, vendor or supplier with whom you are associated and its address; and
- information required to process payments, such as a tax I.D. number and wire instruction details.
We may also collect personal information about you from companies who maintain anti-money laundering and terrorism sanction screening and know your customer databases.
When you submit a job application through our website or a third-party website for an open job position, we will process your personal information for purposes of recruitment.
Business Contacts and Prospective Clients and Investors
SCP may collect personal information about individuals or representatives of organizations with whom SCP has a business relationship (or with whom SCP seeks to establish a business relationship), as well as prospective clients and investors. Such information may include:
- name, address, telephone number, email address and other contact details;
- organization name and address, job title; and
- investor type, strategy, product and communication preferences (if you choose to receive marketing communications, you will have the option to opt out of receiving such communications at any time by contacting us or unsubscribing via a link in the particular communication).
Use of Personal Information
Your personal information will be processed: (i) in order to comply with our legal and regulatory obligations; (ii) because we need the information in order to comply with our obligations under contract; and/or (iii) because we have a legitimate business interest in processing it, including for the following purposes (as applicable):
- to respond to your questions and handle and resolve complaints;
- to perform research with respect to the usage of the Site (applicable to website visitors);
- to personalize and enhance your website experience (applicable to website visitors);
- to fill open job positions as part of a recruiting process;
- to maintain the security of our premises, personnel, assets, systems and intellectual property and to manage access to our premises and our disaster recovery procedures (applicable to office visitors);
- to pay you for your services (applicable to third-party service providers, vendors and suppliers);
- in order to comply with our obligations in connection with record-keeping requirements and applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of jurisdictions in which SCP conducts business (applicable to office callers, third-party service providers, vendors and suppliers);
- to maintain and provide appropriate management of our relationship with you;
- to exchange mail correspondence or documentation which may involve providing your contact details to couriers and service providers in charge of the delivery service;
- to engage your services in the future (applicable to third-party service providers, vendors, suppliers and business contacts);
- to contact you to set up meetings and/or phone calls between you and your SCP business contact(s); and
- to process your subscription requests and to send marketing communications about SCP to you (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication) (applicable to website visitors, business contacts and prospective clients and investors).
Where required by applicable law, we will obtain your prior consent before sending you direct marketing communications.
For information on how we use and process technology and cookies on the Site, see the section entitled “Use of Technology and Cookies” below.
SCP processes personal information only for legitimate business purposes and at all times in compliance with applicable law and/or regulation.
Sharing and Transfer of Personal Information
We may share the personal information we store about you with:
- SCP affiliated entities (within and outside the EEA);
- third-party service providers, vendors, contractors, and agents of SCP as part of normal business operations, including providers:
- engaged to assist in know your customer and identity verification and anti-money laundering and terrorism screening (applicable to third-party service providers, vendors and suppliers);
- of accounting, banking and other data processing services;
- of information technology services and platforms/applications;
- of courier services or other package delivery services;
- of call recording and storage services (applicable to office callers);
- third party outsourcing providers;
- building security personnel (applicable to office visitors);
- third parties acting on your behalf such as consultants and other agents;
- governmental authorities and/or law enforcement officials where required;
- financial institutions to wire payments to you (applicable to third-party service providers, vendors and suppliers);
- advisors who provide audit, financial and legal advice to SCP; and
- other parties to a merger, acquisition, reorganization, funding/investment round or similar transaction or proceeding involving SCP, or steps in contemplation of such activities.
SCP may also disclose your personal information to particular parties pursuant to your express consent, to fulfill your instructions, to comply with applicable laws and regulations or to fulfill other applicable requirements.
Personnel employed by service providers generally may have access to your personal information for the purpose of performing duties for SCP but are prohibited from using such information for other purposes.
When transferring personal information from within the EEA or the Cayman Islands to countries outside the EEA or the Cayman Islands, we comply with European Union law by using Standard Contractual Clauses approved by the European Commission or by adopting other means to ensure that adequate safeguards are applied (including, where relevant, transfers to a recipient with an appropriate Privacy Shield certification or appropriate arrangements in compliance with obligations in the Cayman Islands). If you would like more information on how we comply with transfer requirements please contact firstname.lastname@example.org.
Safeguarding of Personal Information
SCP maintains established internal policies and procedures as well as physical and electronic safeguards that comply with applicable standards to safeguard access to personal information in our possession from accidental or unlawful destruction, loss, alteration, unauthorized use or disclosure. We endeavor to limit access to personal information about you to those employees, agents and other authorized parties who need to know the information to enable SCP to provide products or services to you. Please note that such safeguards, however, do not guarantee that personal information transmitted via the Internet or stored in our systems or is otherwise under SCP’s care will be absolutely safe from unauthorized use or intrusion from third parties due to the inherent nature of the Internet.
Retention of Personal Information
Personal information stored by SCP is generally retained for a period of ten years from (a) the date the data record was created or (b) a particular trigger event depending on the type of data record containing the personal information. Examples of trigger events are (i) the tax filing year in which an invoice for services received is paid, (ii) date of contract expiration or termination, and (iii) account closure or fund dissolution date.
The rights described in this paragraph are applicable to you only if you reside in a jurisdiction where the provision of such rights is required by the data protection and privacy laws and regulations of the governing regulatory authority. As such, where required by applicable law or regulation, you may ask SCP for a copy of your personal information, to correct it, to erase it or to transfer it to other organizations. You may also have rights to object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent. In particular, you have rights to object to direct marketing at any time.
You should also be aware that these rights may be limited (for example, access to personal information may be denied if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information). In addition, SCP may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your personal information. Where we must collect and process personal information in order to comply with applicable law or enter into and perform services under an agreement with you, if you do not provide the personal information we may not be able to enter into the agreement or provide services as contemplated by any agreement we have in place. Where we are not able to fulfill a request you make because your rights are limited, we will inform you of the reasons as to why when responding.
PRIVACY STATEMENT-CALIFORNIA – THIS SECTION APPLIES TO CA CONSUMERS ONLY
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of SCP and its subsidiaries and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice.
The categories of information SCP collects and how SCP uses such personal information is explained above in the section titled “Collection of Personal Information” and in the section titled “Use of Technology and Cookies” below. If a consumer wishes to have their information deleted then they may request that the firm do so, however, the firm can refuse to delete personal information that the firm maintains in order to do any of things listed in 1798.105 (d)(1)-(9) of the CCPA.
The consumer has the right to request a report concerning their personal information that contains the information specified in 1798.110 (a) of the CCPA concerning the consumer’s personal information. The firm will in no way discriminate against a consumer who makes a request under the CCPA.
To request a report the consumer can reach out to email@example.com or call the following number +212 993-1670.
SCP does not sell or otherwise share personal information except in the ordinary course of business. SCP also does not provide personal information to third parties except as outlined above, and in the Use of Technology and Cookies section of this document.
Should you have any questions or requests in relation to your rights, please email firstname.lastname@example.org. We will attempt to deal with all requests at the earliest opportunity. In addition, if you have unresolved concerns you have the right to complain, where permitted, to competent data protection authorities.
Use of Technology and Cookies
We may use third-party web analytics services on our Site. These service providers help us analyze how visitors use the Site. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers.
The providers of third-party plugins and widgets on our Site, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Site and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.
We use the following types of cookies on our Site (note that some cookies may fall into multiple categories):
Test Cookies - These cookies are simply to test whether or not your browser supports cookies. It stores a simple “True” or “False” value. If True, then the below cookies are applied.
Tracking Cookies - These cookies are used to track anonymous user movement throughout the site for statistical purposes. For example, it may track the duration of a user’s visit to a certain page or for example, to allow the Company to determine the number of users that visited a given page of the Site, or that read a certain press release.
Required Cookies - These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for, such as remembering your login details, cannot be provided.
Analytics Cookies - These cookies remember choices you make, such as the duration of your session. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized (such as the IP address through which you visit the Site) and they cannot track your browsing activity on other websites. The Company uses a Google Analytics cookie to collect this information; you have the right to opt-out of having the Google Analytics cookie placed on your browser.
You may also be asked to agree to allow us to use particular analytics cookies while you browse the Site. If you receive our cookie consent banner, you may click “Cookie Consent Tool” to see which cookies we have on our Site and choose whether to accept or opt-out of certain cookies while on the Site. Should you choose not to give your consent for us to use some or all of the analytics cookies on our Site, these cookies will not be placed on your browser while you browse the Site.
You may configure your browser to set preferences regarding cookies such that you can have your computer warn you each time a cookie is sent. Note that you may decline placement of cookies if your internet browser permits, though this may impact your experience of using the Site, and certain portions of the Site may be inaccessible to you if you choose to do so. You may at any time delete any cookies from your hard drive. Aggregated data gathered from cookies is used by the Company to help maintain and improve the information provided on this Site for users. The Company may also employ other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We take seriously the protection of your personal information and have contracts in place with these authorized third parties to protect your personal information. We may also use these technical methods in HTML e-mails that we send Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. The Company may collect the information from use of these technical methods in a form that is personally identifiable.
You can manage cookies using various means:
1. Browser Setting. Your browser likely supports a variety of settings to control the cookies that are set on your computer or device and to delete cookies. These settings are typically found under the “Tools”, “Settings”, or “Options” menus. You can also check the “Help” menu of your browser to learn how to change the cookie preferences through your browser settings. Note that you will need to manage the settings for each browser and device you use. Further information from several popular browsers can be found on your browser’s support site:
- Apple Safari
- Google Chrome
- Microsoft Internet Explorer
- Microsoft Edge
- Mozilla Firefox
2. Online Tools. Some third parties allow you to manage cookies through online tools such as: Network Advertising Initiative, Digital Advertising Alliance, Your Online Choices, Adobe Flash, and the Interactive Advertising Bureau (IAB) Europe.
- In order to opt out of Adobe and Google Analytics Cookies across our websites, visit:
- Adobe Analytics
- Google Analytics
You can opt out of cookies to tailor content or advertising to you by visiting the above links. Note that if you choose to opt out, you won’t necessarily see fewer ads. However, the ads you see may be less relevant to your interests.
3. Browser Extensions. Some third parties have created software that can be added to your web browser to manage their or third-party cookies. Further information from several popular browsers can be found on your browser’s support site, such as: Google Analytics and Ghostery by Evidon, Inc.
Our reference to any third party or their software or services is not an endorsement by us of such third party or their products and services and we disclaim any liability for the use or operation of any third-party software or services.
Do Not Track
We do not track visitors of the Site over time and across third party websites to provide targeted advertising and therefore the Site does not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.
Links to Third-Party Websites
The Site may contain links to third party websites which, in some cases, may be integrated into, and appear to be part of, the Site. SCP encourages you to read the privacy policies of other websites you link to from this website and disclaims any responsibility for the privacy policies and procedures of any third party websites that you reach via a hyperlink contained on this Site. Such hyperlinks are provided for your convenience only, and you access them at your own risk.
Solar Capital Partners LLC
500 Park Avenue, 3rd Floor
New York, NY 100722
p +212 993-1670