Blue Torch Privacy Policy

Protecting investor privacy is vital to our business. This Privacy Policy describes how Blue Torch Capital LP together with its subsidiaries and affiliates (”Blue Torch”) gathers and uses personal information about you when you communicate with us through our website (the “Site”), and how we protect and share this information and the rights you may have in relation to this information.

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. When you visit and browse the Site, you may provide us with information.

Information You Provide to Us

In order to request information from us from the Site, you will be required to provide personal information. This may include your name, postal address, e-mail address, telephone number, facsimile number, investor status, or other information about yourself. In particular, you may be required to provide a username and password to access certain features. If you choose to not provide us with information, you might not be able to gain access to certain information and services on the Site, which rely on such information.

Information Collection Practices

The Site may contain links to websites operated by third-parties, and your personal information may be collected by those third-parties when you use their websites. Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to the Site). These links are provided to you for convenience purposes only, and you access them at your own risk.

How We Use the Information We Collect

We use information we collect about you primarily to communicate with you and manage and improve our services for you and our other investors, as permitted by applicable laws.

We use your personal information that we collect on the Site to:

  • respond to your requests for forms, literature, or information, on the basis that it is in our business interests to respond to your requests, and you have requested that we do this;
  • manage and administer customer services, including but not limited to the administration of your customer account if applicable. In most cases we do this is to meet our contractual obligations to you. Where there is no such obligation, we have a business interest in keeping our records accurate and up to date, which will assist you when we provide our services;
  • comply with legal obligations; and
  • protect our rights, your rights, and the rights of others, as this may be necessary to meet our own high standards of business practice.

We do not share or sell any of your personal information that is collected from this Site.

We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.

When deciding how long to keep your personal information after our relationship with you has ended, we take into account how long we need to retain the information to fulfill the purposes described above and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.

The Security Measures We Take to Safeguard Information

The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. From time to time, we review and consider updates for our security procedures. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable. We process information collected via the Site in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States.

Children’s Information

The Site is intended for use by those over 18, and minors under the age of 13 may not use the Site. We do not knowingly solicit or collect personal information on the Site from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Site, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).

CCPA Categories

The CCPA requires us to provide additional information about the personal information we collect with reference to specific categories of information. For additional information about our sources of personal data, how we use personal data, and how we disclose personal data, refer above. Within the last twelve months, we have not collected any personal information from California residents.

Amendments to this Privacy Policy

We may change this Privacy Policy from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Policy to review any changes. Your continued use of the Sites after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.

This policy is effective from April 21, 2021.

Questions?

You may update your contact information or request deletion of your data by sending us an e-mail at IR@bluetorchcapital.com. Erasure does not include any data we are obliged to keep for legal reasons.