Privacy Policy

Last Updated: January 11, 2021

Candlestick Capital Management LP and our affiliates and subsidiaries (collectively, “Candlestick,” “we,” “us,” or “our”) welcome you. Our collection and use of information from visitors of our website located at https://candlestickcapital.com/ (the “Website”) is subject to the following privacy policy (the “Privacy Policy”), which may be updated by us from time to time without notice to you. By accessing or using the Website, you agree to be bound by this Privacy Policy.

Natural persons who reside in the State of California should also review the Notice to California Residents. You may have additional rights under California law.

THE INFORMATION WE COLLECT AND HOW WE USE IT

Contact Information.

In the course of operating the Website, we collect contact information that you provide to us; contact information typically includes your name, email address, phone number, and any information you provide in messages to us. We use such contact information for purposes of providing you access to our client portal and providing you our services.

Cookies; Third-Party Analytics Providers

We may collect information using “cookie” and other similar technologies. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your use. We use both first and third party session cookies and persistent cookies.

We also use one or more third–party analytics services to evaluate your use of the Website, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Website you visit, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website.

Onward Transfer to Third Parties

Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services.

In the event of a merger, dissolution, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This policy shall be binding upon Candlestick and its legal successors in interest.

Disclosure to Public Authorities

We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

HOW WE PROTECT YOUR INFORMATION

Candlestick takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Policy. Accordingly, we implement reasonable security measures designed to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and to comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share your information (as permitted herein), nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet.

CHILDREN

The Website are intended for users 13 years or older; you are not permitted to access or use the Website if you are younger than 13. We do not knowingly collect personal information from children under the age of 13 through the Website. If you are under 13, please do not give us any personal information. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at compliance@candlestickcapital.com, and we will endeavor to delete that information from our databases.

IMPORTANT NOTICE TO ALL NON-US RESIDENTS

Our servers are located in the US and elsewhere. Please be aware that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Website, you do so at your own risk.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the last updated date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By accessing the Website after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

HOW TO CONTACT US

If you have questions about this Privacy Policy, please e-mail us at compliance@candlestickcapital.com with “Privacy Policy” in the subject line.