Privacy Policy
WEBSITE PRIVACY POLICY Hanwha Asset Management (USA) Ltd., together with its affiliated general partner(s) and fund(s) (“Hanwha”, “us”, “our” or “we”), have created this Privacy Policy to explain how we collect, use, store, share and transfer personal data and information (“Personal Data”) we obtain through this website (the “Site”). Investors/clients, employees, contractors and job applicants may receive a separate privacy notice and such separate private notice shall control with respect to personal data collected from such entities or individuals. For the avoidance of doubt, this website privacy policy (the “Privacy Policy”) applies solely to personal data and information, if any, collected by Hanwha through the Site.
When we use the term “Personal Data” in this Privacy Policy, we mean information relating to an identifiable individual person.
Where permitted by law, by using the Site you consent to such use of your Personal Data and agree to the terms of this Privacy Policy.
Depending on where you are located and your interactions with the Site, certain processing of your Personal Data by Hanwha may be subject to data protection and privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). For example, this may be the case where Hanwha processes the Personal Data of users of the Site who reside in California (the “CCPA Processing”). Currently however, Hanwha is not subject to the CCPA.
PERSONAL DATA WE COLLECT We collect Personal Data from the Site when you enter your contact information into the contact form and/or when you sign up for any events on/through our Site. Currently, this information includes:
(1) Identifiers, such as your name as well as contact details, including email address; and
(2) Information about your communications with us, including the Personal Data you provide to us via the email listed in the Site or the contact form provided on the home page of the Site, or in communications with our employees and personnel after we have received your communications with us through the Site or via email.
The Personal Data collected from this Site may change at any time without notice.
If you provide Personal Data about any person other than yourself, you must ensure they understand how their Personal Data will be used and that they have given their permission for you to disclose the Personal Data to us and our outsourced service providers to use.
INFORMATION WE COLLECT AUTOMATICALLY THROUGH OUR SITE We may automatically collect certain Personal Data including internet and other electronic activity information to help us understand how you use the Site (which we will refer to in this Privacy Policy collectively as “Usage Data”). For example, each time you visit the Site, we may automatically collect your IP address, browser and computer or device type, access time, the webpage from which you came and the webpage(s) that you access during your visit. We may combine Usage Data with other Personal Data in a manner that enables us to trace Usage Data to an individual user. Some web browsers may have “do not track” settings, however, the Site does not honor “do not track” settings.
COOKIES We may use cookies (which are small amounts of data sent from a web server to your browser that are stored on your computer’s hard drive) to keep track of your use of the Site, to validate your identity, to tailor the Site to your account and to meet your interests and to improve the quality of the Site. Generally, you can set your browser not to accept cookies or to notify you if you are sent a cookie, giving you the opportunity to choose whether or not to accept the cookie. Please note that if you do set your browser not to accept cookies, the Site may not function properly. We may use analytics to understand Site traffic.
CHILDREN This Site is not targeted to minors.
OUR USE OF PERSONAL DATA We currently use your personal data for the following purposes: (1) verifying your identity; (2) communicating with you in relation to your inquiries; (3) where necessary to comply with a legal obligation or in connection with legal claims and for compliance, regulatory, or investigatory purposes; (4) monitoring use of our Sites and using Personal Data to help us improve and protect the Site; or (5) where necessary for Hanwha’s or another party’s legitimate interests.
We may use your personal data in the future for: (6) promoting our services to clients, potential clients, and advising you of news or industry updates; (7) sending your direct marketing via email in relation to our services; and (8) to provide services to customers or investors.
OUR PERSONAL DATA SHARING PRACTICES We may employ other companies and individuals to perform functions on our behalf, such as for analyzing data and providing certain features of the Site. To the extent necessary to perform their functions, these third-party service providers will have access to Personal Data. Personal Data is not shared with any unaffiliated third parties for their marketing purposes unless we have obtained your consent to do so in accordance with applicable law.
We may share Personal Data with third parties: (1) in response to subpoenas, court orders, regulatory requests or legal process, or to establish, protect or exercise our legal rights and interests or to defend against legal claims; (2) if we believe it is necessary in order to investigate, prevent or take action regarding inappropriate or illegal activities, fraud or situations involving potential threats to the safety of any person or property; (3) if we believe it is necessary to investigate, prevent or take action regarding inappropriate use of the Site; (4) to our parent company, subsidiaries, joint ventures or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy); and (5) as part of a corporate transaction with a successor or affiliate or in connected with any acquisition, merger or sale of assets.
YOUR RIGHTS Individuals in a number of jurisdictions may have certain rights in relation to their Personal Data. These rights vary, but they may include the right to: (1) request access to and rectification or erasure of their Personal Data; (2) restrict or object to the processing of their Personal Data; and (3) obtain a copy of their Personal Data in a portable format. Individuals may also have the right to lodge a complaint about Hanwha’s processing of their Personal Data with an applicable data protection authority. The rights described herein are not absolute and may not be applicable to you. We reserve all of our rights available to us at law in this regard. If you wish to exercise any of the rights described in this Your Rights section, please contact us via the contact form located on the home page of the Site.
CALIFORNIA SHINE THE LIGHT DISCLOSURE Currently, we do not serve natural person customers. We also do not share personal information collected from the Site with other companies for direct marketing use.
SEC REGULATIONS S-P, S-AM AND THE GRAMM-LEACH-BLILEY ACT The US Securities and Exchange Commission has adopted rules that require financial institutions, like Hanwha, to provide privacy policy notices to their natural person customers. Currently, we do not serve natural person customers, however, to the extent you are a natural person who invests with us, the privacy notice provided to you (which is a separate policy from this Privacy Policy) will govern how we use your Personal Data for the purposes specified in that notice.
SECURITY While we strive to protect Personal Data, we cannot guarantee its security.
LINKS The Site may contain links to other websites. We are not responsible for the privacy practices of any other website (whether accessed through a link or otherwise) and urge you to review such practices prior to submitting any information or Personal Data to such websites.
CHANGES We may update this Privacy Policy from time to time in our sole discretion and encourage visitors to review this page frequently for any changes. Any updated version of this Privacy Policy will be effective as of the date set forth therein. By continuing to use the Site after such updates, you expressly agree to the terms of the updated Privacy Policy.
QUESTIONS Any questions, concerns or complaints regarding this Privacy Policy should be sent via the contact form on the Site or the email address listed therein. Please note that there is no guarantee that you will receive a response or a response that is satisfactory to you.
Effective Date: August 15, 2025