Privacy & GDPR Policy

Please note that the rights and obligations in this GDPR and EU Cookies Policy will only apply with respect to the personal data of individuals who are in the EU and EU citizens/residents. Any other personal data that is not in scope of the protections of the EU General Data Protection Regulation (“GDPR”) and/or EU Cookies laws, and therefore not subject to this Policy, will be handled in accordance with our standard Privacy Policy and Terms of Use.

GDPR and EU Cookies Policy

IOTC GROUP, and its affiliates (collectively, “IOTC GROUP”, “us” or “we”) respect your privacy as a visitor to the website (the “Site”). It is important for you to understand what information we collect about you during your visit and what we do with that information. Your visit to this Site is subject to this “Privacy Policy” which governs our use of personal information and our Terms of Use. You should review this Privacy Policy carefully, and if you do not agree with these terms, or at any time to any future version of these terms, you must discontinue your use of the Site. For the purposes of EU data protection laws, we are also the data controller.

The Types of Information We Collect About You

When you visit and browse the Site or otherwise interact with IOTC GROUP, we may collect two different types of information about you: information you provide to us, and information that we collect by using “cookies” and other technological means. Please see the Section on “Information We Collect Through Other Means” for further information.

Information You Provide To Us

In order to obtain access to certain information or services provided via the Site, you may have to provide information that we may collect and store in a way that allows us to relate it to you personally, including but not limited to your name, e-mail address, address, phone number, facsimile number and investor status. We refer to such information as personal information. Like many other web sites, we actively collect personal information from our visitors by various means, including asking questions on this Site and permitting you to communicate directly with us via e-mail. If you do not provide us with the required personal information, we may not be able to provide you with the requested services.

Information We Collect Through Other Means

In order to improve this Site, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer, tablet or mobile phone (referred to in this Privacy Policy as a ‘device’) from this Site and is stored on your device’s hard drive.

A cookie records on your device information relating to your internet activity (such as whether you have visited this Site before). The cookies we use on this Site won't collect personal information about you and we won't disclose information stored in cookies that we place on your device to third parties.

If you don't want us to use cookies when you use this Site, you can adjust your internet browser settings not to accept cookies. Your web browser's help function should tell you how to do this. Alternatively, to find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit the website: This website will also explain how you can delete cookies which are already stored on your device. However, without these identifier files you may not have access to many features that may make your browsing of our Site smoother, and some of our services may not function properly.

We currently set the following cookies:

Google Analytics:

We use Google Analytics – the web analytics service provided by Google Inc. - in order to understand how visitors to this Site use this Site. The Google Analytics cookies track activity on this Site and use it in aggregate to optimize your user experience. Google Analytics cookies do not collect personal information about you. Again, you may disable scripts run by Google Analytics to the extent that your browser and associated programs provide such functionality. To opt out of being tracked by Google Analytics across all websites, visit this website:

Session ID:

This is a temporary session cookie used to track whether traffic is logged in or out of this Site. Session ID cookies do not collect personal information about you and are deleted when you close your browser.

How We Use Personal Information

The provision of personal information by you may be necessary for the performance of any contractual relationship with you, for compliance with our legal obligations, or where in our legitimate interest for the following purposes: (i) to contact you and respond to your requests and enquiries; (ii) for business administration, including market research and statistical analysis; (iv) to personalise your visit to the Site and to assist you while you use the Site; (v) to improve the Site by helping us understand who uses the Site; (v) for fraud prevention and detection and to comply with applicable laws, regulations or codes of practice; and (vi) to prevent or detect crime, for quality, training and security purposes. Please note that you have the right to object to processing of your personal information where that processing is carried out for our legitimate interest.

Sharing Personal Information

We may use selected third parties to provide services to us, including companies that provide us with technical support and assistance in respect of the Site, including the third party host of this Site, companies engaged to help gather your information or communicate with you, who may have access to personal information provided to us by you. Our affiliates may also have access to personal information provided to us by you including through or in connection with this Site for the purposes set out in this Privacy Policy, including all the IOTC group of companies. We may also disclose any personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or where we deem necessary, in our sole discretion and in good faith, where we believe that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, to our attorneys, advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or part of our business, whether by merger, acquisition, reorganisation or otherwise.

Protection of Information; No Guarantee of Security

We endeavor to protect your personal information. We use both technical and procedural security methods throughout our organization to maintain the integrity and security of our databases, including firewalls in order to keep personal information confidential, and protect users’ personal information against the loss, misuse, unauthorized access, disclosure or alteration, in accordance with applicable data protection and privacy laws. However, we cannot ensure or warrant the security of any information that users transmit to the Site, and we will not be responsible for or liable in connection with any loss or disclosure of your personal information, other than disclosures that we knowingly make in violation of this Privacy Policy.


We may retain personal information provided by you for a minimum period of 7 years or for as long as necessary to comply with our compliance, legal and regulatory obligations, or to achieve the purposes for which the personal information was collected as described in this Privacy Policy.

International Transfer

When you are based in Europe, personal information collected from you, including via the Site will be transferred to certain recipients located outside Europe, (including the United States where this Site is hosted) which do not provide a similar or adequate level of protection to that provided by countries in Europe. You hereby consent to the transfer of your personal data to recipients as described in this Privacy Policy which are located outside of Europe. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Your Data Privacy Rights

If you are based in Europe, you may have certain data privacy rights which may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification and erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to you, or a third party in a digital format. If you wish to exercise one of the above mentioned rights, please send us your request via email to your relevant Sculptor Capital contact or to the contact details below at “Comments”. Individuals in Europe also have the right to lodge a complaint about the processing of their personal information with their local data protection authority.


This Site may contain links to or from other websites. Please be aware that we are not responsible for the privacy practices of other websites. This Privacy Policy applies only to the information we collect on this Site and not on any third party sites. We encourage you to read the privacy policies of other websites you link to from this Site or otherwise visit.

Changes to this Privacy Policy

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised policy here. We may e-mail you notifying you of any changes to our Privacy Policy, but you should check our Site frequently to see recent changes. Any such changes will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on this Site.


If you have any questions, comments or concerns about our privacy practices, or if you wish to make a request under the “Your Data Privacy Rights” section, please email us at

All requests related to data and information governed by this Privacy Policy will be handled in accordance with applicable data protection and privacy laws.