Eurocastle Investment Limited (“Eurocastle”), via its Manager, FIG LLC and its affiliates (collectively “Fortress”), maintains and operates this website. This Online Privacy Statement is meant to help you understand what information we collect when you interact with this website, and how we use and protect such information. This Online Privacy Statement concerns only this website, and does not concern any website to which this site may link. Similarly, it does not concern your interaction with Eurocastle or Fortress in the offline world.
Please read this Online Privacy Statement carefully. In the event that you have any questions or concerns about the guidelines set forth in this Online Privacy Statement, please contact us as set out at the end of this Statement.
We may provide links on our site to third parties. In addition, third parties may also provide links to our site. Should you choose to visit these third party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your personal information. We do not accept, and do disclaim, any responsibility for the privacy policies and information protection practices of any third party website (whether or not such site is linked on or to our site). These links are provided to you for convenience purposes only, and you access them at your own risk.
A. What Information Do We Collect About You
When You Visit and Browse our Website
We collect general information about the devices you use to access our website and services (such as make, model, operating system, IP address, and browser type), and information about your online behavior. By collecting this information, we learn how to best tailor our website for our current and future visitors. To collect this information, we use technical methods such as cookies, as further explained below.
Cookies:
Cookies are pieces of information that a website sends to your computer while you are viewing the website. Eurocastle uses cookies for a variety of purposes. For instance, when you return to our website after logging in, cookies provide information to the site so that the site will remember who you are. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this through your web browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you will not have access to many features that may make your browsing of our website smoother, like the features mentioned above, and some of our services may not function properly.
When You Register For an Account
If this website provides a registration option and you choose to register for an account, we will collect the personal information you provide in order to complete your registration. You may choose to provide us with this information, however there is no obligation to do so, and your choice will not affect your ability to use our website.
When You Contact Us or When We Contact You
We collect personal information you provide about yourself anytime you contact us about our website or services (for example, your name and contact details). You can choose not to provide this information, but then you might not be able to send us requests via our website. We may also use technical methods in HTML e-mails that we send visitors to our website to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails.
B. How Do We Use Your Personal Information
Eurocastle processes your personal information for legitimate business purposes, to fulfil our legal and contractual obligations to you, and/or after consent is obtained from you.
Use in Connection with Normal Business Operations
We may use or share some of the personal information we collect about you with our affiliates or third-party entities as part of our normal business operations (such as processing your requests for forms or other literature or information, transactions, service, or to prepare investor disclosure materials), or to send you administrative communications either about your interactions with us or about features of our website, including any future changes to this Online Privacy Statement.
Other Uses
We may also share your personal information with a select group of third-party service providers that carry out certain functions on our behalf. Sometimes we hire companies to help deliver products or services, like a shipping company that delivers a package. In that instance, there is a need to share your information with that company. Sometimes we also work with other companies who help either gather your information or communicate with you. These companies are allowed to gather, receive, and use your information only for the purposes described in this Online Privacy Statement or as required by law.
We may also disclose your personal information when (a) such disclosure is required by law, or (b) will help to: enforce our Terms of Use; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of our websites, databases, and/or third parties, including the safety and security of tangible and/or intangible property that belongs to us or to third parties.
C. Transferring Your Personal Information to Other Countries
The entities with which we may share your personal information may be located outside of the European Economic Area ("EEA"). We have put in place safeguards reasonable designed to make sure your personal information remains adequately protected when transferred.
D. How Long Do We Keep Your Personal Information
We will retain your personal information for the amount of time necessary to accomplish the purpose for which it was collected. We will also retain personal information that could be relevant to legal proceedings or must otherwise be retained under law or regulations for longer periods.
E. How Do We Protect Your Personal Information
We have implemented technical, administrative, and physical security measures to protect your personal information from unauthorized access and improper use. We review our security procedures in order to consider appropriate new technology and methods on an ongoing basis. Except as otherwise required by law, only authorized persons will be allowed to view your personal information. Eurocastle and Fortress employees receive training about the importance of confidentiality and maintaining the privacy and security of your information.
Your Rights under the EU General Data Protection Regulation
You have the right (subject to certain limitations) to confirm that Eurocastle is processing your personal information, to access the personal information we keep about you, to restrict or object to the processing of your personal information, and to rectify, erase, and port your personal information.
If you wish to exercise any of these rights, please contact us as set out below.
Your Right of Access:
You have the right to obtain:
- Confirmation that we process your personal information; and
- Access to the personal information we have about you.
Your Right to Rectification:
You have the right to have inaccurate personal information rectified.
Your Right to Erasure:
You have the right to have your personal information erased if:
- Your personal information is no longer necessary for the purpose which we originally collected or processed it for;
- We are only relying on your consent to process your personal information, and you decide to withdraw your consent; and
- You object to the processing of your personal information, and we have no overriding legitimate interest or other valid basis to continue the processing of your personal information.
Your Right to Restrict Processing:
As an alternative to requesting the erasure of your personal information, you have the right to limit the way we use your personal information in certain circumstances:
- You contested the accuracy of your personal information and we are verifying the accuracy of such information;
- We have unlawfully processed your personal information and you oppose erasure and request restriction instead;
- We no longer need your personal information but you need us to keep it in order to establish, exercise or defend a legal claim; or
- You have objected to us processing your personal information, and we are considering whether we have legitimate grounds to continue processing your personal information.
Your Right to Object to Processing:
You have the right to object to certain types of processing of your personal information, namely:
- Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)
- Direct marketing (including profiling); and
- Processing for purposes of scientific/historical research and statistics.
Your Right to Data Portability:
Under limited circumstances, you have the right to obtain from us and reuse your personal information for your own purposes. This right allows you to move, copy or transfer your personal information easily, without hindrance to usability. If you request it, we may transmit your personal information directly to another organization if this is technically feasible.
Questions, Concerns and Complaints
Should you wish to make a complaint about our use of your personal information, you may contact Eurocastle as set out below.
You also have the right to lodge a complaint with the appropriate regulatory body/supervisory authority, in particular in the country where you reside, place of work or of an alleged infringement of the law.
How To Contact Us
If you have any questions concerning our privacy practices described in this Notice please contact us a DSR@fortress.com.
Or Write to us at:
Data Subject Rights
Fortress Investment Group
1345 Avenue of the Americas
New York, NY 10105
Effective from May 25, 2018