PRIVACY AND COOKIES
Last Updated: January 2023
1. Personal Information We Collect from You
For purposes of this Privacy Notice, “Personal Data” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.
To obtain access to the Sites and to receive certain Internet Services, you may be required to login and provide certain Personal Data, including:
- Identifiers: such as a real name, alias, postal address, email address, account name, social security number, driver’s license number, passport number, and other similar identifiers.
- Characteristics of protected classification under California or federal law: such as information revealing race, age, religion, sex or gender, sexual orientation, disability status, and marital status.
- Professional or employment-related information: such as job title, professional memberships and affiliations.
- Internet or other electronic network activity information: such as information regarding your interaction with and use of our systems.
- Geolocation data.
- Personal information categories listed in Cal. Civ. Code § 1798.80(e): such as identifiers and examples listed above, as well as bank account numbers, and brokerage account information.
Some of the Personal Data we collect is also considered “Sensitive Personal Information” under the CCPA. That Sensitive Personal Information may include:
- Social security, driver’s license, or passport numbers
- Information about racial or ethnic origin, sex, sexual orientation, or union membership
- Account login and password
We use Sensitive Personal Information for lawful purposes in compliance with the CCPA. We do not use Sensitive Personal Information to infer characteristics about you.
We may combine Usage Data with other Personal Data in a manner that enables us to trace Usage Data to an individual user.
Some web browsers may have “do not track” settings. The Sites do not currently respond to “do not track” settings.
3. How We Use Personal Data
We use Personal Data to fulfill your requests for Internet Services, as well as other products and services (together, the “Services”), to monitor and improve our Services, and to contact you from time to time about us and the Services.
4. Our Information Sharing Practices
Third-Party Service Providers. We employ other companies and individuals to perform functions on our behalf, such as for analyzing data and providing certain of the Internet Services. These third-party service providers have access to personal information needed to perform their functions, but we require that they not use personal information for other purposes. Personal Data is not shared with any unaffiliated third-parties for their marketing purposes.
We do not sell User Information.
5. Retention of Personal Information
We will only retain your Personal Data for as long as necessary to provide services to you fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.
6. Modifying and Deleting Your Personal Data
We have controls in place designed to help us ensure that the information we have is relevant, accurate, and appropriate for the purposes used. If you believe that any data about you is inaccurate, please let us know by contacting firstname.lastname@example.org. Please note that any Personal Data that we have copied may remain in back-up storage for some period of time after your request, and that if you delete certain information you may not be able to use our services in the future without re-submitting such information. Also, please note that we will maintain Personal Data in our database whenever we are required to do so by law or regulation.
7. Your Rights
Individuals in Andorra, Argentina, Australia, California, Canada, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their Personal Data; (ii) restrict or object to the processing of their Personal Data; and (iii) obtain a copy of their Personal Data in a portable format. Individuals may also have the right to lodge a complaint about the processing of Personal Data with a data protection authority. If you wish to exercise any of these rights please email email@example.com or call 1-877-222-4117.
If you make a request related to Personal Data about you, you may be required to supply a valid means of identification as a security precaution. We will process your request within the time provided by applicable law.
The California Consumer Privacy Act (“CCPA”) prohibits covered businesses from discriminating against you for exercising your CCPA rights.
8. SEC Regulations S-P, S-AM and the Gramm-Leach-Bliley Act – PRIVACY NOTICES
Canyon collects nonpublic personal information about current and prospective investors from the following sources: (i) information we receive from current and prospective investors on investment advisory agreements or subscription documents and related forms (for example, name, address, social security number, birth date, assets, income, investment experience); (ii) information about investor’s transactions with Canyon; and (iii) the Internet Services.
We restrict access of current, former and prospective investors’ nonpublic personal information to our affiliates and their personnel, counsel, regulators, auditors, administrators, counterparties, and service providers who need to know that information in order to (i) ensure compliance with applicable laws and regulations, (ii) administer your account and provide products or services to Canyon and/or its investors, or (iii) as otherwise required by law. Canyon maintains physical, electronic and procedural controls in keeping with federal standards to safeguard the nonpublic personal information about current, former and prospective investors that is in our possession.
Nonpublic personal information is not shared with third-parties for their marketing purposes.
If, at any time in the future, it is necessary to disclose any of a client’s personal information in a way that is inconsistent with this policy, Canyon will give advance notice of the proposed change so that its clients will have the opportunity to “opt out” of such disclosure.
We have implemented reasonable measures to help protect your User Information from loss, misuse or unauthorized access or disclosure. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your User Information, we cannot guarantee its security.
The Sites may contain links to other websites. We are not responsible for the privacy practices of any such other website (whether accessed through an advertisement, service or content link) and urge you to review such practices prior to submitting any information to such websites.
12. International Data Transfers