Your privacy is important to us. This Privacy Policy (“Policy”) explains the manner in which Octagon Capital Advisors LP, a Delaware limited partnership (“we,” “our”, “us” or “Octagon”) collects, uses, maintains, and shares information about visitors to our website located at www.octagoninvestments.com (the “Site”). This Privacy Policy covers only data collected through the Site and not any other data collection or processing, including, without limitation, data collection practices of other websites that are not controlled and/or maintained by Octagon to which we link or data that we or our affiliates collect offline. If you are an investor, consultant or otherwise affiliated with us, please refer to the introductory information provided to you by us or contact us as outlined below for additional assistance.
By using or otherwise accessing the Site, you agree to the terms, conditions, policies and restrictions governing the use of the Site, which thus constitute a legal agreement between you and Octagon. We may change, suspend or discontinue any aspect of the Site at any time, including the availability of any feature, database or content therein. IF YOU DO NOT AGREE TO ABIDE BY THIS PRIVACY POLICY, DO NOT USE THE SITE. YOUR CONTINUED USE OF THE SITE FOLLOWING THE POSTING OF ANY CHANGES TO THIS POLICY CONSTITUTES ACCEPTANCE OF SUCH CHANGES.
When you visit our Site, we may collect the following categories of information about you: Internet or Other Similar Network Activity. Specific Personal Information we collect may include: your domain server, type of computer or mobile device, web browser and statistical information regarding the pages that you visit, as well as the items viewed on the Site. If you elect to submit an online request form to us, we collect your name, email address and company. The source of this information is your direct interaction with our website. We may also collect similar personal information from you in connection with business transactions or other interactions in the ordinary course of business (aside from your interaction with our Site). We may also receive your personal information from third parties.
Octagon may use the personal information we collect about you for the following purposes:
Octagon may share your personal information in a limited number of circumstances, including: (i) to third parties with whom Octagon works to enhance the Site and investment management services that Octagon provides; (ii) to respond to a subpoena or court order, judicial process or regulatory inquiry; (iii) to protect or defend against fraud, lawsuits, claims or other liabilities; (iv) to protect the security of our systems, or to protect our rights or property; (v) in connection with a proposed or actual sale, merger, or transfer of all or a portion of Octagon’s business; (vi) to otherwise assist Octagon in offering investment management services, and (vii) for distribution of any information that Octagon believes may be useful to you.
Based upon where you reside, certain choices and rights with regards to your personal information may be available to you. Please see below for information on how to contact us to exercise these rights.
Under the California Consumer Privacy Act of 2018, as amended (“CCPA”), residents of the State of California are provided with specific rights regarding the collection and storage of their personal information.
Residents of the State of California have the right to request that we provide to you the following information about our collection and use of your personal information over the past 12 months. Once your verifiable consumer request has been confirmed, we will disclose to you:
Residents of the State of California have the right to request that we delete any of the personal information collected from you and retained, subject to certain exceptions. Once your verifiable consumer request is confirmed, we will delete and direct our service providers to delete your personal information from our records. Your request to delete the personal information collected may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA.
Octagon takes the security of personal information provided to us very seriously, and we have implemented commercially reasonable steps to maintain physical, electronic, and procedural safeguards in order to protect your personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Octagon also requires third party companies that we hire and to whom we disclose data to keep such information confidential and to use it only to provide the services we have contracted with them to perform.
Octagon may, itself or through a third party vendor, collect technical and usage data passively provided through the use of “cookies”, which are small pieces of data sent to your computer browser from our web server and stored on your computer's hard drive, or voluntarily provided by you while visiting the Site. User-provided data may include contact information, information related to the business you represent or information related to the financial information services you have requested. We may, but have no obligation to, monitor and record activity on the Site for any reason or for no reason. We may investigate any complaint or reported violation of the Terms. We may report any activity that we suspect may violate any law or regulation to regulators, law enforcement officials or other persons or entities that we deem appropriate or take any other action that we deem appropriate.
Your personal information may be transferred across nation borders and may be accessed by Octagon vendors and suppliers from countries with varying degrees of protection for your personal information. By agreeing to this Policy, you expressly consent to the processing of your data in any jurisdiction, including, without limitation, the United States of America, in accordance with this Policy and applicable privacy and data protection laws and regulations, including Standard Contractual Clauses approved by the European Commission; EU-US Privacy Shield; Binding Corporate Rules; and Binding Corporate Processor Rules.
Octagon reserves the right to change this Policy at any time and without notice. If Octagon does change this Policy, Octagon will update the “Last Updated” date at the bottom of this Policy and will post any such modified Policy on the Site. Any change will be effective immediately upon posting on the Site. You should review this Policy each time you access the Site to see the most recent version.
If you have any questions or comments about this Policy or you would like to exercise any of your rights as outlined here, please contact us at (212) 369-2829 and ask to speak with the Chief Compliance Officer or send email to info@octagoninvest.com. Before helping you with your inquiry, we may ask to verify your identity in accordance with applicable law.
You may also write to us at: Attn: Chief Compliance Officer Octagon Capital Partners LP 654 Madison Avenue, 16th Floor New York, New York 10065
Last Updated: October 2020