By virtue of making an investment in the Fund and your associated interactions with us (including any subscription (whether past, present of future), including the recording of electronic communications or phone calls where applicable) or by virtue of you otherwise providing us with personal information on individuals connected with you as an investor (for example directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents), you will provide us with certain personal information which constitutes personal data within the meaning of the DPL (“Investor Data”). We may also obtain Investor Data from other public sources. Investor Data includes, without limitation, the following information relating to you and/or any individuals connected with you as an investor: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your investment activity.
In our use of Investor Data, the Fund will be characterized as a “data controller” for the purposes of the DPL. The Fund's and our affiliates and delegates may act as “data processors” for the purposes of the DPL.
Who This Affects
If you are a natural person, this will affect you directly. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with Investor Data on individuals connected to you for any reason in relation to your investment with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.
How We May Use Your Personal Data
As the data controller we may collect, store and use Investor Data for lawful purposes, including, in particular where necessary for:
- The performance of our rights and obligations under the Fund's subscription agreement and/or the constitutional and operational documents of the Fund.
- Compliance with a legal and regulatory obligation to which we are subject (such as compliance with anti-money laundering and FATCA/CRS requirements).
- The purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.
As a data processor, the Fund's administrator (the “Administrator”), may use Investor Data, for example to provide its services to the Fund or to discharge the legal or regulatory requirements that apply directly to it or in respect of which the Fund relies upon the Administrator, but such use of Investor Data by the Administrator will always be compatible with at least one of the aforementioned purposes for which we process Investor Data.
Should we wish to use Investor Data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.
Why We May Transfer Your Personal Data
In certain circumstances we and/or our authorized affiliates or delegates may be legally obliged to share Investor Data and other information with respect to your interest in the Fund with the relevant regulatory authorities such as the Cayman Islands Monetary Authority or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities.
We anticipate disclosing Investor Data to certain service providers of the Fund (such as the Fund's Administrator for example) and their respective affiliates (which may include certain entities located outside the Cayman Islands), who will process your personal data on our behalf, as a data processor, in compliance with the terms of the DPL, on the basis that:
- Where relevant, you have given your express consent to processing for so long as you have not withdrawn such consent by written notice to us.
- Processing is necessary for the performance of your subscription and investment in the Fund.
- Processing may be necessary for compliance with legal obligations to which we or such data processor may be subject.
- Processing is undertaken in the course of pursuing our and or such data processors legitimate interests as outlined above in this notice.
The Data Protection Measures We Take
Any transfer of Investor Data by us or our duly authorized affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL.
We and our duly authorized affiliates and/or delegates shall apply appropriate technical and organizational information security measures designed to protect against unauthorized or unlawful processing of Investor Data, and against accidental loss or destruction of, or damage to, Investor Data.
We shall notify you of any Investor Data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant Investor Data relates.
Getting In Touch
Should you have any queries or wish to discuss your data protection rights with us, please contact:
CIFC Asset Management LLC
1 SE 3rd Avenue, Suite 1660
Miami, Florida 33131
LBC Credit Management, L.P.
555 East Lancaster Avenue, Suite 450
Radnor, PA 19087
An expert perspective on the credit markets.
1 SE 3rd Avenue, Suite 1660, Miami, FL 33131
+1 786 652 3250
875 3rd Avenue, 24th Floor, New York, NY 10022
+1 212 624 1200
27 Knightsbridge, 6th Floor, London, SW1X 7LY
+44 203 841 6200
555 East Lancaster Avenue, Suite 450, Radnor, PA 19087
+1 215 972 8900