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Privacy Policy 

This Privacy Policy describes how we at Odyssey Partners including our funds, affiliates and subsidiaries (collectively, “we” or “Odyssey Partners”) collect, use and share the personal information that we gather through our website located at (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 this Privacy Policy. This Privacy Policy should be read in conjunction with 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

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.

Personal Information We Collect and How We Use It

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

In addition, 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.

In the preceding 12 months, if you visited our Website, we have only collected identifiers, consisting of IP addresses and site-specific cookies, for the purposes described above. We do not sell personal information and have not sold such personal information in the preceding 12 months.

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 to further our legitimate interests as described above;
  • law enforcement, government regulators or agencies, or other individuals to further our legitimate interest in complying with legal process and our legal and regulatory obligations; and
  • law enforcement or other third parties in connection with investigating suspected or actual illegal activity, or violation of our Terms of Use, in furtherance of our legitimate interests.

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 described in the chart above.

Data Retention

We retain the personal information described above for a period of 5 years 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, 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.

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 IP address and information collected by cookies to the United States. 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 information about any personal information, including IP addresses and information collected by cookies, and copies of any such personal information;
  • request that such personal information be deleted;
  • opt-out of the sale or sharing of personal information; and
  • to correct inaccuracies in personal information.

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.

California Residents

This section provides additional information for California residents only. The California Consumer Privacy Act of 2017 and/or its implementing regulations (“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.

In accordance with the CCPA, in addition to the rights enumerated above, California residents have the right to:

  • opt-out of automated decision-making technologies.

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.

Our site links to other websites that are not part of our organization. We include those links to make it easier for you to get information at their sites. We do not have control over the content or privacy policies at those sites. We recommend that you look at the privacy policies of those websites before you use them.

Data and Network Security

We maintain commercially reasonable operational policies, including physical, electronic and procedural protections, to safeguard and secure our data networks. We cannot guarantee the absolute security of our servers or databases or those of our third-party service providers. You use the Website at your own risk.

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 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