Privacy Policy

This Website Privacy Policy applies solely to your interactions with Court Square Capital Management, L.P. (“our”, “us”, “we”, or “Court Square”) through our Website (as defined below). 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.

We collect limited types of personal information through our website and investor reporting portal, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us.

Unfortunately, the transmission of information and data via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our Websites; any transmission of information or data by you to or through our Websites is at your sole risk.

We do not collect any personally identifiable information through the publicly available areas of www.courtsquare.com, such as IP address, domain name, webpage, or the length of time spent on the website. The information-gathering technology referred to as “cookies” will not be used in connection with the publicly available areas of www.courtsquare.com. The only information that Court Square Capital collects is that which is voluntarily submitted by users. By using www.courtsquare.com, you hereby understand and consent to the transfer of any data submitted by you to Court Square Capital. Under no circumstances will Court Square exchange such information gathered on the publicly available areas of www.courtsquare.com with third parties.

If you are a California resident, please see the California Website Privacy Notice Supplement set forth below for additional information.

CALIFORNIA WEBSITE PRIVACY POLICY SUPPLEMENT

Last Date Updated: February 18, 2020

This California Website Privacy Policy supplements the Website 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 supplement is only relevant to you if you are a resident 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 the Website Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this Website Privacy Policy apply to?

This Website Privacy Policy applies solely to your interactions with us through our Website (re-defined below). 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 and investor reporting portal, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:

• Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and drivers’ license or state identification card number);
• Other customer records, such as telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets);
• Protected classification characteristics under California or federal law, such as date of birth, citizenship and birthplace;
• Commercial information, such as account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s); and
• Internet or other electronic network activity information, such as information regarding your use of our website, fund data room and investor reporting portal (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.

We do not knowingly collect or solicit personal information from anyone under the age of 18.

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:

• Iformation from your communications with us in connection with this Website, including any update notices provided by you.
• Information captured on our Website, including registration information, information provided through online forms and any 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, including but not limited to:

• 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.
• 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 nonpublic 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, lenders, 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 as set forth above in “What information do we collect about you?”

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 us

For any requests relating to the exercise of your rights under the CCPA, 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.

• Call us using the following toll-free number: +1 (888) 616-5691
• Submit a request online by going to the Contact page on our website and choosing Contact Information Update.
• Email us at the following email address: ir@courtsquare.com

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), we may request further information or your investor portal access credentials, if applicable, 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.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required. Please contact Anthony P. Mirra, the Chief Compliance Officer of Court Square at amirra@courtsquare.com with any questions about this California Website Privacy Policy.