Last updated: March 10, 2021

Aetos Capital, Inc. and its affiliates (collectively, “Aetos Capital” “us,” our” or “we”) are committed to keeping your personal information safe. This Privacy Statement describes how we use personal information, with whom we may share it, how we keep it secure, and your rights relating to your personal information.

This Privacy Statement applies to Aetos Capital users and customers (“you”) who use or interact with our website, or with any product or service from any Aetos Capital business. This includes customers and site visitors.

How we collect your information

Aetos Capital collects your personal information through your interactions with us or from third party sources. Specifically, we collect your information when:

• You interact with us, including when you ask us for support or otherwise contact us.

• You visit our site. If you would like more information about how we use cookies to collect personal information, please visit our Cookie Policy.

COLLECTION OF PERSONAL INFORMATION

The categories below describe the personal information we collect about you and the sources from which we collect those categories of personal information.

How we use personal information

We use personal information as permitted under applicable law, as you request or consent to, and for the following purposes:

• Providing our products and services, including to verify your identity, personalize the content you receive, create and administer your account, and sending you important account, product or service update information;

• Communicating with you (and, where required by applicable law, we will obtain your explicit consent to do so);

• When required by applicable law, or for security purposes, to verify your identity;

• Establishing and manage our business relationships;

• Managing career opportunities at Aetos Capital, including for recruitment purposes, candidate screening and evaluation, and employee onboarding;

• Providing customer service, as well as technical and product support;

• Conducting analysis and research; and developing, improving, testing, and enhancing the features and functions of our website, products and services;

• Monitoring, maintaining, administering and improving website performance;

• Protecting your, our, or third parties’ networks, systems, property, or physical safety;

• Complying with requests from regulatory agencies, law enforcement, and other public and government authorities, as well as with relevant industry standards and policies;

• Enforcing our contracts, terms, and conditions or otherwise exercising our legal rights; defending ourselves from claims; and complying with laws and regulations that apply to us or third parties with whom we work;

• Where permissible under applicable laws and regulations, generating anonymous, aggregated data (such that it does not identify any individual users) that we may use for research and product development. We may publish or otherwise provide the results of this anonymized data in our products and services;

• Participate in any merger, acquisition, or other corporate transaction;

• Meet our or third parties’ audit and compliance requirements; and

• For any other purposes that we may specifically disclose at the time you provide or we collect your information.

In compliance with relevant law, we may retain information as needed or appropriate to serve our legitimate business purposes or as required by law.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the mobile browsers or apps you use in order to serve you ads that are targeted to your interests.

You can stop the collection of location information from your mobile device by changing the preferences on your mobile device.

How we share personal information

Aetos Capital may share your personal information with other Aetos Capital companies, our business partners, content providers, clients, service providers, and other third parties with your consent or for the purposes disclosed above in this Privacy Statement. We do not disclose your personal information collected through the website to other entities, except as described in this policy.

Applicable law requires that we identify the categories of personal information we share for business purposes. We disclose the following categories of personal information for business purposes: personal identifiers, device and online identifiers, information about your internet, browser, and network activity, and location data.

We may share your information with the following types of entities or in the following situations:

Service providers: We engage service providers to facilitate our operation of the website. These service providers analyze information about the website and your use of the website. Information disclosed for these purposes may include device and online identifiers, ISP information, session ID and /or session log data, information about your internet, browser, and network activity, and location data.

Legal authorities, emergency responders and other legal requirements: We may disclose personal information to third parties as permitted by, or to comply with, applicable laws, regulations, or legal obligations, including but not limited to responding to a subpoena or similar legal process, protecting against fraud, cooperating with law enforcement or regulatory authorities, protecting and defending our rights or property, preventing or investigating possible wrongdoing in connection with the websites or services, protecting the personal safety of users of the service or the public, and protecting against legal liability. Information disclosed for these purposes may include device and online identifiers, information about your internet, browser, and network activity, and location data.

For Business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Email Marketing: We may use third party email marketing service providers to manage and send emails to you. We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at privacy@aetoscapital.com.

Aggregated and anonymized information

Aetos Capital collects certain information about you and your use of our website or services to generate anonymous, aggregated data (such that it does not identify any individual users) which we use for research, product development, and the purposes set forth above.  We may publish or otherwise provide our research containing this aggregated data in our products and services to third parties. If you would like to opt out of inclusion of your information in such aggregated data, please email privacy@aetoscapital.com.

Links to Other Websites

This Privacy Policy only applies to the use and disclosure of information we collect through our online services. Our online services may contain links to other websites such as our affiliates’ websites and sites belonging to third parties that are not affiliated with us. The inclusion of any link on our website or otherwise in our online services does not imply our endorsement of the linked website or service. While we try to link only to websites that meet our standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites, or links posted on our website or online services. Information you disclose to other parties or through such sites is subject to the privacy and security practices and policies of those parties or websites.  We disclaim all liability, to the extent permissible, with regard to your access to such linked websites.  Access to any other websites is at your own discretion and we encourage you to read the privacy statements of each and every website or online services visited in order to learn how such third parties may treat your information.

How we protect, store, and transfer your personal information

Aetos Capital maintains a comprehensive information security program intended to keep your information safe. We have technical, physical, and organizational measures in place to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal information. The measures we use are appropriate to the nature, scope, and purpose for which we use the personal information we collect. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the information provided. The security of your personal information is important to us, but please note that no method of transmission over the Internet, or method of electronic storage is perfectly secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Aetos Capital, its operations, workforce, and service providers are located throughout the world. Depending on how you interact with us, your personal information may be handled and stored in, accessed from, or transferred to different countries. Whenever we transfer personal information to different countries, we take steps to ensure that the personal information we transfer receives adequate protection in the jurisdictions that we handle or store it.

If you have additional questions about how we protect your information, please contact us at privacy@aetoscapital.com.

PROTECTING CHILDREN’S PRIVACY ONLINE

Our online services are not directed to or intended for individuals under 18 years of age.

Your rights

Your rights may differ based upon your residency. Certain local privacy laws may apply to you depending on your jurisdiction of residence. If you are a resident of California, Nevada or the European Economic Area, please refer to the specific sections of our Privacy Policy below, which may be applicable to you.

Individual data access requests

Certain jurisdictions provide their residents rights to access, correct, restrict the sale of, or erase personal information. These rights are not absolute, and they don’t always apply in all cases.

If applicable, you can exercise your rights by sending us a personal data access request to privacy@aetoscapital.com. In response to a request, we’ll ask you for additional information to verify your identity and may ask that you provide further information to help us better fulfill your request. You can also make your personal data access request by mailing us at the following address:

Attention: Data Privacy
Aetos Capital Inc.
875 Third Avenue
New York, NY  10022

If you request that we erase your personal information and we process that request, we may still retain certain elements of your personal information as permitted by law, including to comply with legal, regulatory, or our own policy requirements.

We won’t discriminate against our customers that choose to exercise their rights to access, control, or delete their personal information. Some of our products and services, however, may require your personal information. If you choose not to provide your personal information, you may not be able to use those products or services.

CALIFORNIA RESIDENTS

California residents should be aware that this section does not apply to: personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations, the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994; or other information subject to a California Consumer Privacy Act (CCPA) exception.

CCPA Notice of Information Collected

In the preceding twelve (12) months, we have collected the categories of personal information set forth in the following table. For each category, we collected one or more of the examples listed.

Your Rights under the CCPA

Under this Privacy Policy, and by law if you are a resident of California, you may have the following rights:

The right to notice. You must be properly notified which categories of personal information are being collected and the purposes for which the personal information is being used.

The right to access / the right to request. The CCPA permits you to request and obtain from us information regarding the disclosure of your personal information that has been collected in the past 12 months by us or its subsidiaries to a third-party for the third party's direct marketing purposes.

The right to say no to the sale of personal information. You also have the right to ask us not to sell your personal information to third parties.

The right to know about your personal information. You have the right to request and obtain from the Company information regarding the disclosure of the following:

• The categories of personal information collected

• The sources from which the personal information was collected

• The business or commercial purpose for collecting or selling the personal information

• Categories of third parties with whom we share personal information

• The specific pieces of personal information we collected about you

The right to delete personal information. You also have the right to request the deletion of your personal information that have been collected in the past 12 months.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer rights, including by:

• Denying goods or services to you

• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

• Providing a different level or quality of goods or services to you

• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can email us at privacy@aetoscapital.com.

California law requires us to verify the requests we receive from you when you exercise certain of the rights listed above. To verify your request, we will check the information you provide us in your request against third party identity verification tools. As part of this process, we may call you after you submit your request to verify information. You may also designate an authorized agent to exercise certain of the rights listed above on your behalf by providing the authorized agent with power of attorney pursuant to the California Probate Code. If an authorized agent submits a request on your behalf, we will contact you to verify that they represent you.

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information and have not within the last 12 months. However, the third party service providers we partner with may use technology on the website that "sells" personal information as defined by the CCPA law.  If you wish to opt out of the use of your personal information for these potential sales as defined under CCPA law, you may do so by following the instructions in this link or by emailing us at privacy@aetoscapital.com. 

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our website does not respond to Do Not Track signals.  However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track signals by visiting the preferences or settings page of your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties' direct marketing purposes.  If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us by email at privacy@aetoscapital.com.

NEVADA CONSUMERS

Nevada law gives Nevada consumers the right to request that a company not sell their personal information. If you are a Nevada consumer and wish to exercise this right, please submit your request here or by emailing us at privacy@aetoscapital.com.

INTERNATIONAL USERS

Our website and  services are United States-based and are controlled, operated and administered by us from our offices within the United States of America, and are made available to you on an unsolicited basis, without any marketing or promotion regarding this website or our services to you from us or our personnel.  This Privacy Policy is provided in accordance with and subject to applicable U.S. law.  If you decide to continue to access our online services from your location outside the United States, you hereby agree that your use of those services is subject to this Privacy Policy and acknowledge and agree that your personal information will be transferred to or processed within the United States.

EUROPEAN ECONOMIC AREA USERS

The foregoing section of this Privacy Policy pertains to you if you are from the European Economic Area (EEA), or are otherwise subject to General Data Protection Regulation (EU) 2016/679 (“GDPR”).

GDPR Privacy

Legal Basis for Processing Personal Information under GDPR

We may process personal information under the following conditions:

• Consent - you have given your consent for processing personal information for one or more specific purposes.

• Performance of a contract - provision of personal information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.

• Legal obligations - processing personal information is necessary for compliance with a legal obligation to which we are subject.

• Vital interests - processing personal information is necessary in order to protect your vital interests or of another natural person.

• Public interests - processing personal information is related to a task that is carried out in the public interest or in the exercise of official authority vested in Aetos Capital.

• Legitimate interests: processing personal information is necessary for the purposes of the legitimate interests pursued by the Aetos Capital.

In any case, Aetos Capital will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

Aetos Capital  undertakes to respect the confidentiality of your personal information and to enable you to exercise your rights under the GDPR.

You have the right under this Privacy Policy, and by law if you are within the EEA, to:

• Request access to your personal information. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact us by email at privacy@aetoscapital.com to assist you. This also enables you to receive a copy of the personal information we hold about you.

• Request correction of the personal information that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.

• Object to processing of your personal information. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal information on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request erasure of your personal information. You have the right to ask us to delete or remove personal information when there is no good reason for us to continue processing it.

• Request the transfer of your personal information. We will provide to you, or to a third-party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please not that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw your consent. You have the right to withdraw your consent on using your personal information. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the website.

Exercising Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us by email at privacy@aetoscapital.com. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, if You are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Contacting Our GDPR Data Protection Officer

We have designated a Data Protection Officer whom you have the right to contact with regard to all issues related to processing of your personal information and to the exercise of your rights under the GDPR.  You may contact our Data Protection Officer by email at privacy@aetoscapital.com.

EEA data subjects may contact the data protection officer with regard to all issues related to processing of their personal data and to the exercise of their rights under the GDPR.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify or supplement this Privacy Policy at any time. Therefore, we recommend that you review this Privacy Policy, updated and posted on this website, regularly for changes. The effective date of this Privacy Policy, as stated above, indicates the last time this Privacy Policy was revised.

Your continued use of our online services after we have changed the Privacy Policy signifies your acceptance of the revised terms.  This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information related to your use of the websites or our services. Under certain circumstances (i.e., with respect to material changes to this Privacy Policy), we may also elect to notify you through additional means, such as by posting a notice on the website or sending you an email. The revised policy will be effective immediately upon posting to our website.

OUR OTHER PRIVACY POLICIES OR NOTICES

This policy provides a general statement of the ways in which Aetos Capital protects your personal information when you access and use this website. You may, however, in connection with specific products or services offered by Aetos Capital, be provided with separate privacy policies or notices that describe the privacy practices associated with your use of those products or services.

CONTACT US

If you have any questions about this Privacy Policy, you can contact us:

By email:        privacy@aetoscapital.com

By mail:

Attention: Data Privacy
Aetos Capital Inc.
875 Third Avenue
New York, NY  10022