Privacy Notice

Important information and who we are

Purpose of this privacy notice


This privacy notice describes how Angelo, Gordon & Co., L.P. and its affiliates (“Angelo Gordon” or “we”) collects and processes your personal information through your use of this website, including any data generated or any data provided by you or otherwise communicated when you use the password-protected section of our website for investors (the “Investor Portal”).

This privacy notice is not intended to override any other privacy notice we provide you in specific circumstances.

If you have any questions about this privacy notice or how we treat your personal information, please contact us at:

Email address: [email protected]
Postal address: Angelo, Gordon & Co., L.P., 245 Park Avenue, 25th Fl., New York, NY 10167 USA

Third-party links


This website may include links to third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy statements.  When you leave our website, we encourage you to read the privacy notice of every website you visit.

What personal information do we collect?


Personal information means any information about an individual from which that person can be identified.   We may collect:

  • Technical Information, which may include your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform on the devices you use to access this website.
  • Usage Information, namely, information about how you use our website including, but not limited to, how long you spend on it and which pages you visit.
  • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.  For example, we may aggregate your Usage Information to calculate the percentage of users accessing a specific website feature.  However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

In addition, for users of the Investor Portal, we may collect, use, store and/or transfer different kinds of information about you, such as:

  • Identity Information, including your first name, last name, username or similar identifier, title, date of birth, gender, marital status, and spouse’s name.
  • Contact Information, including your mailing address, email address and telephone numbers.
  • Financial Information, including your tax documents.
  • Transaction Information, including details about the investment activities of the funds or accounts managed by us in which you have invested.
  • Profile Information, including your username and password, and account preferences.

If you fail to provide personal information


Where we need to collect personal information by law or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with investment services).

How is your personal information collected?


We use different methods to collect information from and about you:

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Information about your equipment and browsing. We collect and store this personal information by using cookies and server logs.  We may also collect Technical Information about your browser through web beacons in emails sent from our website, including investor notifications and marketing emails, to confirm if they were received and opened.
  • Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
    • Aggregated Data from Google Analytics;
    • Identity and Contact Information from publicly available sources, such as your website, industry conference websites, industry publications, etc.

In addition, for users of the Investor Portal, we may collect information in the following ways:

  • Direct interactions. You may give us information that we use or store on this website by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:
    • engage our investment services or subscribe to a fund that we manage;
    • create an account on our website’s Investor Portal; or
    • request or agree to receive marketing emails, offers, and publications from us.

If you are in the European Union or European Economic Area you can find out more about your rights in relation to your personal information that we handle by consulting Section 10, below, or by consulting the Guide to the GDPR published by the Information Commissioner’s Office, which is available by clicking here.  For users of the Investor Portal, you may also find out more about your rights in relation to your personal information that we handle by consulting the Privacy Notice that has been provided to you, which is also available by clicking here.

How do we use your personal information?


We will only use your personal information via this website in accordance with applicable law. Most commonly, we use your personal information in the following circumstances:

  • Where we need to perform our obligations under contract(s) related to your investments.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal information


The table below describes how we may use your personal information via this website and on what basis.  We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information on more than one basis depending on the purpose for which we are using your information.  Please contact us if you have questions or would like further information.

Purpose/Activity

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of information

  • Technical
  • Usage

Basis for processing

Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

For users of the Investor Portal, the following describes additional purposes for which we may use your personal information.

Purpose/Activity

To facilitate your investments in funds and accounts managed by us, including to:

  • Provide access to account statements, tax documents and other account related documents.
  • Distribute investor letters and other communications relating to your investments.
  • Provide access to required regulatory forms.

Type of information

  • Identity
  • Contact
  • Financial
  • Transaction
  • Marketing and Communications

Basis for processing

  • Performance of a contract with you
  • Necessary for our legitimate interests of managing our overall relationship with you.
  • Necessary to comply with a law or regulation

To manage our relationship with you which will include:

  • Notifying you about changes to our website terms of use, website privacy notice, or your investments with us.
  • Asking you for feedback.
  • Identity
  • Contact
  • Profile
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests of maintaining complete, accurate records and studying how clients use our products/services

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Identity
  • Contact
  • Technical
  • Usage
  • Necessary for our legitimate interests of running and safeguarding our business, providing administration and IT services, ensuring network security, and preventing fraud
  • Necessary to comply with legal obligations

To keep you updated on relevant developments in capital markets and other investment news.

  • Identity
  • Contact
  • Profile
  • Necessary for our legitimate interests of keeping our clients informed of our views of the capital markets and relevant investment news

Marketing


Certain documents posted to the Investor Portal may contain communications that are considered marketing.  You are not required to access such documents in order to use the Investor Portal.

In addition, you may receive marketing communications from us if you have requested information from us or automatically if you have previously engaged us as investment advisor and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing communications at any time by contacting us at [email protected] at any time.

Where you opt out of receiving marketing communications, this will not apply to personal information provided to us as a result of investment activities or other transactions.

Cookies


When you visit our website, you will not have the opportunity to reject our use of cookies.  You may set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Some web browsers may transmit “do-not-track” (DNT) signals.  We currently do not respond to DNT settings in your web browser.

We use cookies only for administering the website and ensuring website security.  If you disable or refuse cookies, please note that some parts of this website and our Investor Portal may become inaccessible or not function properly.

The table below describes the cookies we use, their names, and what we use the cookies for:

Type of cookie

“Remember Me” cookie

Purpose

This cookie is used to remember a client who signs in through the mobile app.  If you check this box when you log in on your mobile device, we will store your login information and your mobile device identifier in this cookie.

Investor portal session cookies

This encrypted cookie is used to collect information about how a client uses the private part of our website, after logging in.  It stores a user’s identity and associated IP address, pages visited, and documents downloaded only for the length of the login session.

The IP address will be kept in our third-party IT provider, ITG’s, server logs for at least twelve months for website security functions.  We do not store session cookies by user, so we cannot link together multiple sessions by a particular user.

Analytics cookies

We may use analytics cookies through Google Analytics to help us understand how people use our website.

Change of purpose


We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How do we share your personal information?


We may share your personal information with the parties set out below:

  • Internal Third Parties: Angelo Gordon affiliates including investment funds that we manage.  The groups in Angelo Gordon may share information where it is necessary to perform a contract we have entered or will enter with you, in our legitimate interests, or necessary to comply with a legal or regulatory obligation.
  • External Third Parties:
    • Service providers, including Imagineer Technology Group, and other third-party providers of information technology resources. We may share your personal information with service providers that perform certain functions or services on our behalf in order to fulfill the services you request from us.  These include third parties which host our website, manage databases, perform analyses, send communications for us, process transactions on our behalf, or provide certain other components of our website.  We do not authorize service providers to use or disclose the information, except as necessary to perform services on our behalf.
    • We may use analytics tools provided by Google to help us understand how people use our website. You can learn more about how Google collects and uses information as a part of its tools at https://www.google.com/analytics/#?modal_active=none.
    • Legal process. We may disclose your personal information to the extent necessary to respond to subpoenas, court orders, or other legal processes in response to a request for cooperation from law enforcement or another government agency, in order to comply with our legal and regulatory obligations.
    • Protection of our clients and services. We may disclose your personal information to third parties such as law enforcement if we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity, or violation of our Terms of Use or other contracts.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

How long do we use your personal information for?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  Technical Information regarding your visit to this website is retained only for the duration of the browser session in which you accessed the site.

For users of the Investor Portal, we will retain your personal information specifically concerning your investment for a minimum of 6 years after you have exited your investment in one of our funds.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you are in the European Union or European Economic Area you can find out more about your rights in relation to our retention of your personal information consulting Section 10, below, or by consulting the Guide to the GDPR published by the Information Commissioner’s Office, which is available by clicking here.  For users of the Investor Portal, you may also find out more about your rights in relation to our retention of your personal information by consulting the Privacy Notice that has been provided to you, which is also available by clicking here.

How do we secure your personal information?


We use reasonable technical, administrative and physical security measures to protect your personal information.  We of course cannot guarantee that any information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from unauthorized access or use (e.g., by hackers).  We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties while or after you transmit your information to us.

If you create an account on our Investor Portal, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity.  Please notify us of any unauthorized use of your password or account or any other breach of security.

Children’s Privacy


Our services are not directed at individuals under the age of 18.  We do not knowingly collect information from children under the age of 18.  If we become aware that a child under 13 has provided us personal information, we will delete such information from our files.

Changes to this privacy notice


We may change this privacy notice from time to time.  When we do, we will update you by posting the changed privacy notice on this page with a new “Last Updated” date.  In some cases, we may also inform you of changes by additional means, such as by sending an email to your email address in our records.

Information Collected from Individuals in the European Union and European Economic Area

Your legal rights


You have various rights under the European Union General Data Protection Regulation in relation to the personal information we hold about you.  These include:

  • the right to request access to your personal information and obtain a copy of the information we hold about you;
  • the right to correct your personal information that we hold where it is incomplete or inaccurate;
  • the right to have your personal information erased where there is no good reason for us continuing to use or retain it;
  • the right to request that your personal information is used only for restricted purposes;
  • if the lawful basis for processing your personal information is either our or a third party’s legitimate interests, the right to object to your personal information being processed;
  • the right to require certain of your personal information to be transferred to you or a third party; and
  • the right to lodge a complaint with the relevant data protection authority in your jurisdiction (for example, the Information Commissioner’s Office in the United Kingdom).

If you wish to exercise any of these rights, please contact Angelo Gordon Client Services at [email protected] or by post at Angelo, Gordon & Co., L.P., 245 Park Avenue, 25th Floor, New York, NY 10167 USA.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

International Transfers

This website is hosted in the United States. If you use this website, you are voluntarily transferring your personal information to the United States, a jurisdiction which does not offer the same type of protection to the personal information of individuals as countries within the European Economic Area.