Privacy Policy

The privacy of our investors is very important to us. Pentwater Capital Management LP (“PCM”) is committed to protecting your privacy and maintaining confidentiality of your personal information. This Policy may be updated from time to time without notice. This Privacy Policy was last modified in January, 2020. The following policy pertains to PCM and each of the private funds that it manages. 

Financial companies choose how they share your personal information. Federal law gives our clients 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. Please read this notice carefully to understand what we do.


What is Personal Information?

The term “personal information” refers to any information that specifically identifies you, including information such as your home address, telephone numbers, social security number, birth date, assets and/or income information, employment history and credit history.


How do we collect your Personal Information?

We collect and maintain personal information about you when you become an investor with us. We collect your personal information directly from you in order to provide you with services in connection with your investment, to meet legal and regulatory requirements and for any other purposes to which you consent.  Your personal information may be collected from a variety of sources, including:

(a) subscription agreements, applications, questionnaires or other forms that you submit to us or contracts that you enter into with us;

(b) your transactions with us;

(c) meetings and telephone conversations with you; and

(d) our website (

How do we use your Personal Information?

We collect and maintain your personal information in order to give you the best possible service and allow us to establish your identity, protect us from error and fraud, comply with the law and assess your eligibility for our products. In addition, we may use your personal information for:

(a) verifying  and correcting your personal information; and

(b) providing you with confirmations, tax receipts and financial statements in order to service and administer your account. 

We do not disclose nonpublic personal information about our clients or former clients to third parties other than as described below.


Who do we share your Personal Information with?

We may transfer your personal information, when necessary, to our third party service providers and to our agents in connection with the services we provide related to your account, but they will not share this information with others. Such information is only used for the purposes identified above. PCM will use contractual or other means to provide a comparable level of protection while the information is being handled by a third party service provider or agent. We may also be required by law to disclose information to government regulatory authorities. 

We do not sell, lease, barter or otherwise deal with your personal information with third parties. 

PCM may be involved in the sale, transfer or reorganization of some or all of its business at some time in the future. As part of that sale, transfer or reorganization, PCM may disclose your personal information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy.


How do we obtain your consent to the collection, use and disclosure of your personal information?

By signing a subscription form and/or continuing to do business with us, you are consenting to the collection, use and disclosure of your personal information for the purposes identified in this Privacy Policy.  PCM will not, as a condition of the supply of products or services, require you to consent to the collection, use or disclosure of your personal information beyond that required to fulfill those purposes.


How do we safeguard personal information?

We carefully safeguard your personal information and, to that end, restrict access to personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. PCM’s employees are responsible for ensuring the confidentiality of all personal information they may access. Annually, each of PCM’s employees is required to sign a code of conduct, which contains policies on the protection of personal information.

We also adhere to the General Data Protection Regulation (GDPR) principles that apply to the collection and protection of personal data of indiviuals residing within the European Union (EU) as well as the data protection requirements under the Data Protection Law, 2017 of the Cayman Islands (the “DPL”).


Where is your personal information kept?

Your personal information is maintained on our networks or on the networks of our service providers accessible at614 Davis Street, Evanston, IL, 60201. Your information may also be stored on a secure off-site storage facility.


How you can access your personal information?

You may request access to your personal information by writing to 614 Davis Street, Evanston, IL, 60201. We will respond to your written request promptly. PCM may be unable to provide you with full access to your personal information if we are prohibited by law or regulatory reasons or it has been destroyed. PCM will provide you with an explanation, if we are unable to fulfill your access request.


Who do you contact if you have any questions or concerns?

If you have any questions or concerns with respect to this Privacy Policy, please contact our Chief Privacy Officer by phone 312.589.6400 or by mail, Attention Chief Privacy Officer, Pentwater Capital Management LP, 614 Davis Street, Evanston, IL, 60201.

CCPA Privacy Notice

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Purpose and Scope

Certain third-party services used by Pentwater Capital Management LP (“PCM”), including but not limited to software or products offered by Bloomberg Professional Services and/or Bloomberg Finance L.P., such as the Bloomberg Terminal, may use Biometric Data (as defined below) for identity verification and authentication purposes. To the extent that PCM collects or is in possession of any Biometric Data, this Biometric Data Policy (the “Policy”) sets forth PCM’s policy for the collection, use, safeguarding, storage, retention and destruction of Biometric Data.

It is PCM’s policy to ensure that employee data collected by or in possession of PCM is used and handled in accordance with the Illinois Biometric Information privacy Act (“BIPA”) and all other applicable laws.


Biometric Identifier means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers do not include donated organs, tissues, or parts as defined in the Illinois Anatomical Gift Act or blood or serum stored on behalf of recipients or potential recipients of living or cadaveric transplants and obtained or stored by a federally designated organ procurement agency. Biometric identifiers do not include biological materials regulated under the Genetic Information Privacy Act. Biometric identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996. Biometric identifiers do not include an X-ray, roentgen process, computed tomography, MRI, PET scan, mammography, or other image or film of the human anatomy used to diagnose, prognose, or treat an illness or other medical condition or to further validate scientific testing or screening.

Biometric Information means any information, regardless of how it is captured, converted, stored, or shared, based on an individuals’ Biometric Identifier used to identify any individual. Biometric Information does not include information derived from items or procedures excluded under the definition of Biometric Identifiers.

Biometric Data means both or either of Biometric Identifier or Biometric Information.

Purpose of Collection

PCM or one of the third-party services it uses may collect, possess, store, and/or use employee Biometric Data for identity verification and authentication purposes.


To the extent PCM has access to any Biometric Data, PCM will not disclose, re-disclose or otherwise disseminate any Biometric Data unless:

  • The employee consents to the disclosure or dissemination;
  • Disclosure or re-disclosure completes a financial transaction requested or authorized by the employee or contractor;
  • Disclosure or re-disclosure is required by state or federal law or municipal ordinance; or
  • Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

PCM will not knowingly sell, lease, trade, or otherwise profit from an employee’s Biometric Data.

Retention Schedule

PCM will retain employee Biometric Data, if it is retained at all, until the first of the following options occurs:

  • The initial purpose for collecting or obtaining the Biometric Data has been satisfied, such as the termination of the employee’s employment with PCM or PCM is no longer using Biometric Data for the purposes described above; or
  • Within 3 years of the employee’s last interaction with PCM.

Data Storage

To the extent PCM collects or possess Biometric Data, it shall maintain reasonable physical, administrative and technical safeguards to store, transmit, and protect from disclosure any such Biometric Data collected, stored or retained. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same or more protective than the manner PCM transmits, stores, and protect from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual or an individual’s account or property, such as genetic markers, genetic testing confirmation, account numbers, PINs, driver’s license numbers and social security numbers.

Policy Enforcement

The Chief Compliance Officer of PCM is responsible for the enforcement and administration of this Policy. If you have any questions regarding this policy or if you have questions that are not addressed in this policy, please contact a compliance team member. A copy of this policy is publicly available at

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.