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 on January 1, 2014.

 

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 (www.pwcm.com).

 

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.

 

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 2 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.

 

Where is your personal information kept?

Your personal information is maintained on our networks or on the networks of our service providers accessible at 614 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 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.