Website Privacy Policy


 

Introduction

Cercano Management LLC ( “We” or “us”) are sensitive to the privacy concerns of our individual clients and investors. We respect your privacy and are committed to protecting it through our compliance with this Website Privacy Policy (“Policy”). 

This Policy describes the types of information we may collect from you or that you may provide when you visit the website CercanoLP.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

 

By using this Website, you agree to the terms and conditions of this Policy. This Policy applies to information we collect:

  • On this Website.

  • In email, text, and other electronic messages between you and this Website.
     

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

We also work with third party providers who are contractually obligated to comply with our Policies to protect information. However, if you visit or access one of these third party provider sites or mobile apps, please review the online privacy practices of that site or mobile app to understand the specifics of how your online personal information may be collected, used and shared.

Additional Privacy Policies and Notices for Advisory Clients and Investors

We are a registered investment adviser with the United States Securities and Exchange Commission (the “SEC”) and are required to comply with SEC Regulation S-P (“Reg. S-P”), as well as the United States Gramm-Leach-Bliley Act of 1999 (the “GLB Act”). Reg. S-P and the GLB Act require us to have policies and procedures in place to protect the security and confidentiality of the nonpublic personal information of consumers and customers, and to provide a privacy notice to such persons describing our privacy policies and procedures. A full copy of our privacy policy for investors (“Investor Privacy Policy”) can be found here. We will not disclose any nonpublic personal Information about you, except as permitted by law.

The GLB Act excludes publicly available information (including publicly listed address, telephone numbers, or email addresses), and such publicly available information may be collected in the course of your use of this Website, as further explained below in the section titled: Information We Collect About You and How We Collect It. Nonpublic personal information includes, but is not limited to, nonpublic personally identifiable financial information plus any list, description or grouping of our clients (each, an “Advisory Client” and collectively, “Advisory Clients”) and investors in private funds managed by us or our affiliates (each, an “Investor” and collectively, “Investors”) that is derived from nonpublic personally identifiable financial information. Nonpublic personal information may also include, without limitation, personal financial and account information, such as: names, addresses, contact details, or information that identifies a person as an Advisory Client or Investor; social security numbers or tax identification numbers; assets, net worth, income, or other information provided on a financial product application; bank account information; consumer report information; occupation; information acquired through an Internet “cookie” (as explained in the section titled: Information We Collect Through Automatic Data Collection Technologies); or other information regarding Advisory Clients or Investors not available to the public. Nonpublic personal information also may include advice provided by us to Advisory Clients, and data or analyses derived from Nonpublic personal information.

 

In addition to the Investor Privacy Policy, "Privacy Notice” incudes a description of the types of nonpublic personal information we collect, a description of the manner in which we collect such information, an explanation of the conditions under which we may disclose nonpublic personal information to third parties, and the policies and procedures for the protection and security of confidential information. The Privacy Notice is provided to new individual customers and on an annual basis thereafter.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at: legalnotices@cercanolp.com
 

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);

  • That is about you but individually does not identify you; and/or

  • About your internet connection, the equipment you use to access our Website, and usage details.

 

We collect this information:

  • Directly from you when you provide it to us.

  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies. Information You Provide to Us.  

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further services. We may also ask you for information when you report a problem with our Website.

  • Records and copies of your correspondence (including email addresses), if you contact us.

 

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

 

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data and other communication data and the resources that you access and use on the Website.

  • Information about your computer and internet connection, including your IP address, operating system, and browser type.
     

The information we collect automatically is only statistical data and does not include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.

  • Store information about your preferences, allowing us to customize our Website according to your individual interests.

  • Speed up your searches.

  • Recognize you when you return to our Website.
     

The technologies we use for this automatic data collection may include:
 

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.

  • To provide you with information, products, or services that you request from us.

  • To fulfill any other purpose for which you provide it.

  • To provide you with notices about your account, including expiration and renewal notices.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • To notify you about changes to our Website or any products or services we offer or provide though it.

  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

We may also use your information to contact you about goods and services that we provide that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form). For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Policy:

  • To our subsidiaries and affiliates.

  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cercano Management LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cercano Management LLC about our Website users is among the assets transferred.

  • To fulfill the purpose for which you provide it.

  • For any other purpose disclosed by us when you provide the information.

  • With your consent.
     

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • To enforce or apply our Investor Agreement and other agreements, including for billing and collection purposes.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cercano Management LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Our electronic systems are protected by security software, which software may include firewalls, anti-virus, anti-spam, malware and trojan protection, as well as reasonably up-to-date software patches and security ‘definition’ updates. Although we seek to establish and maintain a security system that covers the use of the internet, its servers, its computers and other IT equipment (such as desktop computers, laptops, tablets and smartphones), please be aware that no security measures are perfect or impenetrable. The safety and security of your information also depends on you. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Policy on this page with a notice that the Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at:

legalnotices@cercanolp.com

Last modified: September 23, 2022