Our Commitment to Privacy – USA

Your privacy is important to Irving Place Capital Management, L.P. and its affiliates (together, “Irving Place Capital,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.

This Privacy Policy describes how we gather and use information for visitors of this website. Please read this Privacy Policy carefully. If you do not agree with any of the terms and conditions contained herein, please do not access or otherwise use this website.

This Privacy Policy constitutes a legally binding agreement between Irving Place Capital and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, the Privacy Policy stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Privacy Policy, please do not access or use this website.

Our Commitment to Privacy – EU

Your privacy is important to Irving Place Capital Management, L.P. and its affiliates (together, “Irving Place Capital,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.

This EU Privacy Policy describes how we gather and use information for visitors of this website that are from the EU and supersedes the Privacy Policy of Irving Place Capital linked to this website with respect to EU users, as applicable. Please read this EU Privacy Policy carefully.

For the purposes of applicable EU laws, Irving Place Capital, IPC Manager II, LLC, IPC Manager III, L.P., IPC Manager III SPV, L.P., IPC Group III, L.P. and their affiliated general partner and managing member entities will each be a data controller of any personal data collected by us. If you have any questions regarding our use of your personal data, or this EU Privacy Policy, please contact the Chief Compliance Officer of Irving Place Capital at ipcfinance@irvingplacecapital.com with any queries arising out of this Privacy Notice.

We rely on various legal bases under applicable data protection legislation in order to process your personal information (e.g., name, title, address, email, marital status, date of birth, IP address, financial data, username, password, etc.), including our legitimate interests, contractual necessity and as required by law. We use the personal information we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot provide our services or products to you). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

The Information We Collect and How We Use It

We may collect various types of information from users of this website. For example, knowing how users use our website – tracking their movement through this website – helps us improve website design and usefulness. As a result, Irving Place Capital’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website, and IP addresses. Irving Place Capital generally does not, however, collect any personally identifiable information such as names, home addresses, or e-mail addresses from users of this website.

To the extent that you provide us with any personally identifiable information through or in connection with this website, we may use such information for Irving Place Capital’s business purposes, but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to Irving Place Capital, you consent to Irving Place Capital’s use of such personally identifiable information for the purposes described in this Privacy Policy.

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we employ certain safeguards to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.

Capacity

You represent to Irving Place Capital that you have the authority to visit this website according to the Terms of Use. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

Notification of Changes

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy means that you accept such revisions, changes, and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.

Miscellaneous

The provisions in our Terms of Use are hereby incorporated by reference.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact the Chief Compliance Officer of Irving Place Capital at ipcfinance@irvingplacecapital.com.