Privacy Policy

Introduction

At Chatham Financial Corp., we know you care about how your personal information is used and shared, and we take your privacy seriously. We believe it is important for you to understand when, how and why we collect personal data as you use our websites, utilize our products and services, contact us, attend our events or interact with us in any manner.

This Privacy Policy outlines the scope of our relationship with you and your data, and details your rights to control how we use your data. We recognize that one of our fundamental responsibilities is to protect the privacy of the information provided by you and we endeavor to always be good stewards of your data.

Contents

1. Who is Chatham?
2. What information does Chatham collect?
3. How does Chatham use the information we collect?
4. How do we share and disclose information?
5. What happens if you don’t give us your data?
6. How can you opt out or unsubscribe from Chatham marketing emails?
7. How can you review, correct or remove your data?
8. Where is your personal information stored?
9. Who can access your personal information?
10. How does Chatham use cookies?
11. How does Chatham handle the data of children?
12. Does Chatham’s Privacy Policy cover other websites?
13. How can you learn if Chatham has updated our Privacy Policy?
14. How can you contact Chatham regarding your personal data?

1. Who is Chatham?

Chatham Financial (“Chatham”) is an independent financial risk management firm helping clients overcome common yet complex capital markets challenges. Chatham works with over 2,000 clients globally, providing advisory and technology solutions to Corporations, Financial Institutions, Private Equity and Real Estate companies through our offices in the United States, Europe, Asia and Australia. Since its founding in 1991, Chatham has hedged over $5 trillion notional, helping clients understand and use debt and derivatives as a critical piece of their financial strategy. Chatham is a multiple bottom line firm committed to delivering trust and transparency in the capital markets.

The Chatham Financial group of companies are owned by Chatham Financial Corp., which is a United States corporation registered in the Commonwealth of Pennsylvania. As used in this Privacy Notice, Chatham (also “we”, “us” or “our”) includes all affiliated companies of Chatham Financial Corp.

This Website Privacy Notice (“Privacy Notice”) applies to www.chathamfinancial.com and www.chathamdirect.com. Chathamfinancial.com and chathamdirect.com are comprised of various global, regional or practice-specific websites and web pages provided by Chatham, one of its affiliated companies or its subsidiaries (the “Website”).

2. What information does Chatham collect?

Chatham collects behavioral and personal information about our clients, potential clients and partners to continually improve your experience with our Website, products and services. The type of information we collect is based on how you interact with us, and you are always welcome to explore our Website without providing any personal information about yourself, although access to our gated content requires you to provide some basic personal information.

We collect information about our users in the following ways:

A. Information you give us
We will collect any personal information you choose to provide to us, for example, to sign up for an email subscription, request gated content (e.g., download a white paper), register for an event or contact a Chatham representative. If you contact us, we will retain the correspondence and use any relevant information to respond to your inquiry, inform you of our services or keep a record of your request.

Examples of the personal information we collect from you include:

• Name
• Job title
• Company name
• Email address
• Postal address
• Telephone number
• Any other information you choose to provide to us

While the transaction data we collect and store for our clients is not considered to be personal data, it is considered proprietary and confidential, and will be provided the same care, discretion and rigorous protection as with any personal data we collect.

B. Information we collect about you
As is typical of most websites, we use cookies, pixel tags and other similar technologies on our Website to automatically collect certain information about the way you use our services. These tools help us improve the quality, usability and performance of the services we offer to you through aggregate information that does not reveal your specific identity and cannot reasonably be used to identify any particular individual user.

To learn more about the cookies we use, click here.

Examples of the data we automatically collect include:

Device information. We collect specific information about the device you use to access our Website, including device type, model, screen size, operating system, IP address and network carrier.

Usage information. We collect data about each visit to our Website such as your IP address, geographical location, browser type, pages viewed, length of session, time of visit and referring website.

Other information. We collect demographic information, interests information (like market affinity categories) and other information.

C. Information we receive from other sources
In order to enhance our ability to provide relevant services and offers to you, we obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as other third parties.

3. How does Chatham use the information we collect?

We will never sell or rent your personal information to anyone. We handle your information where you have given consent to collect your data, where it is necessary in order for us to perform a contract which we have entered into with you, where a legal or regulatory obligation requires us to do so or where it is in furtherance of our legitimate interests in operating our Website or business.

A. Website administration
We utilize your data to better understand how people use our services so that we can continue to improve the Website to ensure that content is presented in the most effective manner. We collect IP addresses to identify the general locations of our users and block disruptive or improper use of our Website. We also use your personal data to tailor the content and information that we may send or display to you and otherwise personalize your experience while using our Website.

B. Marketing
We collect your personal data to determine the effectiveness of our campaigns. We also use your personal data to market to you, including sending you promotional materials or communications regarding services by us or to send you information which we think may be of interest to you—but only if this in accordance with your marketing preferences. You will always be able to opt-out of such communications at any time by visiting our Email Preference Center.

C. Service Administration
We collect your data to help us manage our relationship with you, including responding to your requests or queries, meeting our obligations under any contracts we have entered into with you, seeking feedback on the services we have provided to you or providing you with information and other services we offer that are similar to those that you have already engaged or inquired about. We also collect your data to provide customer support, including managing your use of services and sending customer updates and administrative communications, such as changes to our terms, conditions and policies. We may also use your data to help us investigate and prevent fraudulent activities, unauthorized access to our services and other illegal activities. We may collect your data for any other purposes for which we will notify any impacted clients.

4. How do we share and disclose information?

We do not rent or sell your personal information to anyone under any circumstances. We will share and disclose information about our clients in the following limited circumstances:

A. Affiliates
We will share your personal information with any Chatham entity for purposes consistent with this Privacy Policy.

B. Service Providers
We will also share your information with vendors, consultants and service providers so they can perform tasks on our behalf. These companies are not permitted to use your information for their own purposes and they only handle your data at our express direction. We use these companies to provide products, services, communication, marketing offers and customer services, among other tasks. We utilize payment processing vendors, web analytics companies such as Google Analytics, CRM service providers, email service providers, third-party site advertising platforms, technical service providers and others.

C. Business Partners
We will also share your data with third-party business partners who sponsor events and other offerings with us. We share personal information with these co-sponsors when you sign up for events or offerings to allow our partners to send you marketing communications and information that may be of interest to you, as permitted under applicable law.

D. Business Transfers
In some cases, we buy or sell assets or businesses. In these types of transactions, personal information is typically one of the business assets that is transferred. We may disclose personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding).

E. Protection of Chatham and Others
We will share your personal information where we have under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any contract or other agreements; or to protect the rights, property or safety of Chatham, our clients or others.

F. Disclosures for National Security or Law Enforcement
Under certain circumstances, we may be required to disclosure your personal information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

G. Google Advertising and Google Analytics
We use the full suite of Google Advertising and Google Analytics features and products, including Remarketing with Google Analytics, Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting.

H. Cookies
We use cookies to identify targets, place advertisements and judge how well our marketing campaigns are reaching relevant audiences. You can opt out of all Google Analytics Advertising Features using NAI’s consumer opt-out, as well as Google Analytics’ opt-out.

5. What happens if you don’t give us your data?

You can enjoy many of the Chatham’s services without providing any personal data. You can still visit our site, but we may not be able to provide certain services or offers to you without your personal data. Some personal data is necessary so that Chatham can supply you with the services you have requested, and to enable authentication for authorized system users.

6. How can you opt out or unsubscribe from Chatham marketing emails?

You can opt out of receiving any marketing emails by visiting our Email Preference Center and unsubscribing. You can also unsubscribe by clicking on the unsubscribe link at the bottom of any marketing emails you receive from us. While you may opt out of receiving any marketing emails from us, the request would not apply to any business emails from us, including those dealing with administrative or transactional matters.

7. How can you review, correct or remove your personal data?

If you are located in the European Union, then you have additional rights in regards to your personal data. If you are an individual in the EU and we are collecting your personal data, then you have several rights with respect to that information:

• To learn whether we are collecting your personal information;
• To receive a copy of your personal information;
• To request that we correct any errors, outdated information or omissions in your personal information;
• To request that we no longer use your personal data to contact you for marketing purposes;
• To request that we provide the personal information you have provided to us to a third party; and
• To request that we delete your personal information.

We will require you to confirm your identity with approved identification when you contact us to exercise your rights.

Please note that while we will strive to meet your request regarding your rights to your personal data, there will be instances where local laws and regulations will require us to maintain your records despite your request.

To exercise any of your rights please complete the form in our Data Request Center or contact us at privacy@chathamfinancial.com.

8. Where is your personal information stored?

Your personal data is stored by Chatham on its servers located in the United States and the United Kingdom and on the servers of the cloud-based database management services Chatham engages. These third parties do not use or have access to your personal data for any other purpose than cloud storage and retrieval. Chatham retains data for the duration of the client’s business relationship with Chatham.

Chatham is a global company with affiliates and third-party providers located in the United States, European Union, Australia and Singapore. Your personal data may be accessed from, stored or processed in these countries or any other country where Chatham or its third-party providers are located. Your personal data may be accessed from, stored or processed in a jurisdiction that does not have privacy laws that provide equivalent protections to those in your home country. Please be assured that we will protect all personal data under our control in accordance with this Privacy Policy and take reasonable steps to ensure that as good stewards we protect your data using industry best data security practices as identified by reputable sources, including NIST and ISO.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to help prevent unauthorized access.

To ensure the security of your data, Chatham and its affiliates adhere to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce with respect to personal information that is transferred from the European Economic Area and Switzerland to the United States within the scope of Chatham’s Privacy Shield certification.

We retain personal information about you for the period necessary to fulfil the purposes outlined in this Privacy Notice or until you request that your personal information be removed from our records, unless a longer or shorter retention period is required or permitted by applicable law.

9. Who can access your personal information?

To help protect the privacy of data and personal information you provide to us, we maintain physical, technical and administrative safeguards. We update and test the security of our application and infrastructure on an ongoing basis. We restrict access to your personal data to those employees who need to know that information in order to perform their responsibilities. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

10. How does Chatham use cookies?

This Website uses cookies to improve the user experience and ensure that the website is functioning effectively. In order to provide you with a more personalized and responsive service, we need to remember and store information about how you use this Website. This is done using small text files called cookies.

Cookies are designed to contain a small amount of information specific to a particular user and website. Cookies are stored on the web server as well as a user’s device and allows the server to deliver a website experience tailored to a particular user’s preferences.

Whenever you use this Website, information may be collected through the use of cookies and other technologies. We use cookies to evaluate your use of the website, compile statistical reports on activity, identify targets, place advertisements and judge how well our marketing campaigns are reaching relevant audiences.

You are able to opt out of cookies on our Website by category, except for those that are deemed strictly necessary, by clicking on the link below:

Cookie Settings

Do Not Track or DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. This website does not currently respond to DNT requests.

11. How does Chatham handle the data of children?

This Website is not designed for or intentionally targeted at children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.

12. Does Chatham’s Privacy Policy cover other websites?

Our Website may, from time to time, contain links to other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to those websites. Our link does not equal an endorsement of those sites, their owners or their practices. This Website uses interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to share information from this Website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your personal data.

13. How can you learn if Chatham has updated our Privacy Policy?

Chatham may modify this Privacy Notice from time to time to reflect our current privacy practices. When we make changes to this Privacy Notice, we will revise the updated date at the bottom of this page. We encourage you to periodically review this Privacy Notice to keep informed about how Chatham is protecting your information.

14. How can you contact Chatham regarding your personal data?

Chatham is committed to protecting the privacy of your personal data. If you have questions, comments or requests relating to our administration of your personal data, please contact us at privacy@chathamfinancial.com. Questions, comments and requests may also be addressed to our data controller:

Maya Garza
Chatham Financial Corp.
235 Whitehorse Lane
Kennett Square
PA 19348
USA
Telephone: 610 925 3120
Fax: 610 925 3125
Email: privacy@chathamfinancial.com

Or to the data controller’s EU representative:

Chatham Financial Europe, Ltd
Burdett House, 4th Floor
15-16 Buckingham St.
London WC2N 6DU
United Kingdom
Telephone: +44 (0) 20 7766 5700
Fax: +44 (0) 20 7766 5701
Email: privacy@chathamfinancial.com

If you are located in the European Economic Area, then you have the right to lodge a complaint with your local data protection authority or the Information Commissioner’s Office (ICO) in the United Kingdom, which is Chatham’s lead supervisory authority in the EU. Concerns may be reported on the ICO’s website, by emailing the ICO or by contacting the ICO’s head office:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113

Chatham has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to BBB EU Privacy Shield, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the BBB EU Privacy Shield website for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Last Updated: 27 June 2018