Online Privacy Policy

BEACH POINT CAPITAL MANAGEMENT LP

ONLINE PRIVACY POLICY

This online privacy policy (the “Online Privacy Policy”) describes the policies and procedures followed by Beach Point Capital Management LP and its affiliates (“Beach Point”, “we”, “us” or “our”) regarding the collection, use and disclosure of your personal information when you visit our website or otherwise interact with Beach Point. In our use of personal information, Beach Point is characterized as a “business” or “data controller” (i.e., the company responsible for, and which controls the processing of, your personal information) under various legal regimes. Beach Point’s affiliates and delegates may act as “data processors” or “service providers.” Please note that when using our website, this Online Privacy Policy should be read in conjunction with our Terms and Conditions. This Online Privacy Policy applies to all natural persons who are not subject to either our Gramm-Leach-Bliley Act (GLBA) investor privacy notice or our employee privacy notice.

Notice of Collection and Use of Personal Information

Personal Information We Collect About You. When you contact us using our contact details on our website, any personal information you provide to us will be collected and processed by us. You are not under any obligation to provide any of this information. However, if you withhold requested information, we may not be able to contact you or provide certain services to you. We may collect the following categories and examples of personal information.

Identifiers: Identifiers such as your name, alias, email address, other contact information, account name, social security number, driver’s license number, and state identification card number.
Protected classifications: Information classified as personal or protected information by state, federal or other applicable law, including your nationality, place and date of birth, age, sex, gender, marital status, citizenship status, information on criminal history/unlawful conduct and correspondence records.
Commercial information: Records of products or services purchased, obtained, or considered.
Professional information: Professional or employment-related information, such as employer’s name, job title, and income.
Education information: Education information, including your level of education.
Internet or other electronic network activity information: Information such as data regarding a consumer’s interaction with a website, application, or advertisement.
Inferences: Inferences that we draw from your personal information in connection with a determination as to your suitability to make an investment, your capacity to evaluate the merits and risks of investments and your qualification to make an investment according to the terms of such investment.

Sensitive Personal Information. Beach Point may collect personal information that is also considered sensitive personal information under certain laws, such as the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”). That information may include social security, driver’s license, and passport numbers; medical or health-related data; and information about racial or ethnic origin, sex, or sexual orientation. Beach Point uses sensitive personal information for lawful purposes in compliance with the CCPA/CPRA and does not use sensitive personal information to infer characteristics about individuals.

How We Collect Your Personal Information. We collect personal information in various ways. For example, you may directly provide us with personal information, such as within the forms and any associated documentation that you complete and submit. We may also obtain personal information about you from third parties, such as our vendors (e.g., background check providers), advisors and other business partners. We automatically collect basic technical information from all visitors to our website through our automatic data collection tools, which may include cookies and other commonly used technologies (see the section on Cookies below). These tools collect certain standard information that your browser sends to our website such as your browser type and language, access times, and the address of the site from which you came to our website. The data collection tools may also collect information about your Internet Protocol (“IP”) address, or clickstream data within our website (i.e., the actions taken in connection with our website). This information helps us improve the functionality of our website.

Business or Commercial Purposes for Collecting Personal Information. We may use the personal information you give us to carry out the following purposes.

Purpose	Lawful Basis
To contact you and to respond to your requests and inquiries	We have a legitimate interest to respond to your requests and inquiries for ongoing business administration
To deliver services to you	To manage and perform our agreement to provide services to you
For recruitment purposes	We have a legitimate interest to consider an applicant for a role or vacancy in accordance with our recruitment process
To improve our website by helping us understand who uses our website	We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient
For fraud prevention and detection and to comply with applicable laws, regulations or codes of practice	To comply with our legal obligations

Please note that individuals in certain jurisdictions may have a right to object to the processing of their personal information.

Disclosing Your Personal Information. We may use third parties as service providers, including companies that provide us with technical support and assistance in connection with the operation of our website, accountants, auditors, lawyers, or other outside professional advisors to Beach Point. All service providers are permitted to use data only for the purpose of performing services on our behalf in compliance with the privacy practices and policies of Beach Point. Our affiliates, acting as service providers, may also have access to personal information provided to us by you, including through or in connection with our website for the purposes set out in this Online Privacy Policy. Similarly, we may disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to advisers, law enforcement agencies, and judicial or 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 a part of our business, whether by merger, acquisition, reorganization or otherwise.

Sale and Sharing of Personal Information. We do not sell any personal information and have not sold any personal information in the past 12 months. Additionally, we do not share personal information for purposes of cross-context behavioral advertising and have not done so in the past 12 months.

Security and Retention. Beach Point uses various appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure or access. While these methods are considered to be effective, Beach Point does not guarantee the protection of your personal information as no data transmission over the Internet can be guaranteed to be completely confidential or 100% secure. You use our website and provide all such personal information at your own risk.

Beach Point retains personal information for as long as necessary to fulfill the purposes for which such personal information was collected or to comply with its legal obligations, resolve disputes, or enforce agreements. The criteria used to determine the retention periods include: (i) how long personal information is needed to provide services and operate our business; (ii) the type of personal information collected; and (iii) whether Beach Point is subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

Data Transfers

Given the global nature of Beach Point’s activities, if you are located in the European Economic Area (the “EEA”), personal information collected from you, including via our website, may be transferred to recipients including other Beach Point entities in countries located outside the EEA, including the U.S., which are not considered by the European Commission to provide an adequate level of data protection. You hereby expressly consent to the transfer of your personal information to recipients (including Beach Point), as described in this Online Privacy Policy, which are located outside of the EEA. 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.

Beach Point has entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal information. You can request a copy of these Model Contracts by submitting your request via email to info@beachpointcapital.com.

Cookies

This website uses “cookies,” which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of our website. We believe our use of cookies is limited to only what is necessary for the operation of our website. Cookies also help us diagnose problems with our server and our website. If you do not want us to use cookies when you use our website, you can adjust your internet browser settings not to accept cookies. Your web browser’s help function should tell you how to do this. Please visit the relevant link below for the internet browser which you use:

Below is a list of cookies that may be used on the website.

Cookie Name	Description of Purpose	Persistent or session cookie	1st party or 3rd party cookie
.CookieConsent	Enables Cookie Consent	Session (366 Days)	3rd party
			GoDaddy Cookies

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: http://www.allaboutcookies.org. This website will also explain how you can delete cookies that 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 website smoother, and some of our services may not function properly.

Links to Other Websites

Our website may contain links to other websites. Beach Point is not responsible for the privacy practices or the content of other websites. This Online Privacy Policy applies only to the information we collect through our website. We encourage you to read the privacy statements of all of the destination websites which you visit.

Revisions to Our Online Privacy Policy

We evaluate our privacy policies and procedures to implement improvements and refinements from time to time. If we make any material changes to this Online Privacy Policy, we will notify you by means of a prominent notice on the website prior to the change becoming effective. We will also post an updated version on our website. Please check our website periodically for updates.

Your Privacy Rights

Individuals in Andorra, Argentina, Australia, California, Canada, Cayman Islands, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right for individuals to:

Know what personal information we collect, including (1) the right to request information regarding the categories of personal information we collect along with other details such as the categories of sources from which the information is collected and third parties with whom it is shared and (2) the right to request a copy of the specific pieces of personal information we collect (also referred to as the right to access personal information);
Delete personal information that we collect from you, subject to certain exceptions;
Correct inaccurate personal information that we maintain about you;
Opt-out of the sale or sharing of personal information—since we do not sell or share personal information, as those terms are defined under the CCPA/CPRA, you are already opted-out;
Opt-out of certain uses of sensitive personal information; and
Lodge a complaint about the processing of personal data with a data protection authority.

California Disclosures

In the preceding 12 months, we have collected and used personal information in the manner described above in the section “Notice of Collection and Use of Personal Information” and subsequent subsections. We may have disclosed to third parties for our business purposes all of the categories of personal information as described above in that section.

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties for their direct marketing to you without your consent.

Exercising Your Rights

Depending on your jurisdiction, you may also be entitled to direct any complaints in relation to our processing of your personal information to your national or local data protection supervisory authority.

If you are making a request for access, we may not be able to provide specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your personal information, your account with us, or our systems or networks.

Individuals who submit requests for access or deletion of personal information will be required to verify their identity by answering certain questions. We will not disclose or delete any information until such individual’s identity is verified.

If you are making a request for deletion, we will ask that you confirm that you would like us to delete your personal information again before your request is submitted. In certain circumstances, we may not delete all personal information, as permitted by applicable law, regulation, court order or similar obligation to retain the data (e.g., government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.

Agents who make requests on behalf of individuals will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.

If you wish to exercise any of the abovementioned rights you may email your request to info@beachpointcapital.com.

Non-Discrimination and No Retaliation

We will not discriminate or retaliate against you based on the exercise of your privacy rights.

Questions and Comments

If you have any questions or comments about our Online Privacy Policy or, if you would like to exercise your data subject rights, please feel free to contact us at info@beachpointcapital.com.