Your privacy is very important to us. This Privacy Notice is provided by Monarch Alternative Capital LP and Monarch Alternative Capital (Europe) Ltd, which, directly or indirectly, act as investment adviser to the fund(s) or other vehicles in which you invest (the “Fund”) and are data controllers for purposes of the Data Protection Act 1998 (the “DPA”). This Privacy Notice sets forth the policies of the Fund with respect to the collection, sharing and protection of non-public personal information of the Fund’s investors, prospective investors and former investors and other individuals whose personal information we process. In the United States, these policies apply to individuals and Individual Retirement Accounts only. In the United Kingdom and elsewhere in the European Union, these policies apply to all individuals whose personal data, as defined in the DPA, we process. These policies may be changed at any time and will apply in the form in which they appear on this page from time to time. Please read this Privacy Notice carefully to understand what the Fund does as regards your personal information. By visiting www.monarchlp.com or otherwise being provided with this Privacy Notice you are accepting and consenting to the practices described in this Privacy Notice.
You may provide us with personal information, such as your address, social security number, assets and/or income information: (i) in Subscription Agreements and related documents; (ii) in correspondence and conversations with the Fund’s representatives; (iii) through our website (including certain technical information); and (iv) through transactions in the Fund.
We do not disclose any of this personal information to anyone other than to: (i) members of our group, which includes our subsidiaries and affiliates, (ii) our group’s attorneys, auditors, counterparties, brokers, other financial institutions or service providers, in each case only as necessary to facilitate the acceptance and management of your investment, (iii) regulators or other government agents purporting to have jurisdiction over the group, including in connection with any government or self-regulatory organization request or investigation, and (iv) as may otherwise be permitted by law. Anti-money laundering and similar laws may require us, for example, to disclose information about the Fund’s investors. We will also release information about you if you direct us to do so or if we are compelled to do so by law. In the event we seek to buy or sell any business or assets, we may release information about you to the prospective buyer or seller and if we or substantially all of our assets are acquired by a third party your personal data will be one of the transferred assets.
We will carefully safeguard your private information and, to that end, we restrict access to personal information about you to those employees and other persons who need to know the information to enable the Fund to provide services to you. We maintain appropriate physical, electronic and procedural safeguards to protect your personal information.
All information you provide to us is stored on our secure servers and third-party back-up servers. Any payment transactions will be effectuated using appropriate technology. If we have given you (or you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will take reasonable precautions to protect your personal information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security measures to try to prevent unauthorized access to it.
Please note that information that we obtain from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”) which will be accessible by employees and other persons working on our behalf, located outside of the EEA, including certain service providers who may process the information you give us.
If your information is processed in the European Union, you have the right to request a copy of the personal information that we process about you, for which we may charge you a fee of up to £10 pursuant to the DPA to meet our costs in providing you with details of the information we hold about you. Any such requests and all comments or questions regarding this Privacy Notice should be addressed to Ronen.Voloshin@monarchlp.com.