Privacy Policy

Harbor Point Equipment Finance Privacy Policy October 16, 2024

Privacy Policy

I. Who Are We?

Harbor Point Equipment Finance (“Harbor Point”) is a global alternative investment manager focused on opportunities in commercial aviation.
Harbor Point believes its unique investment strategy, relationships, and hands-on approach enable it to generate attractive risk-adjusted returns for its clients across market cycles.

With offices in Stamford, Dublin, and Singapore, Harbor Point maintains a global footprint and is supported by professionals across finance, technical, legal, risk management, and underwriting functions.

If you have any questions or comments about this Privacy Policy or our practices, or if you wish to make a request regarding your Personal Information, please contact us:

Harbor Point Equipment Finance LLC
750 Washington Blvd, Suite 500
Stamford, CT 06901
+1 203-487-8200
customer.service@harborpointef.com

II. What Is Covered By This Privacy Policy?

This Privacy Policy describes Harbor Point Equipment Finance LLC’s policies and practices regarding its collection and use of your personal data and explains your privacy rights.

This Privacy Policy applies to both:

  • our online information gathering and dissemination practices in connection with this website and its pages (the “Site”); and
  • personal information we collect or receive offline, whether directly from you or from other sources.

If you arrive at this Privacy Policy by clicking a link on our Site, or by searching for or clicking on a link directing you to any page of our Site, then this Privacy Policy applies to you.
By using the Site, you consent to the use of your information in the manner described in this Privacy Policy.

This Privacy Policy may change periodically as we adopt new privacy practices or policies, so please check back from time to time.
Your continued use of the Site constitutes acceptance of the revised policy.

Use of our Site is strictly limited to persons who are of legal age in the jurisdictions in which they reside.
You must be at least sixteen (16) years of age to use our Site.
If you are not at least 16 years of age, please do not use the Site or provide any information through it.

This Privacy Policy does not apply to any website owned or operated by or on behalf of any other entity, including our portfolio companies, even if our Site includes links to those websites.
If you visit or disclose information through other websites, you are subject to the privacy policies and practices of those sites.

III. What Personal Information Do We Collect, From Where, and Why?

The following describes:

  1. the categories of Personal Information we may have collected in the preceding 12 months, whether offline or online;
  2. the sources from which we may have collected it; and
  3. the business purposes for which we may have collected it.

A. Information We Do Not Knowingly Collect

We do not knowingly solicit, collect, or receive information from or about minors under the age of eighteen (18).

B. Information You Provide to Us Directly

You may voluntarily submit or otherwise disclose Personal Information to us, including your:

  • name,
  • email address,
  • mailing address,
  • resumé,
  • phone number,
  • contact type (such as investor or employment candidate), and
  • a personalized message regarding your inquiry.

You may provide this information through the “Contact Us” page on our Site, or by mail, email, telephone, fax, or other electronic means.

If you contact or correspond with us, we may keep a record of your contact information and correspondence, whether oral or written.
We may use your contact information and any other information you provide to respond to your inquiry, provide customer service, and attempt to resolve your request.

If you wish to change or correct any information you have voluntarily submitted to us, please contact us using the methods described above.

C. Information We Receive from Third Parties During Due Diligence

We may receive Personal Information from third-party entities in which we are considering making an investment, as part of our due diligence process.
Any such information is shared confidentially for the purpose of analyzing a potential investment and is subject to a nondisclosure agreement that limits further disclosure or use for any other purpose.

D. Information Automatically Collected Through Use of the Site

Like most websites, our Site automatically collects certain information during a user’s visit.
This information may include:

  • IP address,
  • device location used to access the internet,
  • browser type,
  • operating system, and
  • information about Site usage, including browsing history and pages viewed.

We use this information to improve the Site’s design, estimate usage patterns, speed up searches, improve user experience, diagnose server problems, administer the Site, analyze trends, track visitor movements, and gather broad demographic information about visitor preferences.

(i) IP Address

Each time you visit our Site, we may automatically collect your internet protocol (IP) address and the web page from which you came.
We may use IP addresses to administer and optimize the Site, identify users, gather broad demographic information, and diagnose or resolve technical or security issues.

(ii) Cookies, Pixel Tags, and Web Beacons

Cookies (browser or flash) are small files that a site or service provider transfers to your device through your web browser, if allowed, that enable the site’s or provider’s systems to recognize your browser and remember certain information.

We use cookies to optimize Site functionality and improve your experience while navigating the Site.
Most browsers allow you to disable or reject cookies through browser settings.
You may also use the “Privacy Policy” banner at the bottom of the Site to adjust cookie settings and accept or reject certain cookies.

Our Site may also use pixel tags, web beacons, or similar tracking technologies (“pixel tags”) to collect information such as:

  • internet service provider,
  • IP address,
  • browser type,
  • operating system,
  • date and time of access,
  • referring website address, and
  • destination website address after leaving our Site.

We may aggregate this information across users to help improve the Site and the services we provide.

(iii) Do Not Track

Our Site tracks when visitors enter through a marketing landing page.
The Site also records third-party websites accessed when a user clicks a hyperlink from our Site.
We do not track users across subsequent websites and do not serve them targeted advertising.

(iv) Analytics Information

Web servers for the Site may collect anonymous navigational information about where visitors go on our Site and information about the technical performance of our Site and services.
Anonymous information does not directly or indirectly identify, and cannot reasonably be used to identify, a particular individual.
Examples include browser data, domain type, service provider, and IP address.

We use anonymous analytics to operate, maintain, and improve Site features and functionality.

We use Google Analytics (“GA”) for aggregated, anonymized website traffic analysis.
To track session usage, Google places a cookie (_ga) with a randomly generated ClientID in a user’s browser.
This ID is anonymized and contains no identifiable information such as name, email address, or phone number.
We also send IP addresses to Google.
We use GA to understand aggregated website behavior, such as which pages users visit and how long they stay on them.
This helps us improve the user experience and measure Site effectiveness.

You may delete your _ga cookies and/or install the Google Analytics Opt-Out Browser Add-On.

IV. What Personal Information Do We Share With Others?

A. We Do Not Sell Personal Information to Third Parties for Their Own Use

Harbor Point Equipment Finance LLC does not sell your Personal Information to third parties for their own use.
Except as described in this Privacy Policy, we do not disclose information about your visits to our Site to third parties.

Accordingly, there have been no sales of Personal Information to third parties for their own use or further disclosure during the preceding twelve (12) months.
Harbor Point Equipment Finance LLC does not knowingly collect, and does not and will not sell, the Personal Information of minors under 16 years of age without first obtaining affirmative authorization.

B. Sharing Information with Service Providers

In connection with providing business services to Harbor Point Equipment Finance LLC, one or more of our service providers may have access to your Personal Information.
These service providers may include:

  • outside legal professionals,
  • accounting professionals,
  • data analytics providers,
  • service or security providers, and
  • technology support companies.

We restrict our service providers from accessing or using your Personal Information for any purpose other than as reasonably necessary to perform the authorized business purpose in their contracts.
Your Personal Information will not be further used or disclosed by our service providers beyond those purposes.

C. Sharing Personal Information at Your Direction

We may share your Personal Information with third parties whom you authorize us in advance to disclose it to or allow to use it in connection with the services we provide.

D. Sale of Our Company or Company Assets

In the event of a sale, assignment, liquidation, or transfer of our assets or any portion of our business, we reserve the right to transfer information we collect from individuals, or otherwise collect in connection with use of the Site, to unaffiliated third-party purchasers.

E. Monitoring, Law Enforcement, and Legal Requests

Harbor Point Equipment Finance LLC reserves the right, at all times, to monitor, review, retain, and disclose any information, including non-public Personal Information, as necessary to satisfy applicable law, regulation, legal process, or governmental request, or to cooperate with law enforcement and other authorities.

We may also use such Personal Information if required to investigate fraud internally or when necessary to protect the Site, the company, or others.

F. Our Internal Use and Research

Harbor Point Equipment Finance LLC reserves the right to use and disclose de-identified, anonymized, aggregated, or publicly available information that has not been combined with nonpublic Personal Information for any lawful purpose, including internal use, data mining, analytics, and research.

V. How Do We Protect Personal Information?

We take reasonable security procedures and practices appropriate to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
We maintain physical, electronic, and procedural safeguards designed to protect against unauthorized disclosure of Personal Information, and we dispose of Personal Information properly and securely using industry standards.
Our data security policies and practices are periodically reviewed and modified as necessary.

VI. Additional Information for California Residents

The information below applies to California residents.

A. Your Rights Under the California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”), effective January 1, 2020, grants privacy rights to California consumers in connection with their Personal Information.
“Personal Information” or “PI” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

A California consumer has the following rights with respect to PI:

  • the right to know what PI is collected, used, shared, or sold;
  • the right to access PI collected and retained by the business;
  • the right to request deletion of PI, subject to certain exceptions;
  • the right to opt out of the sale of PI; and
  • the right to non-discrimination for exercising privacy rights under the CCPA.

B. Consumer Right to Notice of Collection

A business subject to the CCPA must, at or before the point of collection, inform consumers of the categories of PI to be collected and the purposes for which it will be used.
A service provider collecting PI on behalf of a covered business may not be required to provide its own notice of collection.

C. Consumer Right to Know

A covered business must disclose in its privacy policy the PI it has collected, sold, or disclosed for a business purpose in the past 12 months.
In response to a verifiable request, a business must disclose:

  • the categories of PI collected about the consumer;
  • the categories of sources from which that PI was collected;
  • the business or commercial purpose for collecting or selling PI;
  • the categories of third parties with which the business shares PI; and
  • the specific pieces of PI collected about the requesting consumer.

If a business sells PI or discloses it for a business purpose, it must also disclose:

  • the categories of PI collected about the individual consumer;
  • the categories of PI sold about the individual consumer and the categories of third parties to whom it was sold, or state that no sale occurred; and
  • the categories of PI disclosed for a business purpose, or state that no such disclosure occurred.

D. Consumer Right to Delete

A California consumer has the right to request that a covered business delete his or her PI, subject to certain exceptions.
Once a request is reasonably verified, the requested PI must be removed from the business’s records, and the business must direct its service providers to delete the information unless an exception applies.

A request to delete may be denied if retaining the information is necessary to:

  1. complete the transaction for which the PI was collected or provide a requested good or service;
  2. detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity;
  3. debug products and repair errors impairing intended functionality;
  4. exercise free speech or ensure another consumer’s right to exercise free speech;
  5. comply with the California Electronic Communications Privacy Act;
  6. engage in certain public-interest scientific, historical, or statistical research;
  7. enable internal uses reasonably aligned with consumer expectations;
  8. comply with a legal obligation; or
  9. make other internal and lawful uses compatible with the context in which the consumer provided the information.

E. Consumer Right to Non-Discrimination

A business must not discriminate against a consumer for exercising CCPA rights.
A business may charge different prices or provide different levels of service only if the difference is reasonably related to the value provided by the consumer’s data.
A business may also offer financial incentives for the collection, sale, or deletion of personal information on an opt-in basis.

F. Consumer Right to Opt Out

A covered business that sells PI to third parties must provide notice and clearly inform consumers of their right to opt out of the sale.
Such a business must also provide a “Do Not Sell My Personal Information” link on its homepage.

A business may not sell the PI of a consumer under 16 years of age unless:

  • the consumer between 13 and 16 years of age has affirmatively authorized the sale; or
  • for a child under 13, the child’s parent or guardian has affirmatively authorized the sale.

G. Privacy Policy Requirements

A covered business must include the following in its online privacy policy, updated every 12 months:

  1. a description of consumer CCPA rights, including the right to opt out of the sale of PI and, if applicable, a separate link to a “Do Not Sell My Personal Information” webpage;
  2. the method or methods by which a CCPA request may be submitted; and
  3. a list of the categories of PI the business has collected, sold, or disclosed for a business purpose in the preceding 12 months.

VII. How Do I Make a CCPA Request?

A. Instructions for Submitting a Request

If you are a California consumer and wish to make a CCPA request to Harbor Point Equipment Finance LLC, you may submit your request using one of the following methods:

We will confirm receipt of your request within 10 days.
The confirmation will include a ticket number, information about how we will process and verify your request, and when you should expect a response.

We are only required to respond to a request to know for access or data portability twice in any 12-month period.
We are also required to keep records of your CCPA request for at least 24 months, including:

  • assigned ticket number,
  • request date and nature,
  • manner in which the request was made,
  • date and nature of our response, and
  • the basis for any denial, in whole or in part.

B. Verification of Your CCPA Request

We must be reasonably certain that the person making the request is you or a representative authorized to act on your behalf.
We cannot respond to your request or provide PI unless we can verify your identity or authority.

When you submit your request, we may ask for certain information, such as your full name, date of birth, and address, in order to verify your identity or your authority to act on behalf of another person.
To the extent possible, we will use the information you provide to cross-check existing records rather than requesting new PI.

If we must collect new PI for verification purposes, we will delete that information as soon as practical after processing your request, except where retention is required by law.
You are not required to create an account with us to verify your request.
We will only use the information you provide for verification purposes.

Certain requests require different levels of verification depending on the sensitivity of the information involved.
For example, if you request the specific pieces of PI we hold, rather than just categories, we may require a written declaration under penalty of perjury confirming that you are the consumer whose PI is the subject of the request.

Certain information, such as a Social Security number, driver’s license number, other government-issued identification number, or financial account information, will not be disclosed in response to a CCPA request.

If you wish to authorize someone else to act on your behalf, we must receive proof of that authority.
Proof may include:

  • written authorization from you after verifying your identity directly with us;
  • a power of attorney or other legal document establishing authority; or
  • proof of registration with the California Secretary of State as a representative authorized to act for another consumer.

You may also make a verifiable consumer request on behalf of your minor child.

C. Our Response to Your CCPA Request

Within 10 days of receiving your CCPA request, we will provide an initial confirmation of receipt with an assigned ticket number by email or U.S. mail.
If you submit a Request to Delete, we must re-confirm your choice to delete the specified information after your request has been verified and before the data is deleted.

Harbor Point Equipment Finance LLC strives to respond to a verifiable consumer request within 45 days of receipt, regardless of the time required for verification.
If we need additional time, we will inform you of the reason.

We will send our response by U.S. mail or email, at your option.
Any information we provide will cover only the 12-month period preceding receipt of your request.
If we cannot comply with your Request to Know or Request to Delete, such as because we cannot verify your identity or because an exception applies, we will explain our reasoning in our response.

We do not charge a fee to process or respond to your request unless the request is excessive, repetitive, or manifestly unfounded.
If we determine that a charge is warranted, we will explain the reason in writing and provide a cost estimate before completing your request.

VIII. How Do I Contact Harbor Point Equipment Finance Regarding Pending Requests?

If you have any questions about a pending CCPA request, please contact us and provide your ticket number:

Call us at: +1 203-604-2430
Email us at: customer.service@harborpointef.com