Privacy Policy

LAST UPDATED: JULY 31, 2018
 

INTRODUCTION

This privacy (“Policy”) describes how Anzu Partners, LLC, and any associated entity managed by Anzu Partners LLC, including Anzu Industrial Capital Partners LP, AICP I Limited, and various special purpose investment vehicles organized by Anzu Partners LLC (collectively “Anzu”, the “Company,” “we,” and “our”) collects, uses and shares personal data (the “Services”). Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it.

PARTICULARLY IMPORTANT INFORMATION

WHO WE ARE: For the purpose of applicable data protection legislation, the data controller of your personal data is Anzu of 1399 New York Ave NW, Suite 601 Washington, DC 20005.

MUST READ SECTIONS: We draw your attention in particular to the sections entitled “International Data Transfer” and “Your Rights.”

CHANGES TO THIS POLICY: We will post any modifications or changes to the Policy on anzupartners.com. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will post a notice on our site prior to such changes(s) taking effect.

1. PURPOSES OF PROCESSING

What is personal data?

We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation 2018 (the “GDPR”) and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.

Why do we need your personal data?

We will only use your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with business communications and company updates. You have been asked to agree to provide this information in order for us to continue communicating with you. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time.

2. COLLECTING YOUR PERSONAL DATA

We collect information about you in the following ways:

Information You Give Us. This includes:

  • the personal data you provide when you correspond with us by phone, email or otherwise.
  • the personal data you provide in the tax and legal documents you may have submitted to us, including your name, email, phone number, physical address, and in some cases your tax identification number, your citizenship, and your status as an accredited investor.
  • We will not collect sensitive personal data, which the GDPR defines as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, or genetic data or biometric data. We ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).
 

3. USING YOUR PERSONAL DATA

We may use your personal data as follows:

  • to maintain lines of communication strictly for investment and general communications purposes;
  • to respond to your questions and to provide assistance when requested;
  • to comply with tax or financial audits;
  • to send information including technical notices, updates, security alerts, and support and administrative messages;
  • as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
  • as described in the “Sharing of your Personal Data” section below.

4. SHARING YOUR PERSONAL DATA

We may share your personal data as follows:

  • Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
  • Our Third-Party Service Providers. We may share your personal data with our third-party service providers who provide services such as cap table management, relationship management, document management, business advising, law advising, payment processing, email delivery, financial auditing, and other similar services. We will not provide the exact names of the services in order to protect against hacking and phishing attempts. However, you are welcome to reach out and ask for the specific third parties we utilize. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They have all provided documentation that states that they are also compliant with the GDPR and will comply with appropriate security measures to protect your personal data.
  • Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
 

5. INTERNATIONAL DATA TRANSFER

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

6. SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 10 below.

7. RETENTION

We will retain your personal data for the life of the business due to regulatory requirements. You may at any time request that we delete your data. Please note that the deletion of your data may disrupt our communications with you depending on the data you request to be deleted.

8. YOUR RIGHTS

  • Opt-out. You may contact us any time to opt-out of: (i) direct communications; (ii) our collection of personal data; (iii) any new processing of your personal data that we may carry out beyond the original purpose; or (iv) the transfer of your personal data outside the European Economic Area (EEA).
  • Access. You may access the information we hold about you at any time by contacting us directly.
  • Amend. You can also contact us to update or correct any inaccuracies in your personal data.
  • Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
  • Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us using the details in Section 10 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

9. COMPLAINTS

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: privacy@anzupartners.com. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.

10. CONTACT INFORMATION

We welcome your comments or questions about this Policy. You may contact us in writing at privacy@anzupartners.com or 1399 New York Ave NW, Suite 601, Washington DC 20005.