In this Policy when we refer to Stabilis or “we”/“us”/“our” we mean Stabilis Capital Management, LP, and other entities that are associated with us.
We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.
This Policy describes:
- Categories of information that we collect
- How we use the information we collect
- How we share the information with third parties
- How long we keep your information
- Your rights regarding your data
- How to contact us and other important information
The information that we collect and where we get it from
"Personal information" is any information that can be used to identify you or that we can link to you and which we have in our possession or control.
We will collect and process the following categories of personal information about you:
- Information that you provide to us
We will process personal information that you give to us including when you email us or contact us through various channels as follows:
- In connection with our provision of investment advisory services: if you are a client of Stabilis you will provide us with personal information when you or the company you represent becomes a client. If you are not a client we may collect or receive your personal information because you are involved in one of our client’s matters.
Information we otherwise collect about you
Information we obtain from other sources
- If we collect or receive your personal information in the context of our provision of investment advisory services we might receive information from third parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities. That information could include your name, contact details and other information relevant to the investment advisory services that we are providing to our client.
How we use the information we collect
We may do the following with your personal information:
- use it to provide investment advisory services to the relevant client
- use it to engage in marketing and business development activity in relation to our investment advisory services. This may include sending you newsletters, marketing communications and other information that may be of interest to you
- where you have applied for a position with us, to review and process your job application
- to comply with legal and regulatory obligations that we have to discharge
- use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings
- record and monitor your use of our website for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports
- use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our website and our business
- use it to look into any complaints or queries you may have, and
- use it to prevent and respond to actual or potential fraud or illegal activities.
Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
- Consent - we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
- Performance of a contract - we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
- Legitimate interest - we may use your personal information for our legitimate interests, some examples of which are given above.
- Compliance with law or regulation - we may use your personal information as necessary to comply with applicable law/regulation.
How we share information with third parties
We may share your personal information outside the Firm. This may include:
- Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
- Third parties relevant to the investment advisory services that we provide. This may include, but is not limited to, attorneys, accountants, auditors, brokers, bankers and other professional service providers, regulators, authorities and governmental institutions.
- To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
Where we transfer your personal information as noted above, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information.
How long we keep your information
How long we hold your personal information for will vary and will depend principally on:
- the purpose for which we are using your personal information - we will need to keep the information for as long as is necessary for the relevant purpose, and
- legal obligations - laws or regulation may set a minimum period for which we have to keep your personal information.
We will ensure that the personal information that we hold is subject to appropriate security measures.
Your rights regarding your data
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.
These rights include:
- Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
- Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed other than to our client and as authorized by our client.
- Requesting that we correct your personal information if it is inaccurate or incomplete.
- Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
- Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
- In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit those information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
- Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
- Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
- We can, on request, tell you which data protection authority is relevant to the processing of your personal information.
Our website and third-party vendors, including Google, use first-party cookies (Google Analytics cookie) and third-party cookies together for various analytical functions.
Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.
To learn more about cookies used by Google Analytics, please visit the information page.
To learn more about cookies used by Salesforce Pardot, please visit the information page.
How to contact us and other important information
If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at:140 East 45th Street, Suite 22-C, New York, NY 10017.
THE INFORMATION AND SERVICES PROVIDED ON THE SITE ARE NOT INTENDED FOR DISTRIBUTION TO, OR USE BY, AND ARE IN PARTICULAR NOT DIRECTED TO, ANY PERSON OR ENTITY IN ANY JURISDICTION OR COUNTRY WHERE SUCH DISTRIBUTION OR USE WOULD BE CONTRARY TO LAW OR REGULATION, WOULD OBLIGATE STABILIS TO COMPLY WITH ADDITIONAL RULES OR WHICH WOULD SUBJECT STABILIS OR ANY OF ITS AFFILIATES TO ANY ADDITIONAL REGISTRATION REQUIREMENT WITHIN SUCH JURISDICTION OR COUNTRY.
If you meet the requirements for registering with Stabilis, including being qualified as an “accredited investor” (as that term is defined under Regulation D promulgated under the Securities Act of 1933) and also deemed a “qualified purchaser” (as that term is defined under Section 3(c)(7) under the Investment Advisers Act of 1940), you may become a “Registered User” of the Site.
1. TERMS AND CONDITIONS
The Site is offered to you conditioned on your acceptance without modification of the terms, conditions, and notices contained herein. Your use of the Site constitutes your agreement to and understanding of all such terms, conditions, and notices. Stabilis reserves the right to change the terms, conditions, and notices under which the Site and the information and services offered through the Site are offered without further notice to you. Your continued use of the Site will signify your agreement with and understanding of any additional or modified terms, conditions or notices applicable to the Site.
While Stabilis uses reasonable efforts to update the information on the Site, Stabilis makes no representations or warranties as to the accuracy, reliability, timeliness or completeness of any information at the Site. Any content at the Site is subject to change without notice.
2. GRANT OF REGISTERED USER LICENSE
Users may print and download materials and reports from the Site provided that all hard copies contain all copyright and other applicable notices contained in the originals of such materials and reports. The use of any such material on any other Web site or networked computer environment is prohibited.
Nothing at the Site shall be construed as granting, by implication, estoppel or otherwise, any license or right to use any image, trademark, logo or service mark at the Site. No act of downloading or otherwise copying from the Site will transfer title to any software or material at the Site to you. You may not decompile, reverse engineer, disassemble, or otherwise reduce any computer files obtained from the Site to a human-perceivable form. Anything that you transmit to the Site becomes the property of Stabilis, may be used by Stabilis for any lawful purpose (subject to any further agreement between you and Stabilis), and is further subject to disclosure as deemed appropriate by Stabilis, including to any legal or regulatory authority to which Stabilis is subject. Stabilis reserves all rights with respect to copyright and trademark ownership of all material at the Site, and will enforce such rights to the full extent of the law.
3. NATURE OF SITE
The Site is provided solely for the purpose of providing information and news about securities markets, hedge funds, hedge fund managers and other alternative investments.
While the information contained on the Site has been obtained from sources believed reliable, neither Stabilis nor any information provider guarantee that the information on the Site is accurate, timely, valid or complete or make any warranties with regard to the results that have or may be obtained from its use.
IF YOU ARE IN ANY DOUBT AS TO WHETHER THIS WEB SITE CAN BE LAWFULLY USED BY YOU DO NOT USE THE SITE.
4. NO INVESTMENT ADVICE OR INVESTMENT RECOMMENDATIONS
The information on the Site is intended for informational, educational and research purposes only. Stabilis does not provide recommendations, investment advice or any other advice to you or any other party through the Site, and no information or material at the Site is to be relied upon for the purpose of making or communicating investment or other decisions. Accordingly, Stabilis does not offer advice regarding the quality or suitability of any investment or of any investment manager and assumes no responsibility or liability for any investment decisions or advice, treatment, or services rendered by any person or entity mentioned, featured or linked to on the Site.
Neither the information nor any opinion contained on the Site constitutes investment advice or an offer or a solicitation by Stabilis for the purchase or sale of any securities, futures, options or other financial instruments. This material and any views expressed herein are provided for informational purposes only and should not be construed in any way as an endorsement or inducement to invest with any hedge fund or other alternative investment program or any investment manager or advisor mentioned. Before making any investment decision, seeking any investment manager’s or advisor’s services or investing in any hedge fund or other alternative investment program, you are advised to consult with your broker or other financial advisor to verify pricing and other information and/or do such other due diligence as may be appropriate under the circumstances, including reading and examining thoroughly the relevant disclosure documents and/or offering memorandum. Stabilis shall have no liability for investment decisions based upon, or the results obtained, from the content provided herein.
5. INTELLECTUAL PROPERTY RIGHTS
All material contained on or available through the Site, unless otherwise indicated, is protected by law including, but not limited to, copyright, trade secret, and trademark law, as well as other state, national, and international laws and regulations.
Except as expressly provided herein, Stabilis does not grant any express or implied right to users of the Site under any patent(s), copyright(s), trademark(s), or trade secret information. Accordingly, unauthorized use of any material contained on the Site by you will violate copyright laws, trademark laws, trade secret laws, the laws of privacy and publicity, and other regulations and statutes.
The contents of the Site are Copyright © 2018. All rights reserved. Stabilis also owns a copyright in the Site as a collective work and/or compilation, and in the selection, coordination, arrangement, and enhancement of the Site’s content.
Stabilis and all other names, logos, and icons identifying Stabilis’s products and services are proprietary marks of Stabilis, and any use of such marks without the express written permission of Stabilis is strictly prohibited. Other product and company names mentioned herein may be the trademarks of their respective owners.
7. SITE SECURITY
The Site may contain links to other Web sites (See “Links to Other Sites” below). Stabilis is not responsible for the privacy practices or the content of such Web sites. The Site has strict security measures in place to protect against the loss, theft, misuse and/or alteration of the information contained on the Site.
8. CONFIDENTIALITY ON INTERNET
Use of the Internet is solely at your own risk and is subject to all applicable local, state, national, and international laws and regulations. While Stabilis has endeavored to create a secure and reliable Site, please be advised that the confidentiality of any communication or material transmitted to/from the Site over the Internet cannot be guaranteed.
Accordingly, Stabilis and its affiliates are not responsible for the security of any information transmitted via the Internet or for the consequences of any reliance on such information. You assume the sole and complete risk for using the Site and must make your own determination as to these matters.
9. SECURITY OF SITE
Actual or attempted unauthorized use of the Site may result in criminal and/or civil prosecution. For your protection, Stabilis reserves the right to view, monitor, and record activity on the Site without notice or permission from you.
Any information obtained by monitoring, reviewing, or recording is subject to review by appropriate governmental, regulatory and law enforcement organizations in connection with applicable law, including the investigation or prosecution of possible criminal activity on the Site. Stabilis will also comply with all lawful court orders and governmental, regulatory and law enforcement requests involving such information.
10. LINKS TO OTHER SITES
Stabilis may provide links, in its sole discretion, to other sites on the World Wide Web for your convenience in locating related information and services or otherwise. Stabilis has not reviewed the content of any site owned by a third party that may be linked to the Site and exercises no control over such sites.
Accordingly, Stabilis expressly disclaims any responsibility and shall not be liable for the content (or any errors, misrepresentations, or omissions therein), the accuracy and timeliness of the information, the download, transmission or delivery of any such information and/or quality of products or services provided by or advertised on these third-party Web sites. Moreover, these links do not imply an endorsement with respect to any third party or any Web site or the products or services provided by any third party. See “Disclaimers.”
11. EVENTS BEYOND STABILIS’S CONTROL
You expressly absolve and release Stabilis and its affiliates and each of their respective officers, directors, members, partners, shareholders, employees, agents, advisors and representatives (collectively, “Stabilis and Its Affiliates”) from any claim of harm resulting from a cause beyond Stabilis’s control, including, but not limited to, failure of electronic or mechanical equipment or communication lines, telephone or other interconnect problems, computer viruses, unauthorized access, theft, operator errors, severe weather, earthquakes, or natural disasters, strikes or other labor problems, wars, terrorist attacks, or governmental restrictions.
THE MATERIALS AT THE SITE ARE PROVIDED “AS IS.” SUCH MATERIALS HAVE BEEN GATHERED AND DERIVED FROM SOURCES BELIEVED TO BE RELIABLE, HOWEVER STABILIS HAS NOT INDEPENDENTLY VERIFIED THE INFORMATION AND MAKES NO REPRESENTATION OR WARRANTY, EXPRESSED OR IMPLIED, OF ANY KIND WHATSOEVER, TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, INCLUDING REGARDING THE ACCURACY, TIMELINESS, VALIDITY OR COMPLETENESS OF THE INFORMATION, INCLUDING WARRANTIES OF FITNESS FOR A PARTICULAR PURPOSE, MERCHANTABILITY OR NON-INFRINGEMENT OR THAT THE SERVICE WILL REMAIN UNINTERRUPTED.
STABILIS FURTHER ASSUMES NO RESPONSIBILITY FOR, AND MAKES NO WARRANTIES THAT, FUNCTIONS OR SERVICES CONTAINED AT THE SITE WILL BE UNINTERRUPTED OR ERROR-FREE, THAT DEFECTS WILL BE CORRECTED, OR THAT THE SITE OR THE SERVER THAT MAKES IT AVAILABLE WILL BE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. STABILIS AND ITS AFFILIATES SHALL NOT BE LIABLE FOR ANY DAMAGES TO, VIRUSES THAT MAY INFECT, OR SERVICES, REPAIRS OR CORRECTIONS THAT MUST BE PERFORMED, ON YOUR COMPUTER OR OTHER PROPERTY ON ACCOUNT OF YOUR ACCESSING OR USE OF THE SITE. PLEASE NOTE THAT SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, SO SOME OR ALL OF THE ABOVE EXCLUSIONS MAY NOT APPLY TO YOU.
THE INFORMATION ON THE SITE IS INTENDED FOR INFORMATIONAL, EDUCATIONAL AND RESEARCH PURPOSES ONLY. ACCORDINGLY, STABILIS AND ITS AFFILIATES, DO NOT RECOMMEND, SOLICIT OR OFFER ANY INVESTMENT THROUGH THE SITE AND SHALL NOT BE LIABLE FOR ANY INVESTMENT DECISIONS, ADVICE, LOSS OF PROFITS, COSTS OR ANY OTHER INDIRECT DAMAGES RELATING TO THE SUITABILITY, ADEQUACY, VALIDITY, ACCURACY, TIMELINESS, DELAY OR COMPLETENESS OF ANY INFORMATION ON THE SITE.
WITH RESPECT TO THE PERFORMANCE DATA PRESENTED ON THE SITE, YOU SHOULD NOTE THAT PAST PERFORMANCE IS NOT NECESSARILY AN INDICATION, AND IS NOT A GUARANTEE, OF FUTURE PERFORMANCE.
UNAUTHORIZED USE OF ANY MATERIAL CONTAINED ON THE SITE MAY VIOLATE COPYRIGHT LAWS, TRADEMARK LAWS, TRADE SECRET LAWS, THE LAWS OF PRIVACY AND PUBLICITY, AND OTHER REGULATIONS AND STATUTES. FOR ANY AUTHORIZATION REQUESTS, PLEASE CONTACT US AT (212) 256-8970..
13. LIMITATION OF LIABILITY AND INDEMNITY
Under no circumstances, including, but not limited to, negligence, shall Stabilis and Its Affiliates be liable for any special or consequential damages that result from the use of, or the inability to use, the materials in the Site, even if Stabilis and/or Its Affiliates have been advised of the possibility of such damages. In no event will Stabilis and Its Affiliates have any liability to you for damages, losses and causes of action (whether in contract, tort, including, but not limited to, negligence, or otherwise) for accessing the Site.
14. GOVERNING LAW
The Site is controlled and operated by Stabilis Capital Management, LP from the office in the United States. Stabilis makes no representation that materials in the Site are appropriate or available for use in other locations, and access to them from territories where any of the contents of the Site are illegal is prohibited. Those who choose to access the Site from other locations do so on their own accord and are responsible for compliance with applicable local laws.
15. TERMS AND TERMINATION
19. RESERVATION OF RIGHTS
Any rights not expressly granted herein are reserved.
20. ENTIRE AGREEMENT