Privacy Policy

We collect, and have collected over the last twelve (12) months, the following information from the following categories of individuals.

Website Visitors

Depending on how you choose to use the Site, we may need you to provide the following information:

• to contact us - name, address, e-mail address, telephone number and other contact details along with any other information you choose to provide;

• to login to our client/investor portal - username and password (if applicable); and

• to subscribe to certain communications - email address and country of residence (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication).

For information on technology and cookies used on the Site, see the section entitled “Use of Technology and Cookies” below.

Office Visitors and Callers

When you visit Oaktree offices or telephone certain Oaktree employees, we may collect certain personal information such as:

• name, organization and other contact details;

• video images of you in certain areas of the buildings in which our offices are located from CCTV footage;

• date and time of your visit to Oaktree offices; and

• voiceprints and telephone numbers during the recording of telephone calls (recording of telephone calls made to or from certain personnel in Oaktree’s London office is required by MiFID II).

Third-Party Service Providers, Vendors and Suppliers

In the process of engaging third-party service providers, vendors and suppliers, Oaktree may collect certain personal information about them and/or about their individual representatives and associates including:

• name, job title, telephone number, email address and other contact details;

• the name of the third-party service provider, vendor or supplier with whom you are associated and its address; and

• information required to process payments, such as a tax I.D. number and wire instruction details.

We may also collect personal information about you from companies who maintain anti-money laundering and terrorism sanction screening and know your customer databases.

Business Contacts and Prospective Clients and Investors (if applicable)

Oaktree may collect personal information about individuals or representatives of organizations with whom Oaktree has a business relationship (or with whom Oaktree seeks to establish a business relationship), as well as prospective clients and investors. Such information may include:

• name, address, telephone number, email address and other contact details;

• organization name and address, job title; and

• investor type, strategy, product and communication preferences (if you choose to receive marketing communications, you will have the option to opt out of receiving such communications at any time by contacting us or unsubscribing via a link in the particular communication).

If you are resident in the People’s Republic of China, some of this information constitutes sensitive personal information under Chinese data protection law (namely, national identification numbers and other identifying numbers, commercial information, salary and certain Internet or other similar network activity information about you through the use of technology, such as cookies and tags, which compile information about your usage of data sites) and, in this context, you understand and are aware that sensitive personal information is personal information that, if disclosed or used illegally, could easily lead to the infringement of a natural person’s human dignity or the endangerment of the safety of his or her person or property.

We do not knowingly process any personal information about anyone under the age of 18.

Sources of Personal Information

We may collect personal information about you that you provide to us directly, as well as from the following additional sources:

• companies who maintain anti-money laundering and terrorism sanction screening and know your customer databases;

• law enforcement, regulatory or government agencies; and

• certain public sources.

Your personal information may be processed, where lawful and relevant under applicable law, on any of the following grounds: (i) in order to comply with our legal and regulatory obligations; (ii) because we need the information for reasons of substantial public interests; (iii) in order to comply with our obligations under contract; (iv) because we have obtained your consent; and/or (v) because we have a legitimate business interest in processing it, including for the following purposes (as applicable):

• to respond to your questions and handle and resolve complaints;

• to perform research with respect to the usage of the Site (applicable to website visitors);

• to personalize and enhance your website experience (applicable to website visitors);

• to maintain the security of our premises, personnel, assets, systems and intellectual property and to manage access to our premises and our disaster recovery procedures (applicable to office visitors);

• to pay you for your services (applicable to third-party service providers, vendors and suppliers);

• in order to comply with our obligations in connection with record-keeping requirements and applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of jurisdictions in which Oaktree conducts business (applicable to office callers, third-party service providers, vendors and suppliers);

• to maintain and provide appropriate management of our relationship with you;

• to exchange mail correspondence or documentation which may involve providing your contact details to couriers and service providers in charge of the delivery service;

• to engage your services in the future (applicable to third-party service providers, vendors, suppliers and business contacts);

• to contact you to set up meetings and/or phone calls between you and your Oaktree business contact(s); and

• to process your subscription requests and to send marketing communications about Oaktree to you (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication) (applicable to website visitors, business contacts and prospective clients and investors).

Where required by applicable law, we will obtain your prior consent before using your personal information for direct marketing purposes and if you do not consent, we will not use your personal information for these purposes.

For information on how we use and process technology and cookies on the Site, see the section entitled “Use of Technology and Cookies” below.

Where it is permitted for Oaktree to rely on its legitimate interests as the ground for processing your personal information, we will carry out an assessment to determine any conflicts between our interests and any rights in relation to the protection of your personal information that you may have.

We may disclose, and have disclosed over the last twelve (12) months, the personal information we collect about you with the following categories of recipients:

• Oaktree affiliated entities;

• third-party service providers, vendors, contractors, and agents of Oaktree as part of normal business operations, including providers:

  • engaged to assist in know your customer and identity verification and anti-money laundering and terrorism screening (applicable to third-party service providers, vendors and suppliers);

  • of accounting, banking and other data processing services;

  • of information technology services and platforms/applications;

  • of courier services or other package delivery services;

  • of call recording and storage services (applicable to office callers);

• third party outsourcing providers;

• building security personnel (applicable to office visitors);

• third parties acting on your behalf such as consultants and other agents;

• governmental authorities and/or law enforcement officials where required;

• financial institutions to wire payments to you (applicable to third-party service providers, vendors and suppliers);

• advisors who provide audit, financial and legal advice to Oaktree;

• group companies for marketing purposes, including sending marketing communications on our behalf, sending their own marketing communications and facilitating joint marketing activities; and

• other parties to a merger, acquisition, reorganization, funding/investment round or similar transaction or proceeding involving Oaktree, or steps in contemplation of such activities

Oaktree may also disclose your personal information to particular parties pursuant to your express consent, to fulfill your instructions, to comply with applicable laws and regulations or to fulfill other applicable requirements.

Personnel employed by service providers generally may have access to your personal information for the purpose of performing duties for Oaktree but are prohibited from using such information for other purposes.

Your personal information may be transferred to or disclosed to entities in countries where data protection laws might not exist or be of a lower standard than in Europe, the United Kingdom, the Cayman Islands, or your home country (if different). This includes the transfer of personal information among Oaktree affiliated entities and the jurisdictions in which they operate. As at the date of this notice, Oaktree has affiliates within the United Kingdom (UK) and the European Economic Area (EEA), as well as affiliates within the United States, Dubai, Hong Kong, China, Japan, Singapore, South Korea, India, Australia and Switzerland. In addition, we may transfer or disclose your personal information with non-affiliated parties located in the same jurisdictions as Oaktree entities as well as other jurisdictions (including India) and information may be stored and processed manually and electronically through global systems and tools for the purposes outlined in this Privacy Policy.

When transferring personal information from outside the EEA, the UK or the Cayman Islands, we seek to comply with European Union and the UK law by using Standard Contractual Clauses or by adopting other means to ensure that adequate safeguards are applied (including, where relevant, transfers to a recipient with an appropriate Privacy Shield certification or appropriate arrangements in compliance with obligations in the Cayman Islands). We also seek to comply with any other data transfer requirements that apply in other countries where we operate, which may include requesting your consent to such transfers. If you would like more information on how we comply with transfer requirements please contact [email protected].

Oaktree maintains established internal policies and procedures as well as physical and electronic safeguards that comply with applicable standards to safeguard access to personal information in our possession from accidental or unlawful destruction, loss, alteration, unauthorized use or disclosure. We endeavor to limit access to personal information about you to those employees, agents and other authorized parties who need to know the information to enable Oaktree to provide products or services to you. Please note that such safeguards, however, do not guarantee that personal information transmitted via the Internet or stored in our systems or is otherwise under Oaktree’s care will be absolutely safe from unauthorized use or intrusion from third parties due to the inherent nature of the Internet.

Protection of Personal Information

The security of your information is important to us. We employ different technical, administrative, and physical security measures designed to protect any personal information you provide through our website or otherwise from unauthorized access or use. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. We will not be responsible or liable for any damages, losses, or causes of action arising out of or in connection with the disclosure of your personal information. You use our Site and send us such information at your own risk.

We will retain your personal information only for as long as we consider necessary in connection with the purposes set out in this Privacy Policy, unless applicable law or regulations require or permit a longer retention period, as described further in our document retention policies. In addition, we may retain your personal information for the duration of any period necessary to establish, exercise, or defend any legal rights.

The rights described in this paragraph are applicable to you only if you reside in a jurisdiction where the provision of such rights are required by the data protection and privacy laws and regulations of the governing regulatory authority. As such, where required by applicable law or regulation, you may ask Oaktree for information about our collection, use, and disclosure of your personal information (specifically the pieces of personal information collected, categories of personal information collected, categories of sources from whom the personal information is collected, the purpose for collecting the personal information, and the categories of third parties with whom we have shred the personal information), to correct it, to delete it or to transfer it to you or another organization. You may also have rights to restrict the processing of your personal information, object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent, but if you do so, it will not affect the lawfulness of any of our processing of your personal information before you withdrew your consent. You may also have the right to lodge a complaint with your data protection supervisory authority. You have rights to object to direct marketing at any time, which you may do so by using any opt-out function given in our emails to you and/or by emailing the relevant contacts noted in this notice. You may also have the right under applicable laws to be free from discrimination for exercising any or some of the rights above, as well as the right to nominate another person to act on your behalf in exercising your data rights in the event of your death or incapacity. You may also have the right to obtain a copy of this notice in another language.

You should also be aware that these rights may be limited (for example, where we are required by law to collect and process your personal information, or where we are permitted by law to deny your request to delete certain information we hold about you). Where we are not able to fulfill a request you make regarding the rights associated with our processing of your personal information because your rights are limited, we will inform you of the reasons why when responding.

Where we need to collect personal information by law, in order to process your instructions or to perform a contract and you do not provide such information when requested, we may not be able to carry out your instructions and/or enter into, perform and/or continue with the contract. In particular where we must collect and process personal information in order to comply with applicable law or enter into and perform services under an agreement with you, if you do not provide the personal information we may not be able to perform the agreement (such as providing services to you or paying you for your services). You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have lawful basis for doing so and we have notified you.

Depending on the type of personal information processing described in this Privacy Policy, we may be operating as a sole or joint controller. If operating as joint controllers, the entities jointly determine the means and purposes of the processing of your personal information. However this has no impact on your rights and how you can exercise them against either of the joint controllers by contacting us as set out below.

Should you have any questions or requests in relation to your rights, please email [email protected]. We will attempt to deal with all requests at the earliest opportunity. We may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth, before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. In addition, if you have unresolved concerns you have the right to complain, where permitted, to competent data protection authorities.

California Residents

We have not, in the past twelve (12) months, and will not, “sell” (or share as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and all implementing regulations thereto (“CCPA”)) personal information collected about you. We do not collect, use, or disclose personal information, including sensitive personal information, for purposes other than those specified in this Privacy Policy. Further, we only use and disclose sensitive personal information for purposes permitted by the CCPA, or otherwise with your consent. In particular, we do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA Regulations. The sources of and purposes for which we collect your personal information are described above.

In the preceding 12 months, we collected and disclosed for a business purpose the following categories of personal information and sensitive personal information to the types of third party recipients described above:

• Identifiers, such as name, email address, telephone number, IP address;

• Personal information categories listed in the California Customer Records statute, such as name, address, telephone number

• Commercial information, such as organization, investor type, product preferences

• Biometric information, such as voiceprints, which we only use for the purpose of responding to your questions, for handling and resolving complaints, for training purposes, or as otherwise permitted by the CCPA

• Internet or other similar network activity, such as information regarding your interaction with the Site, network location, browser characteristics, device characteristics, and operating system

• Professional or employment-related information, such as professional background, job title, employer

Where applicable, if you are a California resident you may have the following rights under the California Consumer Privacy Act of 2018 (the “CCPA”) in relation to “personal information” we have collected about you as defined in the CCPA; these rights are, to the extent required by the CCPA and subject to verification and any applicable exceptions:

• Right to Know/Access: You have the right to request that we disclose certain information to you about our collection and use of certain personal information about you as described below:

  • the specific pieces of personal information collected;

  • the categories of personal information collected;

  • the categories of sources from whom the personal information is collected;

  • the purpose for collecting the personal information; and

  • the categories of third parties with whom we have disclosed the personal information.

• Right to Delete: You have the right to request that we delete the personal information, subject to certain exceptions.

• Right to Correct: You have a right to request that we correct inaccurate personal information maintained about you.

• Right to limit the use and disclosure of sensitive personal information

• Right to opt out of the sale or sharing of your personal information (however, currently we do not “sell” or “share” (as such terms are defined by the CCPA) any of your personal information).

  
  

  California Shine the Light Law

  California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our website users who are California residents to request and obtain from us a list of their personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not disclose any personal information to third parties for their direct marketing purposes.

  
  

  To request your exercise of the rights described above, please submit a request to us by either:

  • Calling us toll-free at 1-877-481-0949;

  • Visiting  ; or

  • Emailing us at  [email protected].

• Right to Non-Discriminatory Treatment: You have the right to be free from discrimination for exercising any of the rights above.

Technology

When you visit our Site or open our emails, we may collect certain information by automated means (such as by cookies, web server logs, web beacons and JavaScript). The information we may collect in this manner includes your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our Sites, and dates and times of website visits. We also may use these and similar technology in emails we send you to collect certain information, such as whether you opened or clicked on links in our email. We, or our appointed service providers, may also collect certain personal information through your interaction with marketing communication, electronic messages (e.g., SMS/MMS text messages, WhatsApp, etc.) or emails we (or others on our behalf) send.

We may use third-party web analytics services on our Site. These service providers help us analyze how visitors use the Site. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers.

The providers of third-party plugins and widgets on our Site, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Site and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.

Cookies

Where permitted, the Company may collect certain information about you through the use of cookies. Cookies are pieces of information, or files, placed on your device’s disk that provide information including how and when pages on the Site are accessed by users. To find out more about cookies please visit www.allaboutcookies.org, or see www.youronlinechoices.eu which contains further information about behavioral advertising and online privacy.

We use the following types of cookies on our Site (note that some cookies may fall into multiple categories):

Test Cookies -  These cookies are simply to test whether or not your browser supports cookies. It stores a simple “True” or “False” value. If True, then the below cookies are applied.

Tracking Cookies  - These cookies are used to track anonymous user movement throughout the site for statistical purposes. For example, it may track the duration of a user’s visit to a certain page or for example, to allow the Company to determine the number of users that visited a given page of the Site, or that read a certain press release.

Required Cookies  - These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for, such as remembering your login details, cannot be provided.

Analytics Cookies  - These cookies remember choices you make, such as the duration of your session. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized (such as the IP address through which you visit the Site) and they cannot track your browsing activity on other websites. The Company uses a Google Analytics cookie to collect this information; you have the right to opt-out of having the Google Analytics cookie placed on your browser.

When visiting the Site, you may receive a pop-up banner informing you of our use of cookies.

You may also be asked to agree to allow us to use particular analytics cookies while you browse the Site. If you receive our cookie consent banner, you may click “Cookie Consent Tool” to see which cookies we have on our Site and choose whether to accept or opt-out of certain cookies while on the Site. Should you choose not to give your consent for us to use some or all of the analytics cookies on our Site, these cookies will not be placed on your browser while you browse the Site.

You may configure your browser to set preferences regarding cookies such that you can have your computer warn you each time a cookie is sent. Note that you may decline placement of cookies if your internet browser permits, though this may impact your experience of using the Site, and certain portions of the Site may be inaccessible to you if you choose to do so. You may at any time delete any cookies from your hard drive. Aggregated data gathered from cookies is used by the Company to help maintain and improve the information provided on this Site for users. The Company may also employ other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We take seriously the protection of your personal information and have contracts in place with these authorized third parties to protect your personal information. We may also use these technical methods in HTML e-mails that we send Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. The Company may collect the information from use of these technical methods in a form that is personally identifiable.

During some Site visits, the Company may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page. The Company may use this information to measure Site activity, to develop ideas for improving the Site and for any other purpose to the extent permitted by applicable law.

Managing Cookies - It is always your choice to decide what cookies are stored on your device and whether you choose to delete them. By accepting cookies that are stored on your computer when you visit our Site, we infer that you have accepted the use of cookies as explained in this Privacy Policy. Please note that while you are free to decline cookies, certain features of this site may be difficult or impossible to use and offerings will not be personalized.

You can manage cookies using various means:

1. Browser Setting. Your browser likely supports a variety of settings to control the cookies that are set on your computer or device and to delete cookies. These settings are typically found under the “Tools”, “Settings”, or “Options” menus. You can also check the “Help” menu of your browser to learn how to change the cookie preferences through your browser settings. Note that you will need to manage the settings for each browser and device you use. Further information from several popular browsers can be found at the following sites:

   • Apple Safari

   • Google Chrome

   • Microsoft Internet Explorer

   • Microsoft Edge

   • Mozilla Firefox

2. Online Tools. Some third parties allow you to manage cookies through online tools such as: Network Advertising Initiative, Digital Advertising Alliance,  Your Online Choices, Adobe Flash, and the Interactive Advertising Bureau (IAB) Europe.

   • In order to opt out of Adobe and Google Analytics Cookies across our websites, visit:

     1. Adobe Analytics

     2. Google Analytics

   • You can opt out of cookies to tailor content or advertising to you by visiting the above links. Note that if you choose to opt out, you won’t necessarily see fewer ads. However, the ads you see may be less relevant to your interests.

3. Browser Extensions. Some third parties have created software that can be added to your web browser to manage their or third-party cookies such as:  Google Analytics and Evidon, Inc.

Our reference to any third party or their software or services is not an endorsement by us of such third party or their products and services and we disclaim any liability for the use or operation of any third-party software or services.

Do Not Track

We do not track visitors of the Site over time and across third party websites to provide targeted advertising and therefore the Site does not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

The Site may contain links to third party websites which, in some cases, may be integrated into, and appear to be part of, the Site. Oaktree encourages you to read the privacy policies of other websites you link to from this Site and disclaims any responsibility for the privacy policies and procedures of any third-party websites that you reach via a hyperlink contained on this Site. Such hyperlinks are provided for your convenience only, and you access them at your own risk.

The Site is not intended for or targeted towards, and we do not knowingly collect personal information via the Site from, children under 13 years of age. If we learn we have collected or received personal information via the Site about a child under 13, we will delete that information.

Oaktree reserves the right in its sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting and we will indicate in the Privacy Policy when it was most recently updated. You should review this Privacy Policy periodically for changes applicable to you. Additionally, note that by accessing this Site subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended.

Please direct any questions regarding Oaktree’s Privacy Policy to  .

Oaktree Capital Management, L.P.
333 South Grand Ave., 28th Floor
Los Angeles, CA 90071