Crescent Capital Group LP Privacy Notice
Respect for Your Privacy
The privacy of your personal information is important to Crescent Capital Group LP (“Crescent”). We have policies protecting the confidentiality and security of information we collect about you and we are committed to protecting the privacy of that information. Furthermore, the privacy of your personal information may be protected by various government laws or regulations.
At the same time, in order to provide you with services you may request, it is necessary for us to possess some personal information of yours. Similarly, without some of that information, we cannot inform you about the services we have available or that you may request (though if you are currently receiving information or marketing communications from us, you may opt-out of receiving further communications at any time).
This privacy statement explains our personal information policies and practices. It includes, but is not limited to, explanations of the types of personal information we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, your rights regarding your personal information, and the way to contact us to exercise those rights.
We provide this notice to you to comply with the requirements of Regulation S-P, “Privacy of Consumer Financial Information,” issued by the United States Securities and Exchange Commission and the Federal Trade Commission (“FTC”) privacy regulations.
California residents also have rights under the California Consumer Privacy Act (“CCPA”) and this privacy notice provides the details you need to understand your rights under the CCPA, and to exercise those rights. It provides you with the contact information you need to take action regarding the privacy of your data.
Crescent Never Sells the Personal Data It Collects
You may contact us with respect to our privacy and data protection policies and to exercise any of your rights set forth in this privacy notice by calling this toll-free number (833-358-0002) or by emailing us (firstname.lastname@example.org) or, if you are an investor in one of our private funds, by writing the General Partner at its registered address as set out in your Limited Partnership Agreement. Additionally, you may contact us by regular mail at:
Crescent Capital Group LP
Attn: Privacy Officer
11100 Santa Monica Blvd., Suite 2000
Los Angeles, CA 90025
Data Privacy Information
Defining Personally Identifiable Information
“Personally Identifiable Information” (PII) refers to data that could be used, alone or in combination with other data, to identify you as an individual. It can include name, physical address, email address, IP address, date of birth, social security number, passwords, credit card or other financial or payment information, and more.
Types of Collected PII
Crescent collects some of your personally identifiable information. This section describes the categories of PII that are collected, as well as the categories of sources for obtaining that PII, and the purpose for collecting it.
The PII we collect from you consists of the following categories:
- Investor Data
- Your name, address and identifying numbers and other personal and financial information, from you and from identification cards and papers you submit to us, on applications, subscription agreements or other forms or communications, including but not limited to: first name, last name, mailing address, date of birth, residential history, work history, education history, signature, financial history, personal and/or business email address, telephone, mailing address, social security number or other government issued identification, driver’s license, passport, and photograph.
- Custodian and Broker/Dealer Data
- Information about your account balances and financial transactions with us, our affiliated entities, or nonaffiliated third parties.
Sources for PII
We obtain PII both directly from you and indirectly through third parties such as your consultants, representatives or agents as well as non-affiliated sources such as credit reporting agencies.
Purpose and Legal Bases for Collecting Your PII
We collect and process your PII for a variety of business purposes and legal bases including:
- Legal Basis: Collection and processing is necessary for the performance of your contract:
- Creating, managing and administrating your account
- Conducting anti-money laundering and know-your-client compliance
- Contacting you or your designated representative by phone, email, fax, or mail
- Report tax information to the relevant tax authorities
- Facilitating financial transactions related to your account
- Fulfilling our legal and regulatory obligations
- Updating and maintaining business records
- Legal Basis: Collection and processing is necessary for Crescent’s legitimate business interests:
- Providing you or your representative with marketing communications
- Carry out statistical analysis and market research
Our Website and Your PII
Visiting and navigating our website may involve some form of usage of your PII. This section details the methods and permissions involved.
Crescent does not use on our website automated collection tools - such as cookies or web beacons - that capture information sent from your web browser to our website.
Consent to Use Your PII
By completing any online form on our website, you consent to our storing and using your PII for the reasons provided in this notice. You also consent to our using it to reply to your request as well as to contact you in the future, whether or not at your request, to provide you with additional information.
Without some of this information we cannot provide you with the services you may request. If you are currently receiving information or marketing communications from us, however, you may opt-out of receiving further communications at any time.
Sharing Your PII
Your PII may be combined with information we receive from other sources, or it may be provided to other organizations we work with. This section details that sharing of your PII.
Receiving PII from Third Parties
We may receive information about you from other sources and combine that information with the PII we collect directly from you. For example, we may receive payment information from the organization you use to pay us in order to correct our records. Additionally, to promote protection of your identity, we also may collect credit or identity information which we use to help prevent and detect fraud.
Sharing PII with Third Parties
We do not sell your PII to any third parties.
We may share your PII with our affiliates, business partners, and other third parties including financial advisors, regulatory bodies, back office account providers, custodians, auditors, and technology providers. We may do so for the purposes of operating our business, including to execute, process, service and confirm your securities transactions, to administer and service your account and commingled investment vehicles in which you are invested, to market our products and services through joint marketing arrangements, and to deliver and improve the financial services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business.
We also share personal information for a variety of additional purposes including, but not limited to:
- Within Crescent and our affiliates and subsidiaries for data processing or storage purpose
- With business partners and suppliers to provide services and help facilitate transactions (including opening accounts, conducting securities transactions, processing orders, event registrations, data storage, marketing communications and customer support
- In response to a request from law enforcement, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements
PII From Minors
We do not offer financial services and products to minors and do not intend to collect personal information from children under the age of 13 years. We follow all local legal requirements with respect to the collection and processing of a minor’s personal information.
For California Residents Only
Your PII Rights
The CCPA provides residents of California with certain rights in regard to what we do with your personally identifiable information. This section details those rights, how to exercise them, and what Crescent will do in response.
You have the right to request that we disclose to you, free of charge, the categories and specifics of the PII we collect about you. We require a verifiable request from you to ensure that it is, in fact, you who is requesting such a PII disclosure. Once we verify the request, we will provide that information to you.
Your request for disclosure can apply to any such PII mentioned in the previous paragraph for as much as twelve months preceding your request. Be advised that we are not required to disclose such information about the PII we collect about you more than twice in a twelve-month period.
Following our verification of your request, we will disclose to you, unless otherwise restricted by law or regulation, the following PII we collect about you:
- The categories of personal information we have collected about you
- The categories of sources from which the personal information is collected
- The business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom we share personal information
- The specific pieces of personal information we have collected about you
Deletion of PII
You have the right to request that we delete the PII we have collected from you. Following our verification of your request, we will comply with your request and delete any or all of your PII in our possession that we collected from you and/or any or all such PII in the possession of our service providers, unless otherwise restricted by law or regulation.
Non-Discrimination for Exercising Your PII Rights
We follow the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.
Contacting Us to Exercise Your PII Rights
You may contact us in order to exercise any of your rights set forth in this privacy notice by the methods set forth at the bottom of the first page of this notice.