Sculptor Capital Management Group, Inc. and its affiliates (“Sculptor”, “we,” “us,” “our”) is committed to protecting and respecting your privacy and personal information.
I. PERSONAL INFORMATION WE COLLECT – SOURCES AND CATEGORIES
Information You Provide To Us
The categories of personal information we may collect from all the above sources include the following:
Information We Collect Through Other Means
Cookies and Other Technologies
Sculptor Europe records the telephone lines of certain of its personnel (“Monitored Lines”) in order to comply with its legal / regulatory obligations and/or where in its legitimate interests (i) to monitor / ensure compliance with internal policies and procedures, (ii) to protect the safety of clients, employees and third parties, and (iii) to comply with our regulatory and legal requirements. Where you receive a telephone call from our personnel via one of these Monitored Lines and/or make a telephone call to one of these Monitored Lines, your conversation will be recorded by Sculptor Europe. The recordings are retained for 5 years.
II. HOW WE USE YOUR INFORMATION
We have set out below, a description of the ways we use your personal information (referred to as “processing purposes” below), and for individuals located in the EEA or the UK we explain which of the legal bases we rely on to do.
|Categories of Personal Information||Processing Purposes||Legal Basis (where you are located in the EEA or the UK)|
|Personal Identifiers; and Internet or other electronic activity information.||To provide our Services to you: (i) provide access to certain areas, functionalities, and features of our Services; and (ii) communicating with you about your account including to respond to your requests and enquiries, and in relation to activities regarding our Services and policy changes.||
To pursue our legitimate interests in providing the requested information and/or information about our processing of your personal information in an effective and efficient manner.
|Personal Identifiers; and Internet or other electronic activity information.||For business administration: including to conduct market research and statistical analysis.||To pursue our legitimate interests in managing our business effectively and efficiently through market research and statistical analysis.|
|Personal Identifiers; and Internet or other electronic activity information.||Personalization: to personalize your visit to the Site and to assist you while you use the Site.||
To pursue our legitimate interests in tailoring the Site to your needs in order to provide a more effective Service to you.
|Personal Identifiers; and Internet or other electronic activity information.||Site improvement: to improve the Site by helping us understand who uses the Site.||
To pursue our legitimate interests of improving the Site in order to provide a more effective Service to you.
|Personal Identifiers; and Internet or other electronic activity information.||Quality assurance: for quality and training purposes.||To pursue our legitimate interests to ensure our Site is of the highest quality and to train our personnel to deliver a high quality Service.|
|Personal Identifiers; and Internet or other electronic activity information.||Transactions: To enable any due diligence and other appraisals or evaluations for any actual or proposed merger, acquisition, financing transaction or joint venture contemplated by Sculptor.||To pursue our legitimate interests to operate and improve our business.|
|Personal Identifiers; and Internet or other electronic activity information.||To prevent or detect crimes.||To comply with a legal obligation, e.g. to report a crime to a law enforcement agency.
To pursue our legitimate interests to prevent or detect crimes.
|Personal Identifiers; and Internet or other electronic activity information.||Legal claims: To defend and enforce our rights including, against legal claims that involve us, and to manage regulatory matters, investigations, data breaches, and/or data subject requests.||
To comply with a legal obligation, e.g. to respond to an official request or data subject request.
To pursue our legitimate interests to defend and enforce our rights.
If you are located in the European Economic Area and the United Kingdom: You have a right to object to the processing of your personal information where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfil such requests in all instances.
You are able to request a copy of the legitimate interest assessment carried out by us. Where we need to collect the abovementioned categories of personal information by virtue of a legal obligation or in light of a contract entered or to be entered into with you, and you do not provide this personal information when requested, we may not be able to comply with our legal obligations, provide you with the Services or perform the contract we have or are trying to enter into with you. In such case, we may have to terminate our relationship with you.
III. DISCLOSING YOUR INFORMATION FOR BUSINESS PURPOSES
We may disclose your personal information to service providers that help us operate our business, including for the processing purposes identified in the previous section of this Policy.
IV. INTERNATIONAL DATA TRANSFERS
Our Site is hosted in the U.S. Therefore, when you disclose personal information to us, this personal information will be transferred to the U.S.
If you are located in the EEA/UK, Sculptor may, for the purposes listed in Section II, transfer your personal information to other recipients as referred to above, that are also located in countries outside the EEA/UK, including the U.S., and which are not currently considered by the European Commission and/or UK Government to provide an adequate level of data protection. In these circumstances, Sculptor will take steps to ensure that the personal information is protected including by entering into Standard Contractual Clauses or similar (“SCCs”) with the recipient, seeking assurances from the recipient that they have Binding Corporate Rules in place or otherwise relying on a derogation for the transfer (e.g., where the transfer is necessary for the defense of legal claims).
You can request further information on the data transfer solutions relied upon including, a copy of the SCCs by using the contact details in Section X below.
V. YOUR PRIVACY RIGHTS
California Privacy Rights
California Do Not Track
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browsers’ do not track signals.
EEA / UK Privacy Rights
Residents in the EEA and UK have the following privacy rights, subject to applicable limitations:
Right of Access: you have the right to confirm what data is being processed, obtain information about the processing activities and to receive a copy of your personal information;
Right to Rectification: you have the right to request rectification / correction of your personal information where it is inaccurate or incomplete
Right to Erasure: you have the right to request deletion of your personal information.
Right to Restriction: you have a right to ask that we restrict or suppress the processing of your personal information which means that whilst we are permitted to store the personal information we cannot otherwise process it.
Right to Data Portability: you have right to request the transfer of certain personal information to a third party, in machine readable format.
Right to Object: you have the right to object to the processing of your personal information including for any direct marketing purposes.
Right to Withdraw Consent: you have the right to withdraw your consent, at any time, without hindrance or cost, to prevent further processing. Please note that withdrawing your consent does not affect the lawfulness of our processing of your personal information based on such consent before the withdrawal.
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we take steps to verify your identity before fulfilling your request.
VI. DATA RETENTION
We retain personal information for a minimum period of 7 years or in accordance with our record retention policy. We will only process your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period, the amount, nature and sensitivity of the personal information are considered, together with the necessity and purposes for the processing (including, whether such purposes can be achieved through other means) and the potential risk of harm from unauthorized use or disclosure of the personal information. In exceptional cases (e.g., in pending litigation matters or where the law requires us to) your personal information may need to be kept for longer periods of time.
VII. SECURITY OF YOUR INFORMATION
VIII. CHILDREN’S INFORMATION
The Services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
IX. OTHER PROVISIONS
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority.
Third Party Websites
X. CONTACT US
Sculptor Capital Management, Inc.
9 West 57th Street
New York, New York 10019