Online Privacy Statement

Last revised: June 30, 2023
 

This Online Privacy Statement describes the personal information First Eagle Investment Management, LLC, First Eagle Separate Account Management, LLC, First Eagle Alternative Credit, LLC, Napier Park Global Capital (US) LP, Napier Park Global Capital Ltd, and Napier Park Global Capital GmbH (together, “First Eagle,” “we,” “us,” or “our”) process about you when you visit www.firsteagle.com and any other site on which a link to this Online Privacy Statement appears (“Website”) as well as information that we may process about you via other means, as described below.

If you are a prospective, current, or former client of First Eagle or a shareholder in a registered investment company managed by First Eagle or in another First Eagle investment product, some of the information we may collect from you online constitutes “non-public personal information.” To access the privacy notices that may be relevant to you and learn about our collection, sharing and use of clients’ non-public personal information, please read the Privacy Overview. 

Personal Information We Collect About You

We collect information about you in various ways. Some of this information may be considered “personal information” under applicable law. The categories of personal information that you provide and that we collect or receive from you depends on the context of your interaction with us and our Website, the choices you make when you use our Website, and the features that you use. These categories of personal information may include the following:

  • Identifiers, such as your name, address, email address, unique personal identifier, online identifier, Internet Protocol address, account name, Social Security number, driver’s license number, passport number or other similar identifiers;
  • Personal information categories under California law, including name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, education, employment, employment history, bank account number or other financial information (some personal information included in this category may overlap with other categories);
  • Characteristics that are considered protected classifications under certain laws, such as national origin and marital status;
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Professional or employment information, such as your job title and place of work;
  • Internet or other electronic network activity information, such as information regarding when you access or how you use our Website, the URLS of the pages that you visit and information regarding how long you use various pages or aspects of our Website, the type of browser and/or operating system you are using, and the domain name of your Internet service provider;
  • Geolocation data, such as geographic location information about a particular individual or device;
  • Inferences drawn from any of the information described above to create a profile about an individual reflecting the individual’s preferences;

We may collect information that is considered “sensitive” under some data protection laws, such as your account log-in information if you log into our investor portal, sensitive identifiers like Social Security number and some financial information. When we do so, we use such information only for lawful purposes in compliance with the applicable data protection laws, such as to perform the services requested by you and to resist malicious, deceptive, fraudulent or illegal actions. Where required by applicable law, we will obtain your consent prior to processing such information.

We take reasonable steps to accurately record the personal information that you provide to us and any subsequent updates to such information. We encourage you to review, update, and correct the personal information that you provide to us. Please contact us at FirstEagle.Privacy@firsteagle.com in order to do so.

How We Collect Your Personal Information

We may obtain information about you from the following sources:

You may provide information to us directly. For example, we collect and receive information from you directly when you complete subscription applications or other forms, contact us, register for or log into your account, and visit our Website.

We collect information from third parties, service providers, and public records. We may engage third-party entities to provide services to us and may receive information about you from those entities. We also collect information about your transactions with our affiliates or unaffiliated third parties, as well as information from public records we may access in the ordinary course of business.

We collect information from you automatically through tracking technologies. When you visit our Website we collect certain information from you automatically. We may collect this information through cookies and other tracking technologies. We may combine this information with other information we collect about you on our Website or via other sources.

For more information regarding how we and third parties we engage may collect information from you automatically via cookies and other tracking technologies, please see Cookies and Other Tracking Technologies below.

How We Use Your Information 

We may use the information we collect from you in a variety of ways, including:

  • To present our Website and its contents to you and to operate our Website;
  • To deliver the information, products or services you have requested from us;
  • To register your account and deliver access to your account to you;
  • To reach out to you about and market or promote new information, products or services to you that we believe you may be interested in;
  • In connection with client services and client management systems;
  • To communicate with you, including to notify you about changes to our Website or products or services
  • To help us improve our Website and deliver a more personalized experience. This includes by enabling us to estimate and analyze our audience size and usage patterns, store information about your preferences, speed up your searches and recognize you when you return to our Website;
  • To carry out our obligations and enforce our rights arising from any contracts entered into with you. This includes for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of the Website, its employees or agents, or other users;
  • To comply with applicable laws and regulations, including laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions, and to comply with valid legal process, including a search warrant, subpoena or court order;
  • To carry out statistical analysis and market research and other legitimate business interests; 
  • In any other way we may describe when you provide the information, or otherwise at your direction or with your consent; and
  • As permitted by law or as we may notify you.
How We Share Information

We may share the information that we collect about you as follows:

  • With our affiliates;
  • With our service providers, business partners and vendors. These parties may include companies that host our Website, provide web analytics, perform data processing, distribute emails to you or help us communicate with you;
  • When you request any of our products or services, we will share your information to the extent necessary or appropriate to fulfill your request; and
  • As permitted and/or when required to do so by law. For example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.

If First Eagle or any of its affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of assets, the relevant customer database, including personal information we may possess about you, and information collected pursuant to this Online Privacy Statement, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.

If you are located in Europe, please note that due to the global nature of First Eagle’s operations, it may be necessary to disclose your personal information to persons in locations outside of the European Economic Area, the United Kingdom and/or Switzerland. Where First Eagle does disclose or transfer your data outside of these regions, we will ensure that appropriate data transfer mechanisms are in place. Generally, we put in place European Commission approved standard contractual clauses for such transfers.

Cookies and Other Tracking Technologies

We and third-party partners we engage may use cookies (i.e., small files stored on your hard drive), web beacons, tracking pixels or other tracking technologies to automatically collect information, including personal information such as your IP address, from your browser.

Our Website may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our Website.

Our Website uses Google Analytics, a web analytics service offered by Google. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at https://policies.google.com/technologies/partner-sites.

Our Website may use cookies and other tracking technologies for a variety of purposes. For example, we, our service providers and other partners we engage use cookies and other tracking technologies:

  • To operate the Website and provide the Website and its content to you;
  • For functional or analytics purposes, such as to provide us with information about which portions of our Website are the most popular, enabling us to see what web pages a user visits and how much time a user spends on each page; and
  • To personalize your experience on our Website (e.g., to recognize you by name when you return to our site, to save your password in password-protected areas, or to tailor content, or product and service offerings to you).

We take steps to contractually limit the rights our third-party partners have to the information they collect from you via cookies and other tracking technologies. However, we may grant some of our third-party partners rights to non-identifiable information.

Your Choices

You can generally manage your cookie preferences through your web browser. Most web browsers will tell you how to stop accepting new cookies and how to disable existing cookies. For more information regarding how to manage your preferences, please consult the information made available by your particular browser or visit www.allaboutcookies.org.

With respect to Google Analytics, you can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout in an effort to opt-out of being tracked by Google Analytics.

Please note that if you choose not to accept cookies, you may be unable to use certain features of our Website. In addition, you may still receive advertisements on our Website; however, they may not be as relevant to you.

“Do Not Track” Signals and GPC 

We do not recognize the “do not track” signals that some browsers may employ as no uniform standard for responding to such signals has been developed at this time. We will recognize Global Privacy Control (“GPC”) and other browser opt-out signals as valid requests to opt out of selling personal information or sharing personal information for cross-context behavioral advertising.

Data Security and Retention

Your relationship and trust are very important to us, as is the security of your personal information. We maintain physical, electronic, and procedural safeguards in an effort to safeguard consumer information and personal information. It is important to remember, however, that no data security measures can guarantee security or protect against unauthorized activity.

We will keep your data for as long as you maintain a business relationship with us and afterwards in accordance with our legal and regulatory obligations. When deciding how long to retain your personal information, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information described above and whether we can achieve those purposes through other means. We may also retain your personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.

Data Subject Rights 

Depending on your jurisdiction, you may have certain data subject rights. These rights vary and may be subject to certain limitations and exemptions, but they may include the right to:

  • know what personal information we collect, including (a) the right to request information regarding the categories of personal information that we collect along with other information such as the categories of sources from which the information is collected and third parties with whom it is shared and (b) the right to request a copy of the specific pieces of personal information that we collect (sometimes referred to as the right to access personal information);
  • correct or delete personal information;
  • opt out of the sale of personal information or sharing personal information for cross-context behavioral advertising;
  • object to or restrict the processing of their personal information, including to limit the use or disclosure of sensitive personal information under certain circumstances; and
  • obtain a copy of your personal information in a portable format;

Individuals may also have the right to not be discriminated against for exercising applicable data subject rights, and to lodge a complaint about the processing of personal information with a data protection authority.

The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. To exercise your data subject rights, please contact us at FirstEagle.Privacy@firsteagle.com or call us toll-free at (800) 482-5667. If you make a request related to personal information about you, we will need to verify your identity. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.

California Shine the Light Disclosure

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties without your consent for their direct marketing.

Links to Third-Party Websites

Our Website contains links to third-party sites and services whose privacy practices may be different than ours. We may also allow you to connect with other third-party sites and services. We are not responsible for the privacy practices of third-party sites and services and you should consult the other third-party sites’ and services’ privacy notices in order to better understand their privacy practices.

Children’s Privacy

Our Website is not intended for users under the age of 16, and we do not knowingly collect information from anyone under the age of 16. No one under the age of 16 is permitted to access or use this Website or provide us with personal information.

Changes to the Online Privacy Statement

We may update or revise our Online Privacy Statement at any time. If there are changes, we will post an updated version of the relevant policy or policies on the Website.

How to Contact Us

If you have any questions or concerns about this Online Privacy Statement, please call us toll free at: (800) 482-5667.