Online Privacy Notice

Updated: February 8, 2022

Hudson Structured Capital Management Ltd., and its affiliates and associated entities, (collectively “HSCM” or “We” or “Us” or “Our”) respect your concerns about privacy. This Privacy Notice describes how we process the Personal Data:

  • that we collect on hscm.com;
  • where you are a contact at one of business partners; and
  • through other data collection points or notices that reference this Privacy Notice.

We provide information on the types of Personal Data we collect, how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe in this Privacy Notice the steps we take to protect the security of the information and how you can contact us about our privacy practices. “Personal Data” is any information that relates to, describes, identifies or can be used, directly or indirectly, to identify an individual, such as name, address, date of birth, personal identification numbers, sensitive personal information, and economic information).

HSCM’s Investor Privacy Policy is available here.

Information You Provide

The types of information we collect concerning individuals includes:

  • business and personal contact information (such as name, job title, postal and email addresses, and telephone number); and
  • other information you provide to us (such as information provided by filling in forms).

We may record and monitor details of electronic interactions with us (by email or other forms of electronic communications) as required by applicable rules and regulations.

We may also collect information from other sources, including:

  • if we have a business relationship with the organization that you represent, your representatives or other business contacts may give us information about you such as your contact details or details of your role in the relationship; and
  • information from third party data providers or publicly available sources for anti-money laundering purposes, background checks, and to protect our business and comply with our legal or regulatory obligations.

Information We Collect Automatically

When you visit our website or open our emails, we may collect certain information by automated means (such as by cookies, web server logs, among others). We may collect your IP address, network location, browser characteristics, device characteristics, URLs, information on actions taken on our website, and dates and times of website visits, among others.

Our website may use cookies and some of these cookies may be placed by third parties such as our service providers.

Our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings when gathering information through cookies. We may log information about your interaction with our website.

How We Use Your Information

We may use the information described in this Privacy Notice for the following purposes to:

  • review, develop, promote, and enhance our business, products and services;
  • comply with requirements under applicable rules and regulations, industry standards and our policies and procedures;
  • meet our legal or regulatory responsibilities, including to protect against, identify and prevent fraud, money-laundering, cyber attack, theft of proprietary materials, financial or business crimes, and other unlawful activity;
  • enter into or executing a contract with you, or for carrying out our obligations under such contract;
  • provide our products and services to you;
  • send you materials and other communications;
  • respond to your inquiries;
  • verify your information; and
  • perform data analysis.

We will also use information collected through cookies, web server logs and other automated means.

We may also use the information in other ways for which we provide specific notice at the time of collection.

We will only process your Personal Data as necessary so that we can pursue the purposes described above.

Sharing Your Information

We do not disclose Personal Data we obtain about you through our website unless as indicated in this Privacy Notice. We may share your Personal Data with our affiliates and associated entities. We may share Personal Data with third-party service providers who perform services on our behalf, our financial and transaction counterparties and your agents and representatives. We do not authorize these persons to use or disclose the information except as required for legal or regulatory purposes.

We may disclose information about you (i) if we are required by law or legal purposes, (ii) to law enforcement authorities, regulators or government entities or other competent authorities at their request, or (iii) when we believe disclosure is necessary or appropriate to prevent harm or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We reserve the right to transfer your Personal Data in the event we sell or transfer all or a portion of our business or assets.

We do not sell your Personal Data.

Retention of Your Information

We retain your Personal Data for our legitimate purposes, to perform our contractual obligations, or as is required by applicable rules and regulations.

Links To Other Websites

Our website may provide links to other websites for your information. The websites may operate independently from us and may have their own privacy notices or policies. We are not responsible for their content, the use of their websites, or their privacy.

Transferring Your Information Internationally

We may transfer the Personal Data we collect about you to recipients in countries other than the country in which the information was originally collected. Where you are based in the UK, the EU, or another country which imposes data transfer restrictions outside of its territory,  this includes transfers outside of the UK and the European Economic Area (“EEA“) or that geographical area, including to those countries in which our affiliates, group members, service providers and business partners operate.

Data protection laws in the European Economic Area (EEA) require additional steps for sending Personal Data abroad. These steps help ensure that the same level of protection is applied to Personal Data once it leaves the EEA.

Your California Data Privacy Rights

Subject to verification, in relation to certain categories of Personal Data from certain California residents, such California residents have certain rights.

Right to Access. You may request information from us about the information we collect from and about you over the past 12 months, including:

  • the categories of Personal Data we have collected about you;
  • the categories of sources from which the Personal Data is collected;
  • the business or commercial purpose for collecting your Personal Data; and
  • the categories of third parties with whom we have shared your Personal Data.

Right to Delete. You may request that we delete any Personal Data we have collected from you in certain circumstances (There may be circumstances where HSCM will be legally entitled to retain it.)

Freedom from Discrimination. We will not discriminate against you because you have exercised any of the rights above. In particular, unless permitted by law, if you exercise your rights, we shall not: (i) deny you goods or services, (ii) charge you a different price or rate for goods or services, (iii) provide you a different level or quality of goods or services, or (iv) suggest that you will receive a different price or level of quality of goods or services.

Other California Rights. California law permits consumers who are California residents to request certain information about our disclosure of Personal Data to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and is subject to certain limitations.

Your Data Privacy Rights Under Bermuda Personal Information Protection Act 2016 (PIPA)

Right to Access.  You may request and obtain from us the details of your Personal Data and how it is processed, including the purposes of processing, whether it has been disclosed to third parties, and how long we intend to hold on to the data. Your information will be provided upon written request and we reserve the right to request authentication of identity in the event of such a request.

Right to Withdraw Consent.  Where you have consented for us to use your Personal Data, you have the right to withdraw the consent at any time.

Right to Accuracy.  You may request that we correct your Personal Data that becomes inaccurate.

Right to Restrict Processing.  You may request that we restrict the use of your Personal Data for the purpose of advertising, marketing and public relations or where the use of Personal Data is causing or is likely to cause substantial damage or substantial distress to you or any other individual.

Right to Erase or Destroy. You may request to erase or destroy your Personal Data in certain circumstances (There will be circumstances that we  will be legally entitled to retain your Personal Data.)

Exercising Your Rights

Please see our Investor Privacy Policy here. To the extent provided by the applicable rules and regulations regarding our processing of your information, you may request access to the Personal Data we maintain about you or request that we correct the information by contacting us. Please contact us using the contact information in the “How to Contact Us” section below.

How We Protect Personal Data

We seeks to maintain physical, electronic and procedural safeguards to guard your Personal Data.

Complaints

If you are not satisfied with our response, you have the right to complain to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen.

How To Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you, please email us at privacy@hscm.com or write to us at:

Hudson Structured Capital Management Ltd.

Attn: Compliance

2187 Atlantic Street, 4th Floor

Stamford, Ct 06902

Status of Privacy Notices

This Privacy Notice explains how HSCM process your Personal Data and was last updated in January 2022. We reserve the right to update it from time to time. If we update the notice, we will take steps to inform you of the update by appropriate means.