Privacy Policy
As a investor and/or prospective investor of Silverview and its funds, your privacy is important to us. Reflecting our commitment to protecting the privacy of your personal information, we have implemented privacy policies consistent with federal guidelines for financial institutions. We have also adopted policies and procedures designed to help ensure the security and confidentiality of your records and information. This notice is being provided to you in accordance with federal regulations regarding the privacy of consumer financial information. Please take the time to read and understand the privacy policies and procedures that we have implemented to safeguard your non-public, personal information.
Website
For purposes of this website privacy policy, the term “Website” shall include this website, any investor or other electronic reporting portals utilized by Silverview and any other electronic communications (e.g., emails)between Silverview and any other person.
Information We Collect
In order to help us provide the best level of service and meet our clients' financial needs, Silverview may collect certain personally identifiable financial information about you from the following sources:
§ Applications or other forms, including subscription agreements and related documents, that you may have completed for Silverview and predecessors (including information such as your name, address, social security number, and income);
§ Your transactions with us, our affiliates, or others (including information such as account balances and capital contributions); and
§ Websites that may ask for site visitor and other information.
Information We Disclose
Silverview does not disclose any non-public, personal information about our current or former clients or investors to anyone, except as permitted or required by law, or as necessary to provide services to you.
In the normal course of business (but not for marketing purposes), we may disclose certain information described above, to certain affiliated or non-affiliated third parties such as, but not limited to, our affiliated companies, attorneys, accountants, auditors, and other persons or entities that are providing services for the Fund (each a “Service Provider”, collectively, “Service Providers”) or assessing our compliance with industry standards. Silverview may disclose the information described above to nonaffiliated third parties as permitted by law, for example, to comply with a subpoena, respond to a regulatory authority or to protect against fraud. Silverview may also disclose such information in response to a specific authorization from you.
Federal law gives you the right to limit only: (i) sharing for affiliates’ everyday business purposes information about your creditworthiness,(ii) affiliates from using your information to market to you, and (iii) sharing for non-affiliates to market to you. State laws may give you additional rights to limit sharing.
Confidentiality and Security
To guard client and investor information, we maintain physical, cybersecurity, computer (IT), and procedural safeguards that comply with federal standards to guard your non-public, personal information. We permit access to non-public, personal information about you to solely those employees who need to know that information in order to perform their job responsibilities. Employees who have access to client or investor information must adhere to our strict security and confidentiality policies.
Silverview Credit Partners LP
Supplement to Privacy Policy
Supplement – Natural Persons Residents of the State of California
Purpose
The California Website Privacy Policy (“CA Supplement”)supplements the Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This CA Supplement is only relevant to you if you are a natural person resident of the State of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in this Privacy Policy. To the extent there is any conflict between this CA Supplement and the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (collectively, “GLB Rights”), GLB Rights shall apply.
Who does this CA supplement apply to?
This CA Supplement applies solely to your interactions with us through our Website. If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.
What information do we collect about you?
We collect limited types of personal information through our Website. The types of personal information we collect about you depends on the nature of your interaction with us. We do not knowingly collect or solicit personal information from anyone under the age of 18. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
§ Internet or other electronic network activity information, such as anonymized information regarding your use of our Website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.
How do we obtain your personal information?
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
§ Information from your communications with us in connection with this Website, including any update notices provided by you; and
§ Information captured on our Website, including registration information, information provided through online forms and anonymous information captured via cookies.
We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
How do we use your personal information?
We will use your personal information for one or more of the following business purposes:
§ To perform services for you;
§ To improve our Website and the products and services that we offer and notify you about changes to our products and services;
§ To communicate with you, including responding to requests for information submitted by you through our Website;
§ To keep a record of your relationship with us;
§ Ongoing operations, administrative, accounting, reporting, account maintenance and other processes;
§ To audit and verify the quality and effectiveness of our services and compliance;
§ To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity; and
§ To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.
Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the "opt-out" or "unsubscribe" link provided in all our marketing emails.
Who do we share your personal information with?
§ We do not sell any of the personal information we collect about you to third parties.
§ We do not disclose any non-public personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and Service Providers, including but not limited to administrators, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
§ Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and Service Providers.
§ We may also share your personal information with applicable third parties in the event of an organization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.
How do we keep your personal information secure?
We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Your rights under the CCPA:
§ Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
§ Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting such personal information;
- The categories of third parties with whom we share the personal information;
- The specific pieces of personal information we have collected about you; and
- Whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.
§ No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
§ How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.
Contact information
For any request or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request to our contact information.
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), if applicable, we may request your investor portal access credentials in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.
Silverview Credit Partners LP
Supplement to Privacy Policy
Supplement - For Persons in Cayman Islands Partnership
Purpose
The Data Protection Law, 2017 (the “DPL”) supplements the Privacy Policy with respect to the purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Law, 2017. In this document, "we", "us" and "our" refers to the Partnership, the General Partner and its or their affiliates and/or delegates.
Who does this supplement apply to?
By virtue of making an investment in the Partnership and your associated interactions with us (including any subscription (whether past, present or 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.
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.
In our use of Investor Data, the Partnership will be characterized as a "data controller" for the purposes of the DPL. The Partnership's affiliates and delegates may act as "data processors" for the purposes of the DPL.
How we may use your personal data
The Partnership, as the data controller, may collect, store and use Investor Data for lawful purposes, including, in particular:
§ where this is necessary for the performance of our rights and obligations under the Subscription Agreement and/or the constitutional and operational documents of the Partnership;
§ where this is necessary for compliance with a legal and regulatory obligation to which the Partnership is subject (such as compliance with anti-money laundering and FATCA/CRS requirements); and/or
§ where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.
Additionally, the fund administrator, may use Investor Data, for example to provide its services to the Partnership or to discharge the legal or regulatory requirements that apply directly to it or in respect of which the Partnership relies upon the fund administrator, but such use of Investor Data by the fund administrator will always be compatible with at least one of the aforementioned purposes for which we process Investor Data.
Further explanation regarding how each of the Service Providers may handle Investor Data is set out in each its respective privacy notice, which is available upon request. 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 Partnership 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 the following parties who provide services to the Partnership and their respective affiliates (which may include certain entities located outside the Cayman Islands or the European Economic Area), who will process your personal data on our behalf:
§ Service Providers
- U.S. Bank Global Fund Services(Cayman) Limited, as the fund administrator;
- AlterDomus (US) LLC, as the fund administrator;
- EisnerAmper LLP, as the fund auditor
- BDO USA, LLP, as the tax compliance service;
- Maples Compliance Services(Cayman) Limited, as the Cayman AML Compliance Officer.
- Seward and Kissel LLP, Kirkland and Ellis LLP and Proskaur Rose LLP, as legal counsel for certain Silverviewfunds
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.
Contact information
For any request or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request to our contact information.
Silverview Credit Partners LP
Supplement to Privacy Policy
Supplement - For Persons in the EEA, Switzerland and the UK
Purpose
The following supplements the Privacy Policy with respect to persons residing in the EEA, Switzerland and the UK. As a investor and/or prospective investor of Silverview and its funds and located in the European Economic Area(EEA), Switzerland or the UK, we would like to inform you about our processing of your personal data by way of this privacy notice in accordance with Europe and data protection laws.
Information we collect
“Personal data” is information about you (a “data subject”), the use of which is governed by applicable data protection laws. It will include any information from which you can be identified, directly or indirectly.
In order to help us provide the best level of service and meet our clients' needs, Silverview may collect personal data about you from the following sources:
§ Applications or other forms, including subscription agreements and related documents, you may have completed for Silverview and predecessors (including information such as your name, address, social security number);
§ Your transactions with us, our affiliates, or others (including information such as account balances and capital contributions);
§ Your communications with us (including information such as your requests, complaints and feedback, as well as information about your family members and third parties which you hereby declare you are authorized to share with us);
§ Web sites and investor portals (including information such as your online activity, IP address, and device data); and
§ Third party sources (including information such as tax information and background checks).
How do we use your information?
We use your personal data in accordance with the law in order to administer our platforms, provide our services, deal with your inquiries and complaints, detect and prevent crime, send you service notifications and inform you about our services, provide technical support, manage invoicing, financial matters and customer due diligence, carry out trend analysis and business development and comply with the law.
We will process your personal data as is necessary to perform your contract with us. We may also rely on our legitimate interest to process your personal data, for example to ensure the efficiency, reliability and security of our services and platforms, to develop our business taking into account your interaction with our services and customer feedback, and to ensure the proper and efficient administration of our business. We will seek your consent where required by law. Finally, we will process your personal data where we are required to do this by law, or as otherwise permitted by law.
When do we disclose your information?
Silverview may share your personal data in accordance with the law with our technology providers and other third-party providers who help us provide our services to you. This may also include various providers, lawyers, auditors and other consultants who help us operate our business efficiently and in compliance with the law and industry standards. If we decide to sell or restructure our business, we may disclose your personal data to our advisers and any prospective owners of the business and their advisers.
Silverview may disclose your personal data to comply with a court order, respond to a regulatory authority or to comply with the law. Silverview may also disclose your information as permitted by law, to protect against fraud, or in response to a specific authorization from you.
We may share your personal data for marketing purposes with our group companies subject to your consent or as otherwise permitted by law.
International data transfers
Most of our services are provided under your contract with our US subsidiaries. In those cases, you will provide your information directly to them. There may be limited cases where you provide information to our Service Providers and their subsidiaries located in the EEA. In those cases, we may transfer your personal data to our group companies, suppliers and advisers located outside your country including the US. We will ensure adequate protection of personal data as required under applicable laws. For example, we may enter into model clauses approved by the European Commission with the recipient, and you may contact us for a copy of these safeguards.
How long do we keep your personal data?
Silverview will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and Silverview’s legitimate interests in maintaining such personal data in its records. This will normally include any period during which Silverview is dealing or expects to deal with you and what Silverview considers to be a suitable period thereafter for internal record-keeping purposes. In doing this Silverview will have regard to the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which Silverview processes your personal data and whether those purposes can be achieved through other means, and the applicable legal requirements. Generally, Silverview will keep information relevant to its dealings with you for 10 years following full redemption.
In some circumstances your personal data may be anonymized so that it can no longer be associated with you, in which case it is no longer personal data. Once Silverview no longer requires your personal data for the purposes for which it was collected, it will securely destroy your personal data in accordance with applicable laws and regulations.
Confidentiality and security
We implement appropriate technical and organizational measures to safeguard your personal data. We restrict access to your personal data to those employees who need to know that information in order to perform their job responsibilities. Employees who have access to client or investor information must adhere to our strict security and confidentiality policies.
Your rights
Data subjects may ask us for a copy of their information, to correct it, erase it or to transfer it to other organizations, where applicable, at their request. Data subjects also have the right to object to some processing including profiling or direct marketing. Where we have asked for their consent to process data, for example, for direct marketing purposes, they may withdraw their consent at any time. Where a data subject withdraws their consent, this will not affect the legitimacy of the processing conducted prior to your request. Where we process data because we have a legitimate interest in doing so (as explained above), the data subject has a right to object to this. Where we make a decision based solely on automated processing which significantly affects the data subject, he or she may have the right to contest the decision, express his or her point of view and obtain human intervention. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data.
For any requests or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
§ By Phone: 646-205-6225
§ By Email: ir@silverviewcredit.com
Our goal is to respond to any verifiable consumer request within thirty (30) days of our receipt of such request, unless otherwise required bylaw. We will inform you in writing if we cannot meet that timeline. Please contact us using the contact information above with any questions about this Privacy Notice.
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