CONTRARIAN CAPITAL MANAGEMENT LLC
PRIVACY NOTICE

Rights of California Residents. The CCPA grants residents of California certain rights with respect to their Personal Information. 

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California residents have the following rights under the CCPA:

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• the right to know the categories of Personal Information we have collected about you;

• the right to know the categories of sources from which Personal Information is collected, sold or shared, and to whom;

• the right to know our business or commercial purpose for collecting, selling, or sharing your Personal Information;

• the right to know the categories of third parties to whom we business disclose your Personal Information;

• the right to request specific pieces of your Personal Information that we hold;

• the right to request the deletion of your Personal Information, subject to several exceptions; 

• the right to opt out of the sale of your Personal Information; 

• the right to request that we correct inaccurate Personal Information that we have about you; 

• the right to request that we limit the use and disclosure of sensitive Personal Information collected about you; and

• the right to not be unlawfully discriminated against for exercising these rights.

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We may take reasonable steps to verify your identity before fulfilling your request to know or delete. For example, we may seek to establish your identity by matching information that you submit alongside your request with information that we have on our records. We may also ask for supplemental information as needed to establish your identity.

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Exercising Your Privacy Rights Under the CCPA. California residents, as well as Authorized agents seeking to submit requests on behalf of California residents and parents or guardians seeking to submit requests on behalf of their minors who are residents of California, may exercise the rights described below by contacting us at legal@contrariancapital.com or by calling us at (203) 862-8200.

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You have the right to request that we delete or correct inaccurate Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will (and direct our service providers) to delete or correct your Personal Information from our records, unless an exception applies. 

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We may deny your deletion or correction request if retaining the information is necessary for us or our service provider(s) to:

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• Complete the transaction for which we have collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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You have the right to request that we limit the use and the sharing of your Sensitive Personal Information to what is reasonably commercially necessary to perform our Services. 

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If you opt out of the sale of your Personal Information, we may still share your Personal Information with third parties if those transfers are not sales, such as with our Affiliates or our Service Providers.

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Response Timing and Procedures

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We endeavor to respond to a verifiable consumer request to correct inaccurate personal information, or delete personal information, within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. 

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The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

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We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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Categories of Personal Information We Disclose 

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We may disclose your Personal Information to a third party for a business purpose. In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose:

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Do Not Track

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California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (“DNT”) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, visit All About DNT (https://allaboutdnt.com).

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Shine the Light

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California's “Shine the Light” law, Cal. Civil Code §1798.83, gives California customers the right to prevent our disclosure of their Personal Information to third parties for those third parties' direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business' practices related to disclosing Personal Information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place.