This Privacy Policy (the Policy) describes how Crestline collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and our websites.
In this Policy when we refer to Crestline or “we”/”us”/”our” we mean Crestline Management, LP, Crestline Europe, LLP and other entities that are associated with us. If you are a resident of the European Union (EU) or the United Kingdom (UK), the GDPR, to the extent applicable, imposes certain obligations on us, as a data controller, and grants certain rights to data subjects located in the EEA or UK (“data subject,” “you” or “your”). This Privacy Policy provides information on our use of your personal data in accordance with, each as amended from time to time and as applicable, the EU General Data Protection Regulation (Regulation (EU) 2016/679) (together with applicable implementing laws, the “EU GDPR”), or by the EU GDPR as retained by The Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 pursuant to the European Union (Withdrawal) Act 2018 (each as amended, and together with the UK Data Protection Act 2018 and other applicable implementing laws, “UK GDPR”, and together with the EU GDPR as applicable, “GDPR”).The rights discussed in certain sections of this Privacy Policy may be subject to exemptions or other limitations under applicable law.
If you are a California resident, please review our section “Additional information for California residents” for additional disclosures, our Notice at Collection, and a description of your rights under the California Consumer Privacy Act.
We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.
This Policy describes:
“Personal information” is any individually identifiable information or information that, in combination with other information, could reasonably allow the identification of an individual.
We will collect and process the following categories of personal information about you:
We may process personal information that you provide us through direct interactions, including when you email us or contact us through various channels as follows:
We will also collect information about when you use our services or when we otherwise interact or correspond with you. We use various technologies to collect and store information when you visit our website. We may, for example, collect information about the type of device you use to access the website, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites and other interactions with our website or use of certain online tools, the web pages and the search terms you enter on our websites. For information about how we use Cookies and the choices you may have, please see our Cookies Policy.
In addition to the categories of personal information above, through the various sources mentioned above, we may collect the following personal information:
We do not disclose any non-public personal information about you to anyone, except as permitted or required by law and regulation.
We seek to carefully safeguard your private information and, to that end, restrict access to non-public personal information about you and only our employees and service providers that have a “need to know” your information to perform their jobs, such as to conduct our business, and who have agreed to the proper handling of such information and who have agreed to keep the information confidential are authorized to have access to your personal information. It may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them. We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information. In addition, we will continue to assess new technology for protecting information with regard to our investors.
We may do the following with your personal information:
Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
We rely on the following legal grounds to process your personal information, namely:
Failure to provide your personal information may affect our ability to provide services to you.
We share personal information among our US and international offices and the various companies and entities that make up our international network. We may share your information (as described above) with our affiliates as permitted by applicable law, such as to provide you with services that you have requested. Our affiliates are entities controlled or owned by us, or entities that control us or are under common control with us. As a result, your personal information may be transferred between locations in the US, the UK, the European Union and other relevant jurisdictions for the purposes described above.
We may also share your personal information outside the Firm with nonaffiliated service providers and financial institutions only if they agree to protect the confidentiality of your non-public personal information and to use the information only for purposes for which it is disclosed to them. This sharing may include:
Where we transfer your personal information as noted above, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information.
Please see below for more details of the protection given to your personal information when it is transferred outside the UK and the European Union.
How long we hold your personal information for will vary and will depend principally on:
In general, we will retain your personal information for as long as we require it to perform our contractual rights and obligations or for periods required by our legal and regulatory obligations. We seek to maintain appropriate physical, electronic and procedural safeguards designed to protect your personal information. Given the nature of information security, there is no guarantee that such security measures and safeguards will always be successful.
Depending on where you are located, you may have a number of legal rights in relation to the personal information that we hold about you under certain laws such as the GDPR. You can exercise your rights by contacting us using the details set out below.
These rights include:
If you wish to exercise any of the above rights as an EEA or UK data subject or to make a complaint to us, please contact us at the details set out below and include “GDPR Rights Request” as the subject of your communication.
Our activities and the jurisdictions in which we are established are such that it may be necessary for personal information that we obtain from you to be transferred and/or processed outside of the EEA or the UK, chiefly but not limited to the United States and the Cayman Islands. Personal information may be accessible by employees and other persons working on our behalf, located outside of the EEA or the UK, including by certain service providers (including but not limited to technical service providers and electronic data storage providers) who may process the information you give us. In circumstances where we transfer personal information outside the EEA or the UK, we will seek to ensure a similar degree of protection is afforded to it by ensuring that, where possible, personal information is generally transferred only to persons in countries outside the EEA or the UK in one of the following circumstances:
You can contact us through the information provided in the contact information section below for further information on specific mechanisms we utilize for transferring personal information outside the EEA or the UK and the countries to which such transfer may be made (which may include, but are not limited to, the United States and Cayman Islands).
Additional information for investors in our Cayman Islands funds
Additional information for California residents
The California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time, “CCPA”) imposes certain obligations on Crestline Management, L.P., or Crestline, and its affiliates (together, “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information, our Notice at Collection, and a description of your potential rights under the CCPA. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.
Terms used herein have the meaning ascribed to them in the CCPA. Crestline Management, L.P., or Crestline, and its affiliates (together, “we” or “us”) is a “business.” “Personal information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or a household.
Notice at Collection and Use of Personal Information
Personal Information We Collect and Personal Information We Have Disclosed for a Business Purpose
In the preceding 12 months, we may have collected the following categories of personal information from or about you. We may collect all or just a few of these categories with regard to a particular California Resident. Also, in the preceding 12 months, we may have disclosed for a business purpose personal information about you to our service providers or other entities that have agreed to limitations on use of your personal information. We may disclose all or just a few of these categories with regard to a particular California Resident:
Personal information under the CCPA does not include deidentified information, aggregate consumer information or publicly available information that is lawfully made available from government records.
Purposes for Collecting and Using Personal Information
In the preceding 12 months, we may have collected your personal information for the following business or commercial purposes. We may collect personal information for all or just a few of these purposes with regard to a particular California Resident.
How Long We Keep Your Personal Information
We retain your personal information as described in the “How Long We Keep Your Information and Security of your Information” paragraph in the “Data Protection Privacy Policy” above.
Sale or Sharing of Personal Information
We do not sell or share your personal information (as such terms are defined under the CCPA).
For more information about our privacy practices, please review our “Data Protection Privacy Policy” at the top of this document, and our entire “California Privacy Policy.”
Our Collection, Use and Disclosure of Personal Information and Sensitive Personal Information
Information We Have Collected and Our Purpose for Collecting It
In the preceding 12 months, and depending on how you interact with us, we may have collected the categories of personal information listed above in “Personal Information We Collect.” We may have collected all or a few of these categories of personal information for the business or commercial purposes identified in “Purposes for Collecting and Using Personal Information.”
Sources of Personal Information
In the preceding 12 months, we may have collected personal information about you from the following categories of sources. We may collect personal information from all or just a few of these categories of sources with regard to a particular California Resident.
Disclosure of Personal Information
We do not sell or share your personal information (as those terms are defined under the CCPA). We do not knowingly sell or share the personal information of California residents under 16 years old. In the preceding 12 months, we may have disclosed the categories of personal information identified in the “Personal Information We Collect” paragraph with the following categories of third parties. We may disclose personal information with none, all, or just a few of these third parties with regard to a particular California Resident:
In the preceding 12 months, we may disclose all or just a few of the categories of personal information identified in the paragraph labelled “Personal Information We Collect” to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us or our affiliates or opposing counsel and parties to litigation; (ii) any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets; and (iii) other third parties as may otherwise be permitted by law. We may also disclose for a business purpose such personal information upon reasonable request by the fund in which you have invested or at your request or direction or with your consent. In addition, we may disclose personal information to the third parties listed above to comply with our legal obligations or for the purposes identified above in “Purposes for Collecting and Using Personal Information” paragraph.
We may also disclose your personal information to our service providers, including our money laundering reporting officer, IT providers, archiving service providers, auditor, email providers, professional services organizations or other entities with which we have contracted to provide support and services and that have agreed to limitations on the use of your personal information for a business purpose or that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.
Use and Disclosure of Sensitive Personal Information
As noted above in “Personal Information We Collect”, under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.
California Residents’ Rights Under the CCPA
If your personal information is subject to the CCPA, you may have certain rights concerning your personal information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“request to delete”); (iv) opt-out of the “sale” (as the term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); (v) opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (vi) limit the use and disclosure of sensitive personal information where required by the CCPA (“right to limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit); (vii) correct inaccurate personal information (“request to correct”); and (viii) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“request to know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting or selling the personal information; (d) the categories of third parties to whom we disclosed personal information about your for a business purpose; and (e) the specific pieces of personal information we have collected about you;.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you where permitted by the CCPA or another law or regulation.
How to Submit a Request Under the CCPA
You may submit requests to know, request to correct, or request to delete (“Consumer Rights Requests”), as described above, through the following telephone number, 817-339-7600, or through our website at the following link www.crestlineinvestors.com. You may submit requests to delete through the following telephone number, 817-339-7600, or by emailing us at privacy@crestlineinc.com.
We are only required to respond to verifiable Consumer Rights Requests made by you or your legally authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name, email address, account login credentials or other account information, answers to security questions, name, government identification number, date of birth, contact information, or other personal information. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the provided methods. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
Changes to this Privacy Policy
We may update this privacy policy from time to time and to reflect changes in our personal information practices. We encourage you to review the most current privacy policy provided to you.
Contact for More Information
If you have any questions or concerns about this California privacy notice please email us at privacy@crestlineinc.com.
Click here for information on our Cookie Policy.
If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at:
Data Protection Liaison- privacy@crestlineinc.com