Privacy Policy

IMPORTANT INFORMATION ABOUT PRIVACY AND CERTAIN INFORMATION SHARING

This Privacy Policy explains the manner in which Mangrove Partners (the “Investment Manager”) and Mangrove Capital (the “General Partner” and, collectively with the Investment Manager, the “Company Entities” and sometimes referred to as “we” or “us”) collect, utilize and maintain nonpublic personal information about investors in The Mangrove Partners Fund, L.P. (the “U.S. Fund”), The Mangrove Partners Fund (Cayman), Ltd. (the “Cayman Fund”) and The Mangrove Partners Master Fund, Ltd. (the “Master Fund” and, together with the U.S. Fund and the Cayman Fund, each singly a “Fund Entity” a collectively, the “Fund Entities”), as required under U.S. Federal legislation. There may be additional rights under other laws that apply to you.

The Company Entities recognize the importance of protecting your personal and financial information when you visit our website located at www.MangrovePartners.com (“Website”) or when you submit information to any of the Company Entities in connection with your investments in any of the Fund Entities. The following information is provided to help you understand the information collection practices at the Website and by the Company Entities and the Fund Entities through other means, such as your submission of subscription documentation to the Company Entities. By visiting the Website, submitting subscription documentation or transacting other business with the Company Entities, you are accepting the practices described in this Privacy Policy as it may be modified. If you do not agree with this Privacy Policy, please do not use the Website and notify the Company Entities immediately by calling 212 897-9535 or by email to info@MangrovePartners.com.

Changes to this Privacy Policy
The Company Entities reserve the right to change, modify, add, remove or revoke this Privacy Policy at any time, in whole or in part, for any reason. Such change shall be effective immediately upon posting on the Website. We suggest that you review the Privacy Policy on the Website periodically for changes. The current version of this Privacy Policy can be accessed from the link on our homepage (www.MangrovePartners.com), or at the bottom of our other Website pages. You also acknowledge that the obligation of the Company Entities and the Fund Entities to deliver this Privacy Policy at least annually shall be deemed satisfied by the posting of this Privacy Policy on the Website.

Collection and Use of Investor Information
The Company Entities, the Fund Entities and SS&C Technologies, Inc., an unaffiliated entity that serves as administrator to the Fund Entities (the “Administrator”), collect personal information about Fund Entity investors through the following sources:

  • Subscription forms, investor questionnaires and other information provided by the investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, email address, US social security number, nationality, employment information, and financial and investment qualifications such as assets and income;
  • Investors’ transactions with the Company Entities, the Fund Entities and the Administrator, including account balances, investments and redemptions;
  • The Website; and
  • Online searches conducted by the Administrator to fulfill our anti-money laundering and “know-your-customer” obligations.

The personally identifiable information you submit to the Company Entities is used only to determine whether you will be admitted as a Fund Entity investor, to determine whether a Fund Entity will accept a further investment from an existing Fund Entity investor, to service your account and/or to provide you with information on the Company Entities and the Fund Entities. We will not sell, share or rent your personally identifiable information to others in contravention of this Privacy Policy. Please contact us by email or telephone as specified below to update your account information whenever such information ceases to be complete or accurate.

Additionally, if you access parts of the Website that are password protected, then (a) once you submit your password and enter, the Website will recognize who you are and collect all information that you submit, including all electronic information (including all transaction information), and (b) any information collected about you from the Website may be associated with other identifying information that we have about you.

We generally record certain usage information, such as the number and frequency of visitors to our Website. This information may include the websites that you access immediately before and after your visit to our Website, the Internet browser you are using and your Internet Protocol (IP) address. If we use such data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.

Cookies: Cookies are small text files that are stored in your computer's memory and hard drive when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website. Cookies help us to provide customized services and information. We use or may in the future use cookies on the Website for the following purposes:

  • Analytical purposes: Analytical cookies allow us to recognize, measure and track visitors to the Website. This helps us to improve and develop the way the Website works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of the site that are of the most interest to them.
  • Usage preferences: Some of the cookies on the Website are activated when visitors to our sites make a choice about their usage of the site. Our Website then ‘remembers' the settings preferences of the user concerned. This allows us to tailor aspects of the site to the individual user.
  • Terms and conditions: We use or may in the future use cookies on the Website to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on our Website. This helps to improve the user's experience of the site – for example, it avoids a user from repeatedly being asked to consent to the same terms.
  • Session management: The software that runs the Website uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use or may in the future use cookies to distribute requests among multiple servers, authenticate users and determine what features of the site they can access, verify the origin of requests, keep track of information about a user's session and determine which options or pages to display in order for the site to function.

To make full use of the Website, your computer or mobile device will need to accept cookies, as the site will not function properly without them. In addition, cookies are required in order to provide you with personalized features on the Website.

Local Flash Storage: We may include content on the Website designed for display using Adobe Flash Player, such as animations, videos and tools. Local flash storage (often referred to as "Flash cookies") can be used to help improve your experience as a user. Flash storage is retained on your device in much the same way as standard cookies, but is managed directly by your Flash software.

If you wish to disable or delete information stored locally in Flash, please see the documentation for your Flash software, located at www.adobe.com. Please note that, if you disable Flash cookies, some site functionality may not work.

Third party cookies: When you visit the Website, you may receive cookies that are set by third parties. These may include cookies set by Google, Unica, Forsee, Wall Street on Demand, Morningstar, Media Mind and/or Flurry. These cookies are used for the purposes described in the bullet points above. We do not control the setting of these third party cookies, so we suggest you might wish to check the third party websites for more information about their use of cookies and how to manage them.

Amending cookie preferences: You can configure your browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Website. In addition, a number of companies offer utilities designed to help you visit websites anonymously.

The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browsers, or you may consult the vendor documentation for your specific software.

Privacy Preferences: The Website may contain information, including P3P privacy policies ("Privacy Preference Information"), intended to work with your selected privacy preferences. While we have tried to make such Privacy Preference Information included within the Website conform to this full-text of this Privacy Policy, this Privacy Policy is the definitive statement of the privacy policies and practices for the Website.

Service Providers: We may use internal or external service providers to operate our Website and employ other persons to perform work on our behalf, such as sending postal mail and e-mail. These persons may have access to the personally identifiable information you submit through the Website, but only for the purpose of performing their duties. These personnel are not permitted to use your personally identifiable information for any other purpose.

Except as described above, the Company Entities, the Fund Entities and the Administrator do not obtain nonpublic personal information about Fund Entity investors from any other source.

Disclosure of Nonpublic Personal Information
The Company Entities, the Fund Entities and the Administrator do not disclose nonpublic personal information about Fund Entity investors to nonaffiliated third parties or to affiliated entities, except as permitted by U.S. law or the consent of Fund Entity investors. For example, the Company Entities, the Fund Entities and the Administrator may share nonpublic personal information in the following situations:

  • To respond to a subpoena or court order, judicial process or regulatory authorities;
  • To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities;
  • To service providers in connection with the administration and servicing of the Fund Entities and the Company Entities, which may include attorneys, accountants, auditors, or other professionals;
  • To service or process Fund Entity transactions; and
  • Upon consent of a Fund Entity investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the Fund Entity investor.

Each Fund Entity investor has the right to opt out of the disclosure of its nonpublic personal information to persons who are not affiliated with the Company Entities. If you wish to do so, please contact us immediately by calling 212 897-9535 or by email to info@mangrovepartners.com. We will honor your opt out election until you revoke it.

Protection of Investor Information
The Company Entities and the Fund Entities maintain safeguards that comply with U.S. Federal standards to protect investor information. The Company Entities and the Fund Entities restrict access to the personal and account information of Fund Entity investors to those persons who need to know such information in the course of their job responsibilities. Third parties with which the Company Entities or the Fund Entities share investor information must agree to follow appropriate standards of security and confidentiality.

E-mail and Marketing
The Company Entities and the Fund Entities do not sell investor e-mail addresses, and do not provide your personal information to third parties for their marketing purposes. The Company Entities and the Fund Entities will not send you e-mail messages without first receiving your permission, unless it relates to servicing your account or unless you have consented to receiving electronic delivery of fund documents. We recommend that you do not send us any individual personal information via nonsecure methods of correspondence, including via public electronic communication channels, such as Internet e-mail, which are generally not secure.

Business Transfers
If all or some of the business, stock or assets of the Company Entities are acquired or merged with another business entity, we will share all or some of your information with this entity to continue to provide service to you. You will receive notice of such an event and the new entity will inform you of any changes to the practices in this Privacy Policy. If the new entity wishes to make additional use of your information, you may decline such use at such time.

Children's Privacy
Although the Website is not targeted toward children, we are concerned about the safety and privacy of children who use the Internet. Consistent with the Children's Online Privacy Protection Act of 1998, we will never knowingly request personally identifiable information from anyone under the age of 13 without prior verifiable parental consent. If we become aware that a child under 13 has provided us with personally identifiable information without verifiable parental consent, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without verifiable parental consent, he or she should contact us immediately.

Third Party Websites
The Company Entities may establish links between the Website and one or more websites operated by third parties. The Company Entities have no control over any such other websites, the contents therein or the products/services offered. Your access to and use of such linked websites is governed by the terms of use and privacy policies of those sites, and shall be at your own risk. The Company Entities and the Fund Entities disclaim responsibility for the privacy policies and customer information practices of third-party internet websites hyperlinked from our Website.

Security
No data transmission over the internet can be 100% secure, so the Company Entities cannot ensure or warrant the security of any information you submit to us on the Website.

Contact Us
If you have any questions about this Privacy Policy or our privacy related practices, or if you would like a copy of the Company Entities' Regulation S-P privacy policy, please contact us.