Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Glazer Capital, LLC (“Glazer Capital” or the “Investment Manager”) on behalf of each investment account or pooled investment vehicle advised or managed by the Investment Manager (each a “Fund”, and together with the Investment Manager, “we” or “us”), and sets forth the policies of the Investment Manager and the Funds for the collection, use, storage, sharing and disclosure (collectively, “processing”) and the protection of personal information, including, but not limited to, personal information collected through glazercapital.com (the “Site”). This Privacy Notice is being provided in accordance with the requirements of data privacy laws applicable to the Investment Manager and the Funds (“Data Protection Law”).
If you are a California resident, please review our California Privacy Notice below.
1. The Types of Personal Information We May Collect and Use
The categories of personal information we collect from you may include names, residential or business addresses or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds details or other sensitive information, such as certain special categories of personal information (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Law.
2. How We Collect Personal Information
We may collect your personal information through: (i) information provided directly to us by you via your communications with us, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us; by observing your actions on our Site; and (iii) recording and monitoring of telephone conversations and electronic communications with you as described below.
We also may receive personal information about you from third parties or other sources, such as our affiliates not under the Glazer Capital brand, the administrator of our Funds, banks, brokers, auditors, law firms, consultants, employment agencies, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.
3. How We Use Your Personal Information
We may process your personal information for the purposes of administering the relationship between you and us (including communications and reporting), direct marketing of our products and services, and for business purposes, including: performing services (for us or our service provider or contractor) such as account servicing, processing orders and payments, and analytics; auditing related to our interactions with you; monitoring and analyzing our activities; internal operations; monitoring and improving the Site; providing account maintenance, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention and investigation; tax reporting; sanctions compliance; preventing, investigating and detecting security incidents; responding to requests for information from law enforcement agencies or supervisory authorities); and short-term, transient use, such that the personal information is not disclosed to another third party and is not used to build a profile about you.
Your personal information will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so.
Where there is suspicion of unlawful activity, failure to provide personal information may result in the submission of a report to the relevant law enforcement agency or supervisory authority.
4. How We May Share Your Personal Information
We may disclose personal information to our affiliates, service providers or other third parties, including but not limited to, administrators, banks, brokers, auditors, law firms, consultants, credit agencies, business partners, for our everyday business purposes, such as administration of our business, record-keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, facilitating transactions and maintaining your account(s) and compliance with applicable legal and regulatory requirements, and in connection with a potential business transfer. We may share your personal information with regulatory, tax or law enforcement authorities to comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. We will also release personal information about you if you, or your agents, authorize us to do so in connection with services we provide to you. We may share your personal information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at (212) 808-7304 or email@example.com or glazercapital.com/contact. When you are no longer our customer or otherwise a user of our services, we may continue to share your personal information with our affiliates for such purposes. We may also disclose information about your experiences with us to our affiliates for their everyday business purposes. We do not permit non-affiliates with whom we share personal information to market their own services to you.
5. Retention Periods and Security Measures
We will not retain personal information for longer than is necessary in relation to the purpose for which it is collected, subject to applicable Data Protection Law. If you are an investor in a Fund, personal information will be retained for the duration of your investment in the Fund and for a minimum period of five to seven years after a redemption or withdrawal, as applicable, of your investment or liquidation of the Fund. We may retain personal information for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal information has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.
6. International Transfers
Due to the international nature of our business, your personal information may be transferred to countries outside the United Kingdom and the European Economic Area (“Third Countries”), such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation (Regulation (EU) 2016/679), including equivalent legislation in effect in the United Kingdom (“GDPR”) or the Data Protection (Bailwick of Guernsey) Law 2017 (“Guernsey DPL”). In such cases, we will process personal information (or procure that it be processed) in the Third Countries in accordance with the requirements of the GDPR and Guernsey DPL, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal information on our behalf in such Third Countries. We may also be required to transfer your personal information to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.
7. Your Rights Under Data Protection Law
You may have certain rights under the GDPR and Guernsey DPL in relation to our processing of your personal information and any processing carried out on your behalf. These rights include: (i) the right to request access to your personal information; (ii) the right to request rectification of your personal information; (iii) the right to request erasure of your personal information (the “right to be forgotten”); (iv) the right to restrict our processing or use of your personal information; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities); (vi) where relevant, the right to request the portability of the data; (vii) if your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. Please note that the right to be forgotten that applies in certain circumstances under the GDPR and Guernsey DPL is not likely to be available in respect of the personal information we hold, given the purpose for which we collect such data, as described above.
You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.
We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customize your experience on this Site and to monitor use of this Site. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this Site. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org.
9. Who to Contact About This Privacy Notice
Please contact Glazer Capital by telephone at (212) 808-7304, by email at firstname.lastname@example.org or by writing to 250 West 55th Street, Suite 30A, New York, NY 10019 for any questions about this Privacy Notice or requests with regards to our handling of personal information.
Privacy Notice For California Consumers
Last updated February 2023
This notice contains disclosures required 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”). Consumers with disabilities may access this notice by contacting Glazer Capital by telephone at (212) 808-7304, by email at email@example.com or by writing to 250 West 55th Street, Suite 30A, New York, NY 10019 to request a copy of this notice in an alternative format, such as a .pdf version of this notice that is compatible with character recognition software.
Information We Collect. In the past 12 months, we have collected and shared for a business purpose the following categories of personal information about California consumers:
|Category||Examples||Shared for Business Purpose|
|Identifiers||A real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, tax identifier or passport number, or other similar personal identifiers.||YES|
|Other personal information categories, as listed in the California Customer Records Statute||A signature, telephone number, employment, bank account number, information about assets or net worth, information on investment activities or any other financial information.||YES|
|Protected classification characteristics under California or federal law||Age (40 years or older), race, citizenship, marital status, sex, veteran or military status.||YES|
|Commercial information||Account activity, records of products or services purchased, obtained, or considered, or other purchasing histories.||YES|
|Professional or employment related-history||Current or past job history||YES|
|Inferences Drawn from other personal information||Profile reflecting a person’s preferences, characteristics and interests.||YES|
|Sensitive personal information||A consumer’s SS, driver’s license, state ID card, or passport number; contents of mail, email, and text messages.||YES|
Personal Information does not include information that is publicly available, de-identified/ aggregated, or subject to HIPAA or GLBA.
We collect Personal Information from the sources provided in Section 2 of the general Privacy Notice above.
We do not knowingly collect, solicit or sell Personal Information from anyone under the age of 16 without the prior consent of a parent or guardian.
Use of Personal Information. We may use the Personal Information we collect as provided in Section 3 of the general Privacy Notice above.
Sharing Personal Information. We may disclose Personal Information as provided in Section 4 of the general Privacy Notice above.
In the past 12 months, we have not sold Personal Information to third parties, and we have shared the categories of personal information we collect only as set forth above.
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:
- The right to request: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our business or commercial purposes for collecting, selling or sharing your Personal Information; (d) the categories of Personal Information disclosed for a business purpose and the categories of persons to whom it was disclosed; (e) the categories of your Personal Information (if any) that we have either sold, shared, or disclosed.
- For certain categories of Personal Information, the right to request a list of what we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties.
- The right to request that we delete your Personal Information, subject to certain exceptions.
- The right to opt out of our sale(s) (if any) of your Personal Information.
- The right to request we correct any inaccurate Personal Information maintained about you.
- The right to limit our use of your sensitive personal information to only use that is necessary to perform the services expected or provide the goods reasonably expected.
- The right not to receive discriminatory treatment for exercising your CPRA rights.
You may submit requests relating to your CPRA rights to us via:
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 representative and (2) sufficient detail that allows us to properly evaluate and respond to it.
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.
Please contact Glazer Capital by telephone at (212) 808-7304, by email at firstname.lastname@example.org or by writing to 250 West 55th Street, Suite 30A, New York, NY 10019 for any questions about this Notice or requests with regards to our handling of personal information.