Client Data Privacy Shield Notice

Please be advised that Cortland Capital Market Services LLC (“Cortland”) may collect and transfer certain personal data outside of the EU to the United States for processing and storage as part of its provision of services to clients of its subsidiaries located in the EU, particularly for the purpose of performing “know your customer” identity verification and “anti-money laundering” compliance reviews. In connection with same, Cortland provides said information to third party vendors which provide identity verification web-based programs. These vendors are subject to confidentiality and data security obligations in their access of said personal data. These vendors would be responsible to Cortland for any misuse or unauthorized access of this personal data. Cortland has in place data security and recovery systems and policies that are at or higher than industry standard for the protection of such personal data. Your personal data may also be disclosed in response to lawful requests by public authorities or by court order, which enforcement authority has jurisdiction over Cortland’s compliance with the Framework.
 
Cortland is committed to complying with the EU-U.S. Privacy Shield Framework (the “Framework”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Cortland has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
 
In compliance with the Privacy Shield Principles, Cortland commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Jessica Mead, General Counsel of Cortland, at legal@cortlandglobal.com. Cortland has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit http://go.adr.org/privacyshield.html for more information or to file a complaint. There are pre-arbitration requirements you must meet. For more information on same, visit privacyshield.gov. The services of the American Arbitration Association are provided at no cost to you.