©2019 Sheffield Asset Management, L.L.C.

WEBSITE PRIVACY POLICY

 

Effective April 1, 2019

The privacy practices of this Website Privacy Policy apply to how we, Sheffield Asset Management, L.L.C., collect and use your information through the domain and subdomains of www.sheffieldmgmt.com (the “Site”).  We recognize that privacy is important to our users, so we design and operate our Site with the protection of your privacy in mind.  This Website Privacy Policy outlines the types of information we may gather and use when you visit our Site, as well as some of the steps we take to safeguard it.  Investors in our funds or our clients (“Investors”) receive our Privacy Notice, describing our privacy policies and procedures applicable to their personal information.  The Privacy Notice does not apply to visitors to this Site who are not Investors.  With respect to Investors, if this Website Privacy Policy and the Privacy Notice conflict, the Privacy Notice will govern.

By visiting the Site, you agree to be bound by the terms and conditions of this Website Privacy Policy.  If you do not agree, please do not use or access the Site. 

By accepting the Website Privacy Policy and the Terms of Use, you expressly consent to our use and disclosure of your information in accordance with this Website Privacy Policy.  This Website Privacy Policy is incorporated into and subject to the terms of the Terms of Use. 

INFORMATION COLLECTION AND USE

This Website Privacy Policy applies to information we collect through the Site.  We do not presently collect any “personally identifiable information,” including any visitors’ names, addresses, phone numbers, social security numbers or email addresses, from visitors to the publicly available areas of the Site. We may collect email addresses of our Investors who choose to access the private, restricted area of our website reserved for Investors.  At times, visitors to our website may choose to contact us by email using links available on the Site; in that case, we may collect a visitor’s email address to reply to that email.

We automatically track the information that your browser makes available to us whenever you visit the Site.  This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser.  This information may include the URL that you just came from (whether this URL is on the Site or not), the URL you next visit (whether this URL is on the Site or not), your computer browser information and your IP address.  We use this information to operate, develop and improve our services.

We also may use data collection devices such as “cookies” on certain pages of the Site to help analyze our web page flow, measure effectiveness, and promote trust and safety.  “Cookies” are small files placed on your hard drive.  We may offer certain features that are only available through the use of a “cookie.”  Cookies can also help us provide information that is targeted to your interests.  Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session.  You may refuse the use of cookies by selecting the appropriate settings on your browser.

We may use information collected from you to measure interest, customize your experience and enforce our Terms of Use.  We may also share information about you if we believe that disclosure is required under law.  For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.  

LINKS TO THIRD PARTY WEBSITES

Our Site also contains links to third party sites that are not owned or controlled by us.  Please be aware that we are not responsible for the privacy practices of such other sites.  We encourage you to be aware of that when you leave our Site and to read the privacy policies of each site that you visit from our Site.

Investors that desire to access the Investor Login portal, are redirected to a website maintained by a third party, Morgan Stanley & Co. LLC and its affiliates, including Morgan Stanley Fund Services (the “Administrator”), and Investors may be requested to provide the Investor’s name, mailing address, email address, phone number, personal financial data and other information to obtain access.  The Administrator may share this information with us and use this information pursuant to the terms of its privacy policy, including, among other things, to determine whether you are an accredited investor and have sufficient sophistication, investment experience and wealth to receive information about certain investment options.  

Use of the Investor Login portal provided by the Administrator is governed by the terms of use and privacy policy of the Administrator’s website.  To review, change or deactivate an Investor’s user account and login information, please follow the instructions provided by the Administrator or the instructions available through the Administrator’s website. 

SECURITY

We use procedural and technical safeguards to protect your information against loss or theft.  We treat data as an asset that must be protected against loss and unauthorized access.  We employ security techniques to protect such data from unauthorized access by users inside and outside the company.  It is possible, however, that a third party will circumvent such security measures, and we do not guarantee that our security measures will successfully prevent third parties from accessing the information we collect.  

 

PHISHING

Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your username, password, credit card information or national identification number in an unsolicited email or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

 

CHILDREN

Children (persons under the age of 18) are not eligible to use the Site and, therefore, we do not knowingly collect any information from persons under the age of 18.  

 

CONDITION OF USE

If you choose to visit the Site, your visit and any dispute over privacy is subject to this Website Privacy Policy and our Terms of Use, including limitations on damages and application of the law of the State of Illinois.  If you have any concern about this Website Privacy Policy, please send a thorough description to info@sheffieldmgmt.com.

 

CHANGES TO THIS POLICY

Please note this Website Privacy Policy may change.  We may amend this Privacy Policy at any time by posting the amended terms on the Site.  All amended terms shall automatically be effective 30 days after they are initially posted on the Site.  Your continued use of the Site constitutes your agreement to this Website Privacy Policy and any changes to this Website Privacy Policy.    If you do not agree with this Website Privacy Policy or any changes to the Website Privacy Policy, please do not use or access the Site.

If you have any additional questions, please feel free to contact us any time at info@sheffieldmgmt.com