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Thank you for visiting the website of SkyBridge Capital II, LLC and its affiliates (together, “SkyBridge”, “we” or “us”). Your visit to this website (the “Site”) is subject to the following Privacy Policy. By visiting the Site, you agree to this Privacy Policy, which may be updated by us at any time. If we update our Privacy Policy, we will post the updated document here. Any such changes will be effective upon posting. We urge you to review the Privacy Policy each time you visit the Site. If you do not agree with any provision of the Privacy Policy, you should not use the Site.
This Privacy Policy concerns only the Site and does not concern any website to which the Site may link. Should you choose to visit these third-party sites, you should review their privacy policies to ensure that you understand and are comfortable with their practices concerning your personal information. Similarly, this Privacy Policy does not concern your interaction with SkyBridge in any manner other than your use of the Site. Finally, this Privacy Policy does not address our privacy practices with respect to any nonpublic personal information we may collect from you as an investor in investment vehicles that we sponsor or manage. We address these practices in separate notices to investors or potential investors.
We are committed to protecting the privacy of visitors to the Site. This Privacy Policy seeks to help you understand whether and how we collect information about you when you visit the Site, and how we use such information.
If you have any questions about this Privacy Policy, please contact Marie Noble, General Counsel and Chief Compliance Officer, at 527 Madison Avenue, 4th Floor, New York, NY 10022; telephone number (212) 485-3129; or mnoble@skybridge.com.
1. THE TYPES OF INFORMATION WE COLLECT ABOUT YOU
When you enter and browse the Site, we may collect two different types of information about you: information you provide to us and information we collect through technology. SkyBridge may retain any information collected through the Site for an indefinite period of time.
Information You Provide to Us
In order to obtain access to certain information or materials provided via the Site, you may have to provide information that we collect and store in a way that allows us to relate it to you personally, including but not limited to your name and contact information, including your e-mail address, mailing address and phone number. We refer to such information as personal information. Additionally, we may collect and retain a record of all communications with you.
Information We Collect Through Technology
We may collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to the Site (an IP address is often associated with the portal through which you enter the Internet). At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site.
The Site may also use other technical methods to track and analyze the traffic patterns on the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect and process information on our behalf. We may also use these technical methods in e-mails that we send our Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that is personally identifiable.
During some visits to our Site, we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.
Cookies and How We Use Them
We use cookies, web beacons and similar technologies (collectively, "Cookies") to track information provided to us by your browser and by our software applications when you use the Site. A cookie is a small piece of information that a website stores on the web browser on your device and can later retrieve. "Session" Cookies are temporary and will expire at the end of a browser session; that is, when you leave a website. Session Cookies allow a website to recognize you and carry information as you navigate between pages during a single browser session and allow you to use the website most efficiently. "Persistent” Cookies, in contrast, remain in the Cookie file of your browser even after you leave a website and after the browser is closed. They enable a website to recognize you upon your return, remember your preferences and provide tailored services to you. A cookie will not contain information that will enable us to contact you via telephone, e-mail, or other means.
We, and third party service providers acting on our behalf, use session and persistent Cookies to:
Remember preferences that you submit as well as those generated from your usage data and your responses to polls and surveys on our Site;
Measure your use of our Site in an effort to improve its quality and enhance your overall experience, including tracking page views, time and date of Site access, and other usage data, and identifying your operating system and browser type (but not other information about your computer or the programs on it) and your general geographic location;
Measure the effectiveness of our newsletters and advertising campaigns; and
Allow you to share certain information on our Site via social media bookmarking buttons, email or on social networking sites.
Most browsers are initially set to accept Cookies. However, you have the ability to change your browser settings. It may also be possible to configure your browser settings to enable acceptance of specific Cookies or to notify you each time a new Cookie is about to be stored on your device enabling you to decide whether to accept or reject the Cookie. You can also disable Cookies by configuring your browser setting to reject Cookies. Please refer to the help section of your browser for instructions on disabling Cookies. For more information about Cookies, how they work, why they are so useful and how to disable them, you can visit www.allaboutcookies.org.
If you do not wish to accept Cookies from this Site, please either disable them or refrain from using this Site. If Cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using all or part of this Site. If you continue to use the Site with a browser set to accepting cookies, we will assume that you accept receipt of all cookies coming from the Site.
Google Analytics
We may use Google Analytics to collect information about your use of the Site. Google Analytics collects information such as how often users visit the Site, what pages users visit, and what other sites they visited prior to or after coming to the Site. More information on how Google Analytics uses your data can be found at www.google.com/policies/privacy/partners/. We would use the information we get from Google Analytics only to improve the Site. By using the Site with your browser set to accepting cookies, you consent to Google Analytics’ use of cookies on the Site.
2. OUR DISCLOSURE AND USE OF YOUR PERSONAL INFORMATION
SkyBridge does not disclose any nonpublic personal information about its Site users to any nonaffiliated third party, except as set forth below.
We may use or disclose certain personal information we collect about you when you visit and browse the Site as part of our normal business operations, including to send you administrative communications either about your interactions with us or about features of the Site.
We may share your personal information with our affiliates. We may associate your personal information with other information we collect about you, such as details about your usage patterns and interests, but we will not sell this information or disclose it to third parties, other than as set forth below.
We may use service providers in connection with the Site. These companies and individuals may have access to and use your personal information, as needed to perform their functions.
We may use aggregated usage data to track trends and analyze patterns on the Site. You may also voluntarily submit information, including by responding to our online polls and surveys, requesting information from us or asking to be contacted by one of our representatives. If you work for one of our institutional (business) clients, we may obtain your business contact information from your firm. If you register to enter an area of this Site, the Site will recognize who you are and collect all information that you submit (including subscription to emails, etc.). Any information collected about you from this Site may be associated with other identifying information that we have about you. In addition to the above uses, we may use your information for the purpose of conducting business with you, managing our relationship with you, and advising you of products and services that we believe might be of interest. The information collected also is used to provide a record of communications between Skybridge and its Site visitors and users and to comply with any applicable legal and/or regulatory requirements.
We will disclose personal information when we believe that such disclosures are required by law, regulation, legal process, subpoena, document or governmental request. We may also do so to protect your safety or security, or protect the safety and security of tangible or intangible property that belongs to us, to you or to third parties.
In the event that SkyBridge (or any portion of our assets or businesses) is acquired by or merged with another entity, whether to an affiliate or a third party, user information may be one of the transferred assets. We may transfer all user information (which may include personal information) to our acquirers or successors. Other than as part of such transaction, we will not sell any of your personal information without your consent.
3. HOW WE USE YOUR NON-PERSONAL INFORMATION
Non-personal information is information that does not personally identify you, including anonymous information and aggregate data. We may use this information to understand better how our visitors use the Site, research our visitors’ demographics, interests, and behavior, improve the Site, provide visitors with customized services and information, and for other similar purposes. We may combine this information with personal information. We may share this information with others and use this information in any manner permitted by law, but any disclosure that identifies you personally will be governed by Section 2.
4. PROTECTION OF INFORMATION
We endeavor to protect your personal information. We use technical, administrative and physical methods and procedural safeguards to maintain the integrity and security of our databases and systems. Please be aware though that there is no such thing as “perfect security”, and third parties may unlawfully intercept or access transmissions or private communications. We will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personal information. You use our Site and send us information at your own risk.
5. DO NOT TRACK
We do not track visitors of the Site over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.
6. INFORMATION REQUESTS
You have the right to request that we disclose to you or delete certain information about our collection and use of your personal information. Once we receive your request and verify your identity, we will disclose such information to you or delete the same, unless a legal exception applies. For example, we may deny your deletion request if retaining the information is necessary for us or our providers to complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. Your request must:
Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person.
Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with non-public personal information if we cannot verify your identity or authority to make the request and confirm that the requested personal information relates to you. We will use the information provided in a request solely to verify your identity or authority to make the request.
7. CALIFORNIA’S SHINE THE LIGHT LAW
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our Site users who are California residents to request and obtain from us a list of their personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not share any personal information with third parties for their direct marketing purposes.
8. GOVERNING LAW AND FORUM
The laws of the State of New York govern this Privacy Policy. Any dispute relating to this Privacy Policy or your use of the Site or the Content shall be resolved solely in the state or federal courts located in New York City. You agree to waive trial by jury in any such action.
Last Updated April 2022
