Privacy Policy | Odyssey

This Privacy Policy describes how we at Odyssey Investment Partners including our funds, affiliates and subsidiaries (collectively, “we” or “Odyssey”) collect, use and share the personal information that we gather through our website located at https://www.odysseyinvestment.com/ (the “Website”). This Privacy Policy does not apply to any information you provide to us separately from the Website, whether through email, postal mail or during a telephone call. By accessing or using the Website, you acknowledge that you have read and agree to this Privacy Policy, which is part of our Terms of Use, available here . Odyssey may change the Privacy Policy at any time. If we make any material changes to the Privacy Policy, we will post them on the Website

For Limited Partners

If you are an Odyssey investor that is an individual, our policies and practices regarding the collection and processing of your personal information are detailed in our Investor Privacy Policy. This Privacy Policy does not apply to any Limited Partner’s use of the Limited Partner Portal. A service provider powers and hosts the Limited Partner Portal, and use of the Portal is governed by that service provider’s terms of use and associated privacy policy, available here and here, which we encourage you to read.

Our Collection and Sources of Personal Information

We collect limited personal information and identifiers through the Website about our visitors via a third-party web-hosting provider, including:

Our third-party web-hosting provider routinely logs visitor Internet protocol (“IP”) addresses. The processing of IP addresses allows our provider to monitor the use of the Website in order to further our legitimate interest in safeguarding our IT systems. The provider does not provide us with any such information. It is possible that we or the third-party provider would be able to identify you by a combination of your IP address and other information.
Our Website uses site-specific cookies, through which small amounts of data are sent to your computer from the third party’s web server and stored on your computer’s hard drive. This data allows you to be identified as a unique user when visiting the Website. This technology does not provide us with any information about your name, address, phone number, or email address.
We may also collect personal information that you provide to us voluntarily when you contact us for any reason. ve not sold such personal information in the preceding 12 months.

How We Use Personal Information

To understand and analyze the usage trends and preferences of our website visitors;
for ongoing review and improvement of the information, content, and services we provide to ensure they are user friendly;
to understand your needs and interests and respond to inquiries and/or other requests or questions;
to detect, investigate and prevent fraud and other crimes or malpractice, and to improve fraud detection and information security;
for the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), and to obtain legal advice or to establish, exercise or defend our legal rights; and for the management and administration of our business, and to comply with our contractual obligations.

How We Disclose Personal Information

In limited circumstances, we may share your personal information with external third-parties, namely to:

Service providers in order to service the Website, engage in analytics, auditing, research, and reporting or manage our advertising;
law enforcement, government regulators or agencies, or other individuals to comply with legal process and our legal and regulatory obligations;
law enforcement or other third parties in connection with investigating suspected or actual illegal activity, or violation of our Terms of Use; and to a buyer or other successor, in connection with, or during negotiations of, a corporate transaction, such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of our assets or liabilities or any line of business, change in ownership control, financing transaction, or in the unlikely event of a bankruptcy.

Data Retention

We retain the personal information described above for as long as may be needed in order to provide the services provided through the Website, or for other necessary purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements or for records management purposes, in which case how long we retain the personal information will be determined by factors including the nature of the legal obligation and/or length of relevant proceedings. We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer periods. Even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.

Cross-Border Transfer

The Website is hosted in the United States. If you access the Website from outside the United States, you will be transferring your information, including personal information, to the United States, and you consent to such transfer. Please be advised that the United States does not offer the same protections for the personal information as countries within the European Economic Area or the United Kingdom.

Your Rights

Depending on your state and country of residence, you may have a right to:

Request access to your personal information and obtain a copy of the information we hold about you;
request that such personal information be deleted;
opt-out of the sale or sharing of personal information
correct your personal information that we hold where it is incomplete or inaccurate;
decline to share certain information with us (in which case we may not be able to provide you some of the features and functionality of the Website);
require that certain of your personal information be transferred to you or a third party;
request that we restrict or block our processing of your personal information; and
lodge a complaint with the data protection regulator in your jurisdiction if you think that any of your rights have been infringed by us.

To submit such a request, please contact our Chief Compliance Officer as set out below.

If you choose to exercise your rights we will not deny services, offer a different quality of service or otherwise discriminate against you for exercising any of your rights listed in this Privacy Policy.

We note that these rights are not absolute and some certain state and national privacy laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.

Additional Information for California Residents

This section provides additional information for California residents only. The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, and/or its implementing regulations (collectively, the “CCPA”) provide protections and rules with respect to California’s definition of Personal Information, which includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual our household.

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If we are successful in validating your identity, we will respond to your request within the time and in the manner required by the CCPA. If we are unable to verify your identity, we will need to deny your request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

If you request to know, access, delete and/or correct your personal information, we may require you to provide any of the following information: address, date of birth, state or country of residence, telephone number, email address or details of a transaction. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. We will use the information you submit and the information we have in our systems to try to verify your identity and to match the Personal Information we have collected about you, if any, to your identity.

If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (a) provide the authorized agent written permission (e.g., via a notarized letter) to do so, and (b) verify your own identity directly with us (as described above), and confirm with us that you provided the authorized agent permission to submit the request.

We do not sell personal information and have not sold any personal information in the preceding 12 months.

In the preceding 12 months, we have only disclosed certain identifiers, consisting of IP addresses and site-specific cookies, to our third-party service providers in order to further our legitimate interest in safeguarding our IT systems and in the case of cookies, for the purposes set forth in the “How We Use Personal Information” section above.

Additional Information for United Kingdom and the European Economic Area

This section provides additional information for individuals in the United Kingdom and the European Economic Area only, who have certain rights under the European Union General Data Protection Regulations (“GDPR”) or United Kingdom GDPR and/or Data Protection Act.

Depending on the circumstances, you may have the right to:

request access to your personal information and obtain a copy of the information we hold about you;
correct your personal information that we hold where it is incomplete or inaccurate;
have your personal information erased where there is no legitimate basis for us continuing to use or retain it;
require certain of your personal information to be transferred to you or a third party;
request that your personal information is used only for restricted purposes and in certain circumstances, object to the processing of your personal information; and
file a complaint with the relevant data protection authority in your jurisdiction.

If you wish to exercise any of these rights, please contact our Chief Compliance Officer as set out below in the “Questions and Contact Information” section of this Privacy Policy. In most cases, we are required to respond to your request within one month. You typically will not be charged a fee in connection with any legitimate requests.

We are entitled to use your personal information for the purposes set forth in the “How We Use Personal Information” section above, because one or more of the following legal bases applies:

We need to do so in order to perform our contractual obligations to you (for example, in order to manage your investments and verify the information you provide);
we have obtained your specific and informed consent (which may include written consent) unless an exemption provided under applicable law permits the use and disclosure of your personal information without your consent;
we have legal or regulatory obligations that must be discharged;
we may need to do so in order to establish, exercise, or defend our legal rights or for the purpose of legal proceedings; or
the use of your Personal Information is necessary for our legitimate business interests or the legitimate interests of a third party, provided such interests are not overridden by your rights or interests, such as: (a) allowing us to effectively and efficiently administer and manage the operation of our business; (b) maintaining compliance with internal policies and procedures; (c) monitoring the use of our copyrighted materials; (d) offering optimal, up-to-date security solutions for mobile devices and IT systems; and (e) for internal research purposes.

Links to Other Sites

The Website links to other websites that are controlled by third parties. We include such links to make it easier for you to get information at their websites. We do not have control over the content or privacy policies at those websites. We recommend that you look at the privacy policies of those websites before you use them. If you link to or use such third-party websites or features, you do so at your own risk.

Data and Network Security

We maintain commercially reasonable operational policies, including physical, electronic and procedural protections, to safeguard the security of your information. We cannot, however, guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of any of our safeguards. Although we may allow you to adjust your privacy settings to limit access to your information, no security measures are perfect or impenetrable. We cannot control the actions of other users or other third parties with whom you may choose to share your information. Therefore, we cannot and do not guarantee that information you provide through the Website will not be viewed by unauthorized persons. We are not responsible for circumvention by any third party of any privacy settings or security measures contained within the Website. You use the Website at your own risk.

Protecting Minors

The Website is intended for use by individuals over the age of 18. We do not knowingly collect personal information from individuals under the age of 18. If you are under 18 years of age, then please do not use or access the Website at any time or in any manner.

Governing Law

This Privacy Policy is governed by New York state law. Any dispute regarding this Privacy Policy or your use of the Website shall be resolved solely in the state or federal courts located in New York.

Limitation of Liability

By accessing the Website, to the extent permitted by applicable law, you expressly and unconditionally release and hold us harmless from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of such information. In addition, while we take efforts to ensure the proper and appropriate use of data by our service providers that may receive your information from us, we are not responsible for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your information caused by those service providers.

Questions and Contact Information

If you have any questions about the Privacy Policy, want to ask for a record of the information we hold about you, ask us to delete or correct your information, or to exercise any other of your rights outlined above you may contact the Chief Compliance Officer by telephone at 212-351-7900, by email at vhadis@odysseyinvestment.com or send your questions or concerns in writing to:

Odyssey Investment Partners

590 Madison Avenue

39th Floor

New York, New York 10022

Attn: Chief Compliance Officer