Information We Collect
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.
Use and Disclosure of Information
Octagon may use the personal information we collect about you for the following purposes:
To better understand general usage of the Site and to improve the Site and/or our investment management services.
To respond to your requests, such as to send you information.
For internal business purposes, such as auditing, data analytics and research to create, develop, operate, deliver and improve our Site, investment management services, and investor communications.
At Octagon’s initiative and without your request, to provide you with information and/or materials regarding Octagon and its affiliates for informational 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.
Your Choices & Rights
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:
The categories of personal information we have collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share or have shared that personal information.
The specific pieces of personal information we have collected about you (also called a data portability request).
If we have not disclosed your personal information for a business purpose, we will disclose this fact. If we have disclosed your personal information for a business purpose, including direct marketing, we will provide you with a list of disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. Under the CCPA, you have the right to know whether your personal information is being sold. Octagon does not sell your personal information.
CCPA Deletion Request Rights
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.
Changes to this Policy
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.
Questions about this Policy & How to Exercise Your Rights
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 firstname.lastname@example.org. 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