California Consumer Privacy Act

Notice to California Residents

Last Update: January 11, 2021

This Notice to California Residents (“CCPA Notice”), provided by Candlestick Capital Management LP (“Company,” “we,” “us,” or “our”) pursuant to the California Consumer Privacy Act (“CCPA”) applies to natural persons who reside in the State of California (“consumers” or “you”) who engage or interact with us or on the funds and accounts managed by us, including, without limitation, visiting our website and purchasing our products or services. Any terms used herein but not defined shall have the meaning assigned in the CCPA.

In the event of any conflict or inconsistency between this CCPA Notice and any of our other privacy policies, this CCPA Notice shall control only with respect to the Personal Information (as defined in CCPA) of consumers, their households or devices. Additionally, if you are located outside of the State of California this CCPA Notice does not apply to you.

Information We Collect

Categories of Personal Information. Company has or may have collected and/or received the Categories of Personal Information identified below (with examples) from or about consumers, their households or devices, within the twelve (12) months preceding the Last Update of this CCPA Notice (“Last Update”). Personal Information does not include (i) publicly available information from government records; (ii) deidentified or aggregated Personal Information; or (iii) information excluded from the CCPA including information regulated by certain sector-specific data protection laws including the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, the Gramm-Leach-Bliley Act of 1999, and the California Financial Information Privacy Act.

Identifiers. A real name, alias, postal address, email address, or other similar identifiers.
Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories

Categories of Sources. We may collect the Categories of Personal Information listed above from the following Categories of Sources: (i) directly from consumers, or consumers’ agents or employers (e.g., forms, surveys, responses, or other interactions from or with consumers), and (ii) indirectly from consumers (e.g., consumer activity online, interactions with our Website and other sites).

Use of Personal Information. We may use or disclose the Personal Information we collect for one or more of the following commercial or business purposes (each, a “Business Purpose”): (i) to investigate and to manage enquiries, disputes and legal proceedings, (ii) comply with court orders, mandatory dispute resolution determinations, mandatory government authority or law enforcement orders or directions, or applicable regulatory requirements (iii) as described to you when collecting your Personal Information or as otherwise permissible under the CCPA, (iv) to evaluate or consummate a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information is among the assets transferred, (v) where applicable, to assist us in verifying your identity, and to provide support, personalize, and develop our products and services, (vi) to fulfill and respond to your inquiries and requests, including providing you with support, investigating and addressing your concerns, monitoring and improving our responses, and to otherwise carry out the purposes for which you provided the information, (vii) to receive products or services from you and (viii) to otherwise conduct our business, including providing our products and services.

Categories of Third Party Recipients. We may only share your Personal Information with Service Providers, which include IT and cloud hosting companies, payment providers, transactions reporting providers, customer relationship management, and providers of administrative services for our Business Purposes or as otherwise required by applicable law.

Disclosures of Personal Information for a Business Purpose. In the twelve (12) months preceding the Last Update, we may have disclosed the Categories of Personal Information for a Business Purpose to the Categories of Third Parties set forth in Table I.

Table I: Categories of Personal Information Collected

Categories of Third Party Recipients

Identifiers

Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e))

Protected classification characteristics under California or federal law

Commercial Information

Biometric information

Internet or other similar network activity

Geolocation data

Audio, electronic, visual, thermal, olfactory, or similar information

Professional or employment-related information

Non-public education information

Inferences

Service Providers

Sales of Personal Information. In the twelve (12) months preceding the Last Update, we have not sold Personal Information.

Your Rights and Choices

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes such rights and explains how to exercise them.

Right to Know About Personal Information. You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your Personal Information. Once we receive and verify your request, we will disclose to you the following (to the extent applicable to your request):

Specific pieces of Personal Information we collected about you in the preceding twelve (12) months (also known as a data portability request)
Categories of Personal Information we collected about you in the preceding twelve (12) months
Categories of Sources from which the Personal Information was collected
Our Business Purpose for collecting that Personal Information; and
If we disclosed your Personal Information for a Business Purpose, Categories of Personal Information that we disclosed for a Business Purpose and the Categories of Third Party Recipients to whom the Personal Information was disclosed.

Right to Request Deletion.You have the right to request that we delete any of Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

Exercising Rights to Know or Request Deletion. To exercise the rights to know or request deletion described above, please submit a verifiable consumer request to us by either: (a) calling us at (800) 420-3780, or (b) submitting your request by email to Compliance@Candlestickcapital.com.

You may only make a verifiable consumer request under the right to know twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information related to you.

Making a verifiable consumer request does not require you to create an account with us.

Verification Process. To submit a verifiable consumer request, the consumer may be required to provide up to three data points, which may include additional Personal Information, to enable us to verify the consumer’s identity with the degree of certainty required by the CCPA.

We will use Personal Information provided in a verifiable consumer request solely for the purpose of verifying the requestor’s identity or authority to make the request. We or a third party on our behalf may follow up with you to determine whether a request is a verifiable consumer request under applicable law.

If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, we will deny the consumer request in whole or in part and will not to disclose the information requested or, as applicable, will not delete the information requested. We will respond to any such consumer request with a denial and will also explain why it has no reasonable method by which it can verify the identity of the requestor.

Response Timing and Format. We will confirm receipt of a verifiable consumer request within then (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. If you do not have an account with us, and you do not indicate a preference for delivery, we will use its discretion in choosing the method of delivery of the information.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. 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 useable and should allow you to transmit the information from one entity to another entity without hindrance.

We may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.

Right to Opt-Out of the Sale of Personal Information. We do not sell the Personal Information of consumers (including minors under 16 years of age). However, if you are 16 years of age or older, you have the right, at any time, to direct us to not sell your Personal Information (the “right to opt-out”) and if you are under 16 years of age you have the right to opt-in to the sale of your Personal Information.

Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. We will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties, (iii) provide you a different level or quality of products or services, and (iv) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.

Right to Designate an Authorized Agent

If you submit a request to know or delete your Personal Information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization.

Other California Privacy Rights

Pursuant to California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties.

To make such a request, please send an email to Compliance@Candlestickcapital.com.

Changes to Our CCPA Notice

This CCPA Notice is effective as of the date of the Last Update stated at the top of this CCPA Notice. We may change this CCPA Notice from time to time with or without notice to you. By visiting or accessing the Website or the Services, purchasing products or services from us, or otherwise engaging or interacting with us after we make any such changes to this CCPA Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CCPA Notice in current effect. Please refer back to this CCPA Notice on a regular basis.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in the CCPA Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone:

Email:

Postal Address:

(800) 420-3780

Compliance@Candlestickcapital.com

Candlestick Capital Management LP
1 Lafayette Place
Greenwich, CT 06830
ATTN: Compliance

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