PRIVACY POLICY
At Centerbridge Partners, L.P. (“Centerbridge,” “our,” “us” or “we”), we recognize how important your privacy is to you, and we are committed in our efforts to keep your personal information secure. This Privacy Policy (“Policy”) sets forth our policies with respect to information you provide to us or that we otherwise receive and seeks to help you understand how we collect, use, and manage any information we collect about you when you visit any website owned by Centerbridge that links to this Policy (the “Site”) or when you otherwise interact with Centerbridge.
PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE SITE. WE CAN UPDATE THIS POLICY AT ANY TIME. ANY CHANGES WILL BE EFFECTIVE ONCE POSTED HERE, AND THE UPDATED POLICY WOULD GOVERN ANY AND ALL USE BY YOU OF THIS SITE. IF YOU DO NOT ACCEPT THE TERMS AND CONDITIONS STATED IN THIS POLICY, DO NOT USE THE SITE.
If you are a California resident, please read our Privacy Notice for California Consumers below.
Information we collect.
When you visit this Site or otherwise interact with us, Centerbridge may collect three types of information about you: data you provide to us directly (e.g., where you access this website, contact us via email or other methods, or otherwise make information available electronically or through other means); data we collect about you from other sources; and data that may be provided to us from third-party sources. In addition, we may automatically collect information when you visit our Site. This information may include your Internet Protocol (IP) address, Internet Service Provider (ISP), domain name, browser type, date and time of your interaction with us and information provided by tracking technologies, such as cookies, JavaScript and other similar technologies (“Automatically Collected Information”). Tracking technologies help to collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (e.g., scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Site, but your ability to use some features or areas of the Site, and our ability to provide you with services or resources based on the information we have collected, may be limited. Please see our Cookie Policy, here.
How we use the information we collect about you.
We may use information you give us for the following legitimate interests: to communicate with you, to respond to your inquiries and to provide you with any information you have requested, to provide for the administration of our business and to aid in recruitment efforts/process job applications. We may also use information for the following other lawful purposes: to fulfill our regulatory and/or legal obligations and to process information with your consent. We also may use Automatically Collected Information to better understand how our visitors use the Site, and analyze their demographics, interests and behavior, to improve the content of the Site, the user experience and to manage and further develop our business. Centerbridge will not sell or market Automatically Collected Information to non-affiliated third parties for their marketing purposes. However, we are not restricted or limited in our ability to disclose aggregated statistics about visitors to this Site, along with specific information concerning individual visitors of this website, provided that no specific individual can be identified by the information disclosed.
How we share the information we collect.
We may share your personal information with our affiliates for the management and administration of our business. We may also provide your personal data to third-party service providers such as accountants, auditors, lawyers or other outside professional advisors to Centerbridge (subject to binding contractual obligations of confidentiality), or as required to do so to comply with legal or regulatory obligations or for other legal reasons, including protection of our proprietary and other rights. Service providers who may come into contact with information covered by this Policy are expected to and, in certain cases, directed to safeguard such information and use such information solely for the provision of services to us.
How we safeguard and protect the information we collect.
We have implemented appropriate technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, or other unlawful or unauthorized forms of processing, in accordance with applicable law, including as it relates to transferring information to other countries for purposes as described above.
Data accuracy, minimization and retention.
We take all reasonable steps to ensure that the personal information we store reflects any updates you have provided, that your data is limited to that which is reasonably necessary in connection with the purposes set out in this Policy, and that your data is only processed for the limited period necessary for the purposes set out in this Policy and for our legal obligations for record retention.
Data transfer.
If you are located in the United Kingdom or European Economic Area (“EEA”), we may transfer the personal information we collect about you to our affiliates and other recipients in countries outside the United Kingdom or EEA (such as the United States). We have put in place appropriate safeguards with respect to such transfers.
Your rights.
You have a number of legal rights in relation to the personal data we hold about you, including the right of access to your personal data, the right to request the correction of inaccuracies, the right to request the deletion or restriction of processing of your personal data, the right to withdraw consent and the right to lodge a complaint with data protection authorities. Should you have any questions, comments or concerns about our privacy practices or your personal information, please contact legalnotices@centerbridge.com.
If you are located in the UK, you may also contact our representative in the UK: Centerbridge Partners Europe, LLP, 10 New Burlington Street, 2nd Floor, London W1S 3BE. If you are located in the EEA, you may also contact our representative in the EU: Centerbridge Partners
Luxembourg S.à r.l., 9 Allée Scheffer, 2520 Luxembourg.
Current and prospective investors should also reference the Centerbridge Client Privacy Notice for the Centerbridge Funds which Centerbridge separately makes available.
Q2 2021 Edition
Privacy Notice For California Consumers
Last updated: February 2024
This notice contains disclosures required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”). Terms defined in the CPRA have the same meaning when used in this notice. This notice is only relevant to California residents (“consumers” or “you”), and applies only to the collection or other use of “personal information” that is subject to the CPRA. Consumers with disabilities may request an alternative format of this notice by calling the number found at the bottom of this notice.
Information We Collect. In the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information (“Personal Information”):
| Category | Examples |
| Identifiers | A real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers. |
| Other personal information categories, as listed in the California Customer Records Statute | A signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. |
| Protected classification characteristics under California or federal law | Age (40 years or older), race, color, national origin, religion, disability, sexual orientation, medical condition, ancestry, citizenship, marital status, sex/gender, or veteran or military status. |
| Commercial information | Records of your receipt and payment for services and of personal property. |
| Internet or other similar network activity | Information on your interaction with our website, social media accounts, or electronic communications we send to you. |
| Sensory data | Audio and visual Information, such as your voice and likeness as captured in photographs, video, or audio recordings for audio and video meetings, as well if you attend our events, visit our offices, or leave us a voicemail. |
| Professional or employment-related information | Current or past job history or performance evaluations. |
| Non-public education information | Records concerning your education maintained by or on behalf of an educational institution, such as transcripts. |
| Inferences drawn from other personal information | Profile reflecting a person’s preferences, abilities, and aptitudes. |
| Sensitive personal information | A consumer’s SS, driver’s license, state ID card, or passport number; account log-in or debit/credit card number in combination with any access code, password, or account credentials; precise geolocation; racial/ethnic origin, religious/philosophical beliefs, or union membership; contents of mail, email, and text messages; genetic data; biometric information; PHI; or sex life or sexual orientation. |
Personal Information does not include information that is publicly available, de-identified/ aggregated, or subject to Health Insurance Portability and Accountability Act (HIPAA) or the Gramm-Leach Bliley Act (GLBA).
We collect Personal Information from the following categories of sources:
We do not knowingly sell or share with third parties (for cross-context behavioral advertising) Personal Information from anyone under the age of 16.
Purpose for Collection and Use of Personal Information. We may collect or use Personal Information for one or more of the following purposes:
Disclosing Personal Information. We may disclose Personal Information to:
In the past 12 months, we have not sold or shared (for cross-context behavioral advertising) Personal Information to third parties.
Length of Time. We will keep your Personal Information for as long as necessary to comply with our regulatory obligations.
Rights of California Consumers. The CPRA provides a California consumer the following rights, subject to certain exceptions and limitations:
You may submit requests relating to your exercise of CPRA rights to us via:
phone 212-672-5000
or
email legalnotices@centerbridge.com
You may only make a verifiable request for access or data portability twice within a 12-month period. All verifiable requests must provide (1) enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent and (2) sufficient detail that allows us to properly evaluate and respond to it. We may need to request additional information from you to verify your identity or understand the scope of your request. If we are unable to verify your identity, we will need to deny your request. You may designate an authorized agent to make a CPRA request on your behalf and we reserve the right to seek proof that you have given the authorized agent signed permission to act on your behalf.
We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
Questions
If you have questions regarding this Notice, please contact us at legalnotices@centerbridge.com.
By accessing or using this Centerbridge Partners, L.P. (“Centerbridge,” “our,” “us” or “we”) website (the “Site”), you hereby accept and agree to comply with the terms and conditions set forth in these Terms of Use (this “Agreement”). This Agreement is a binding agreement between you and Centerbridge, and governs your access and use of the Site, which includes any text, graphics, videos, live events, user interfaces, visual interfaces, information, data, tools, products, services and other content (together, “Content”) and the design, structure, selection, coordination, expression and arrangement of the Content on or through the Site. You may contact Centerbridge by e-mail legalnotices@centerbridge.com with questions about the terms and conditions of this Agreement.
PLEASE READ THIS AGREEMENT CAREFULLY BEFORE USING THE SITE. WE CAN UPDATE THIS AGREEMENT AT ANY TIME WITHOUT PRIOR NOTICE AND THE UPDATED AGREEMENT WOULD GOVERN ANY AND ALL USE BY YOU OF THIS SITE. YOU ARE ADVISED TO PERIODICALLY REVIEW THESE TERMS FOR ANY CHANGES. IF YOU DO NOT ACCEPT THE TERMS AND CONDITIONS STATED IN THIS AGREEMENT, DO NOT USE THE SITE.
1. Centerbridge grants you a limited right to use the Site.
Your right to use the Site is subject to your agreement to abide by this Agreement in its entirety, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of the Site. You may not disclose any Content to any third party, except to your financial, legal or tax advisors, and others with whom you share investment decisions. At any time and for any reason we may revoke your right to use all or any portion of the Site. You may not violate or attempt to violate the security of the Site.
2. The Site, and the Information on this Site, is owned by Centerbridge, its affiliates and/or third parties.
The Site and the Content is protected by one or more copyrights, patents, database rights, trademarks, servicemarks and/or other intellectual property and proprietary rights that are owned by Centerbridge, its affiliates and/or third parties. You may not decompose, decompile, reverse engineer, disassemble or otherwise deconstruct all or any portion of the Site. You may not publish, broadcast, retransmit, reproduce, repackage, frame, commercially exploit, use, create any derivative of or otherwise redistribute all or any portion of the Site except as explicitly permitted in this Agreement. You may print copies of any accessible portion of the Site only for your own personal use. You may discuss information that you learn from the Site with your financial, legal, accounting or tax advisors, and others with whom you share investment information for purposes of their advice to you. You may not remove or use any copyright, trademark or other proprietary notice or legend contained on (or printed from) the Site.
3. You make certain representations and warranties regarding your use of the Site.
You represent and warrant that: (i) you have full authority and all rights necessary to enter into and fully perform all of your obligations pursuant to this Agreement; (ii) you have not entered and you will not enter into any agreement or perform any act which might contravene the purposes and/or effects of this Agreement; and (iii) you will not delete any Content from the Site.
The Content may contain information, including fund terms, relating to funds in which you are not currently invested. By accessing this website, you acknowledge that you have requested for the Content to be made available to you and that this request does not arise from any Centerbridge marketing.
4. Limitations on your use of the Site.
You agree (i) abide by all applicable laws and regulations in your use of the Site; (ii) not to interfere with the Sites’ functionality or appearance; (iii) not to data mine, page scrape or use any automatic or manual process to access, acquire, copy or monitor any Content or any portion of the Site; and (iv) not to attempt to gain unauthorized access to any portion or feature of the Site.
5. All Content is for informational purposes only.
Nothing on the Site constitutes an offer to sell or a solicitation to buy any security or other investment. Although the Site may include investment-related information, nothing on the Site is a recommendation that you purchase, sell or hold any security or other investment, or that you pursue any investment style or strategy. We do not give any advice or make any representations as to whether any security or investment is suitable for you or will be profitable. Nothing on the Site is intended to be, and you should not consider anything on the Site to be, legal, tax, investment or accounting advice. You should consult with your own advisors with respect to legal, tax, regulatory, financial, accounting and other similar matters.
YOU SHOULD BEAR IN MIND THAT PAST PERFORMANCE OF ANY INVESTMENT, INVESTMENT STRATEGY OR INVESTMENT STYLE IS NOT INDICATIVE OF FUTURE RESULTS.
6. There are various risks you assume in relying on the Content.
Dated Content speaks only as of the date indicated. We make reasonable efforts to provide accurate Content, but at times we may not promptly update or correct the Site even if we are aware that it is inaccurate, outdated or otherwise inappropriate. We may change all or any portion of the Site at any time without notice to you. We do not endorse the opinions of, or warrant the accuracy of facts or other Content contributed by, any third party. You agree that we are not liable for any action you take or decision you make in reliance on any Content.
7. Centerbridge is not liable for any technological problems and any impact that they may have.
All or any portion of the Site may not be available and may not function properly at any time. We make reasonable efforts to avoid technological problems, but at any time the Site may have and may cause technological problems such as viruses and other damaging computer programming routines or engines. We take reasonable security precautions when using the Internet, telephone or other means to transport data or other communications, but we disclaim liability for any interception of data or communications. We make reasonable efforts to ensure that the Site is secure but we do not guarantee the security of the Site. We are not liable for any damage or injury caused by the performance or failure of performance of all or any portion of the Site. We are not liable for any defects, delays or errors in or resulting from your use of the Site.
8. Centerbridge is not responsible for information on any third party web site that is referred in, or accessible or connected by hyperlink to, the Site.
Centerbridge may provide links from the Sites to certain websites operated by third parties who may or may not be affiliated with Centerbridge (the “Third Party Sites”). Centerbridge is providing such links solely as a convenience to you. Accordingly, Centerbridge makes no representations concerning the content of the Third Party Sites. The fact that Centerbridge has provided a link to the Third Party Site does not constitute an endorsement, authorization, sponsorship, or affiliation by Centerbridge with respect to the Third Party Site, its owners, or its providers. Centerbridge has not tested any information, software, or products found on any of the Third Party Sites and therefore does not make any representations with respect thereto, including any representations regarding the content or sponsors of the Third Party Site, or the suitability or appropriateness of the products or transactions described therein.
9. Centerbridge has the right but not the obligation to monitor and record activity on the Site and respond as it deems appropriate.
We may monitor and record activity on the Site for any reason or for no reason. We may investigate any complaint or reported violation of our policies. We may report any activity that we suspect may violate any law or regulation to regulators, law enforcement officials or other persons or entities that we deem appropriate. We may issue warnings, suspend or terminate use of the Site, deny access to all or part of the Site or take any other action that we deem appropriate.
10. Website Privacy Policy.
Any personal nonpublic information that we gather from you through the Site will be governed by our Website Privacy Policy, which is incorporated into these Terms of Use by reference.
11. Non-Public Investor Sections of the Site.
If you are a Centerbridge investor or are a representative of a Centerbridge investor, you may have been granted access to certain non-public portions of the Site through a uniquely assigned investor log-in (“Investor Portal”). Your use of the Investor Portal Site is also governed by the “Important Information and Terms of Use for the Centerbridge Investor Portal.” If you have been granted access to the Investor Portal by Centerbridge, you must maintain confidentiality of your log-in information and you remain responsible for all usage of the Investor Portal through your account, whether such use is made by you or anyone else. You must immediately notify us of any known or suspected unauthorized use of your log-in information or any known or suspected breach of security, including loss, theft or unauthorized disclosure of your log-in information.
12. CENTERBRIDGE DISCLAIMS ALL WARRANTIES WITH RESPECT TO THE SITE THAT THE LAW ALLOWS IT TO DISCLAIM.
THE SITE IS PROVIDED “AS IS” AND “AS AVAILABLE.” WE DISCLAIM ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, OF ANY KIND WITH RESPECT TO THE SITE INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT OF INTELLECTUAL PROPERTY AND PROPRIETARY RIGHTS. WITHOUT LIMITING OUR GENERAL DISCLAIMER, WE DO NOT WARRANT THE AVAILABILITY, ACCURACY, COMPLETENESS, TIMELINESS, FUNCTIONALITY, RELIABILITY, SEQUENCING OR SPEED OF DELIVERY OF THE SITE OR ANY PART OF THE CONTENT OR THAT THE SITE WILL BE VIRUS AND/OR MALWARE-FREE.
CENTERBRIDGE’S LIABILITY WITH RESPECT TO THE SITE IS LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW. IN NO EVENT WILL WE OR ANY OF OUR AFFILIATES, AGENTS OR EMPLOYEES BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE OR CONSEQUENTIAL DAMAGES HOWEVER CAUSED ARISING OUT OF THIS AGREEMENT, THE SITE, OR THE INABILITY TO USE THE SITE. OUR LIABILITY IS LIMITED EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF THE DAMAGES THAT YOU SUFFER OR IF ANY REMEDY YOU HAVE FAILS OF ITS ESSENTIAL PURPOSE. UNDER ALL CIRCUMSTANCES, THE MAXIMUM LIABILITY OF CENTERBRIDGE, ITS AGENTS AND EMPLOYEES TO ANY USER OF THE SITE WITH RESPECT TO THE SITE IS $100. THIS DISCLAIMER OF LIABILITY APPLIES TO ANY AND ALL DAMAGES OR INJURY, INCLUDING THOSE CAUSED BY ANY FAILURE OF PERFORMANCE, ERROR, OMISSION,INTERRUPTION, DELETION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS, COMMUNICATION LINE FAILURE, THEFT, DESTRUCTION OR UNAUTHORIZED ACCESS TO, ALTERATION OF OR USE OF ANY ASSET, WHETHER FOR BREACH OF CONTRACT, TORTIOUSBEHAVIOR, NEGLIGENCE OR UNDER ANY OTHER CAUSE OF ACTION.
13. You will be responsible for any liability to Centerbridge that arises out of your breach of this Agreement or your use of the Site.
You agree to indemnify and hold harmless Centerbridge and its affiliates, agents, officers, employees and third-party sources from and against any and all suits, losses, claims, demands, liabilities, damages, costs and expenses (including reasonable attorneys’ fees) that arise from or relate to: (i) your use of the Site, (ii) your breach of this Agreement or any representation, warranty or covenant made by you in this Agreement, (iii) your violation of any applicable law, statute, ordinance, regulation or of any third party’s rights, or (iv) claims asserted by third parties which, if proven, would place you in breach of representations, warranties, covenants or other provisions contained in this Agreement.
14. New York law and jurisdiction govern this Agreement.
This Agreement shall be governed by and construed in accordance with the laws of the State of New York, without regard for the conflict of laws principles thereof. Each party hereby consents to the exclusive jurisdiction of the state and federal courts of New York. Each party waives, to the fullest extent permitted by applicable law, any right it may have to a trial by jury in respect of any suit, action or proceeding relating to this Agreement.
15. You are bound by certain other general conditions.
We may assign this Agreement in whole or in part at any time without your consent. You may not assign this Agreement or delegate any of your obligations under this Agreement. Any purported assignment of this Agreement in violation of its terms is void. If any provision of this Agreement is found invalid or unenforceable, that provision shall be enforced to the maximum extent possible and the remaining provisions of this Agreement shall remain in full force and effect. No waiver by Centerbridge of any term of these Terms of Use shall be deemed a waiver of any other term of these Terms of Use. This Agreement constitutes the entire understanding, and supersedes all other understandings, between you and Centerbridge concerning the subject matter hereof.
Last Revised: July 24, 2023
SEC REGISTRATION
Registered with the United States Securities and Exchange Commission (IARD/CRD Number 157359).
FCA REGISTRATION
Authorized and regulated by the UK Financial Conduct Authority (Registration Number 544525).
MODERN SLAVERY STATEMENT
LINK TO MODERN SLAVERY STATEMENT
COMMITMENT TO THE UK STEWARDSHIP CODE
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Centerbridge Partners Europe, LLP, directly and/or through its affiliates (“Centerbridge”), is required to make a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their alternative investment strategy. Centerbridge supports the overall principles of the Code and has adopted a proxy voting policy, a conflicts policy and various related procedures designed to reflect such principles where consistent with all of the following: the investment program of the Centerbridge funds, the governing documents of our funds, applicable laws within and outside the UK to which Centerbridge is subject and, above all, the best interests of our investors as a whole. We make such information available to investors and prospective investors, consistent with our obligations under applicable law. We note that under certain circumstances, the foregoing obligations and objectives may be best achieved by determining not to take action – e.g., by not voting rather than necessarily casting a vote. Certain actions, including voting and acting collectively with others, can carry associated costs and risks. Centerbridge weighs such costs and risks against the benefits sought to be achieved by the Code in its day-to-day application of the Code’s principles to its business.
COMMITMENT TO THE SHAREHOLDER RIGHTS DIRECTIVE II
Under the Shareholder Rights Directive II (the “Directive”), Centerbridge Partners Europe, LLP, directly and/or through its affiliates (“Centerbridge”), is required to make a disclosure about the nature of its commitment to the Directive, or, where it does not commit to the Directive, to provide a clear and reasoned explanation for not doing so. The Directive sets out a number of principles relating to the role of shareholder engagement and the exercise of voting rights in EU listed companies. While Centerbridge supports the overall principles of the Directive, Centerbridge’s investment strategies (credit, private equity and real estate) involve only minimal activity in scope of the Directive. Therefore we have determined not to adopt an engagement policy, and to rely instead on the Firm’s existing policies and procedures, including our proxy voting policy, our conflicts policy and various related procedures already in effect, which are directly responsive to the principles of the Directive and which Centerbridge has determined are proportionate to the risks of the business. We make such information available to investors and prospective investors, consistent with our obligations under applicable law.
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