In this Policy when we refer to Crestline or “we”/“us”/“our” we mean Crestline Management, LP, Crestline Europe, LLP and other entities that are associated with us.
We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.
This Policy describes:
- Categories of information that we collect
- How we use the information we collect
- How we share thhe information with third parties
- How long we keep your information
- Your rights regarding your data
- How to contact us and other important information
The information that we collect and where we get it from
"Personal information" is any information that can be used to identify you or that we can link to you and which we have in our possession or control.
We will collect and process the following categories of personal information about you:
- Information that you provide to us
We will process personal information that you give to us including when you email us or contact us through various channels as follows:
- Signing up for access to our Site: when you sign up for access to our website or when you contact us with queries or respond to our communications the personal information you provide may include your full name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.
- In connection with our provision of investment advisory services: if you are a client of Crestline you will provide us with personal information when you or the company you represent becomes a client. If you are not a client we may collect or receive your personal information because you are involved in one of our client’s matters.
- Recruitment application: when you apply for a role with us you may provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, home address and home telephone number, mobile telephone number and other details set out in your application.
Information we otherwise collect about you
Information we obtain from other sources
- If you apply for a position with us we may collect personal information relating to past employment, qualifications and education, opinions from third parties about you, past employment history and other details about you, which will be provided to us by a third party that provides background screening services to us.
- If we collect or receive your personal information in the context of our provision of investment advisory services we might receive information from third parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities. That information could include your name, contact details and other information relevant to the investment advisory services that we are providing to our client.
How we use the information we collect
We may do the following with your personal information:
- use it to provide investment advisory services to the relevant client
- use it to engage in marketing and business development activity in relation to our investment advisory services. This may include sending you newsletters, marketing communications and other information that may be of interest to you
- where you have applied for a position with us, to review and process your job application
- to comply with legal and regulatory obligations that we have to discharge
- use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings
- record and monitor your use of our website for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports
- use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our website and our business
- use it to look into any complaints or queries you may have, and
- use it to prevent and respond to actual or potential fraud or illegal activities.
Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
- Consent - we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
- Performance of a contract - we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
- Legitimate interest - we may use your personal information for our legitimate interests, some examples of which are given above.
- Compliance with law or regulation - we may use your personal information as necessary to comply with applicable law/regulation.
How we share information with third parties
We share personal information among our US and international offices and the various companies and entities that make up our international network. As a result, your personal information may be transferred between locations in the US, in Europe and outside Europe for the purposes described above.
We may also share your personal information outside the Firm. This may include:
- Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
- Third parties relevant to the investment advisory services that we provide. This may include, but is not limited to, attorneys, accountants, auditors, brokers, bankers and other professional service providers, regulators, authorities and governmental institutions.
- To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
Where we transfer your personal information as noted above, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information.
You can obtain more details of the protection given to your personal information when it is transferred outside Europe by contacting us using the details set out below.
How long we keep your information
How long we hold your personal information for will vary and will depend principally on:
- the purpose for which we are using your personal information - we will need to keep the information for as long as is necessary for the relevant purpose, and
- legal obligations - laws or regulation may set a minimum period for which we have to keep your personal information.
We will ensure that the personal information that we hold is subject to appropriate security measures.
Your rights regarding your data
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.
These rights include:
- Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
- Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed other than to our client and as authorised by our client.
- Requesting that we correct your personal information if it is inaccurate or incomplete.
- Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
- Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
- In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit those information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
- Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
- Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
- We can, on request, tell you which data protection authority is relevant to the processing of your personal information.
How to contact us and other important information
If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at: Data Protection Liaison - firstname.lastname@example.org