Effective Date: December 2017. Last Updated: June 2023
Fortress Investment Group LLC and its affiliates (collectively “Fortress”) has drafted this Privacy Statement to help you understand what personal information we collect on you, how we use such information and the rights and choices you have with regard to such information. This statement applies to information we collect when you interact with us on the websites where it appears.
This Privacy Statement does not apply to our use of information at times when we provide you with another privacy statement. This includes our privacy notice for our investors. It also does not apply to our use of employee information. Job applicants from California can read our Privacy Notice for California Job Applicants. Job applicants from the European Union or the United Kingdom can read our GDPR Candidate Privacy Notice.
Please read this Privacy Statement carefully. In the event that you have any questions or concerns about the guidelines set forth in this Privacy Statement, please contact us as set out at the end of this Statement.
Notice At Collection
Categories of information we may collect about you are provided below.
What Information Do We Collect About You?
Contact information. We may collect your name and email address. We may also collect your mailing address or phone number.
Device and Site Usage Information. We collect general information about the browser and devices you use to access our website and services. This might include the operating system, IP address, and hardware version (such as make, model, operating system, IP address, and browser type) and information about your online behavior. We may also collect information about your Site usage and any errors you may experience. We also collect information about the sites you came from and where you visit when you leave us. We also look at the areas of our site you visit and any actions you make.
Identity verification information. In connection with verifying potential transaction counterparties we may have them complete a “Know Your Customer” form. Information collected on that form includes identification information (drivers’ license or passport numbers). It also may include wire transfer information such as financial account information.
Job applicant information. If you voluntarily decide to submit a job application on our website we will collect job-related information about you. This includes education information and job history.
How Do We Use Your Personal Information?
When it is necessary to process your personal information, Fortress will do so:
- for legitimate business purposes: this may include customizing your experience with us and presenting content in an effective way for your device. We will also use your information to improve our platforms and services. This includes learning how to best tailor our website for our current and future visitors.
- to fulfill our contractual obligations to you: this includes facilitating the creation and maintenance of accounts you have with us.
- to comply with legal or regulatory obligations imposed on us: this includes for security purposes and to help avoid fraud or to protect the company or its constituents;
- to communicate with you about your account or our relationship: This includes sending you information related to your account. It may also include requests for feedback or to manage complaints. We also use your information to respond to your questions and requests. This might include troubleshooting issues you have with our platform or services; and/or
- when legally required, after consent is obtained from you.
Our use of sensitive information: We do not use or disclose sensitive information, as that term is defined in California, for inferring characteristics or for purposes other than those permitted by law.
More information about our privacy practices
For more information about our privacy practice, please read the rest of our Privacy Statement, below.
How We Share Information
We may share some of the personal information we collect about you with our affiliates or third-party entities:
- (i) as part of our normal business operations (such as processing your requests for forms or other literature or information, transactions, to enable you to access our services, or to prepare investor disclosure materials, or disclosing within our family of companies);
- (ii) to send you administrative communications either about your interactions with us or about features of our website, including any future changes to this Privacy Statement; or
- (iii) as otherwise permitted by law.
We may also share your personal information with a select group of third-party service providers, vendors, and advisors that carry out certain functions on our behalf. The categories of service provider that we use include companies that: deliver products or services, like a shipping company that delivers a package; improve the functionality of our website; provide analytic services; or help to gather your information or communicate with you. These companies are allowed to gather, receive, and use your information only for the purposes described in this Privacy Statement or as required by law.
We may also disclose your personal information when:
- (a) such disclosure is required by law, court of law, or as requested by any governmental, self-regulatory organization or law enforcement authority;
- (b) to the extent necessary for a reorganization, restructuring, merger, acquisition or transfer of assets related to our business; or
- (c) doing so will help to: enforce our Terms of Use; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of our websites, databases, and/or third parties, including the safety and security of tangible and/or intangible property that belongs to us or to third parties.
Where Do We Store Your information?
The entities with which we might share your personal information may be located outside of the jurisdiction in which the personal information was collected. Where required, we have put in place appropriate safeguards designed to make sure your personal information remains adequately protected when transferred internationally. For instance, the transfer of personal information out of the European Economic Area (including to the UK) or the UK, each to third countries that have not been granted an adequacy decision by the European Commission, will be made pursuant to a valid data transfer mechanism under applicable data protection laws, including on the terms of the European Commission standard contractual clauses.
You may ask for further information on the safeguards that we have put in place, where required, for the transfer of your data outside of the jurisdiction in which it was collected by contacting us as indicated in the “How To Contact Us” section below.
How Long Do We Keep Your Personal Information?
We will retain your personal information for the amount of time necessary to accomplish the purpose for which it was collected or as otherwise permitted by law. We will also retain personal information that could be relevant to legal proceedings or must otherwise be retained under applicable law or regulations for longer periods.
Sources of Personal Information Collected
We obtain the categories of personal information listed above from the following sources:
Directly from you.
We collect information directly from you when you complete our Restricted Party Screening Form. We may also collect your information if you submit a request on our website.
Passively.
We collect information about users over time and across different websites and apps. We also work with third-parties that collect personal information this way. We may use several common tracking tools to collect information. Tracking tools include browser cookies and web beacons. To learn more about cookies visit the FTC’s Online Tracking page. We may work with others to gather information on our platforms and elsewhere. We may do this on our websites and in emails that we send to you.
We use cookies to distinguish you from other users of our website. This helps us to ensure that you have an optimal experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them please see the “Your Rights and Choices” section below.
From others.
Business partners and our affiliates may provide information about you to us. This might include
your agent or a financial intermediary. It might also include risk management databases.
We Combine Information.
We may combine information that we have collected offline with information that we collect online as permitted by law. We combine information collected across devices, such as computers and mobile devices. We also combine information that we get from a third-party with information we already have.
What Are the Legal Reasons We Use Your Information?
If you are in the UK or the EU, we are required to tell you our “legal basis” for processing your information. Typically we use your information to perform our contract with you. We will also use your sensitive information and process certain cookies with your consent. We use personal information in some circumstances for legal compliance. This includes responding to court orders.
How Do We Protect Your Personal Information?
We use reasonable security measures to protect your personal information. No website is 100% secure, however. We cannot promise that your use of our sites or apps will be completely safe. We encourage you to use caution when using the internet. This includes not sharing your passwords.
Third Party Sites and Tools
We may link to other parties’ tools. This might include their websites or apps. These third parties have their own privacy policies. You should read those before using or sharing personal information with them. This statement does not apply to third party practices. We do not control third parties’ privacy practices.
Your Rights and Choices
You may have certain rights over our use of your information. These rights depend on where you are located or how you have interacted with us. They include:
Cookies and Tracking Tools
We collect personal information about users over time and across different websites when you use our platforms. We also have third parties that collect personal information this way. To do this, we use several common tracking tools. These may include browser cookies. We may also use web beacons, flash cookies, and similar technologies. We use a variety of cookies, these may include:
- Strictly necessary cookies: These cookies are essential in order to enable you to move around the website and use its features, and ensuring the security of your online transactions with us and online access to our website. These cookies do not gather information about you for the purposes of marketing.
- Performance cookies: These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages.
- Third Party cookies: These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.
- Functionality cookies: These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign.
- Analytics and Research cookies: These cookies allow the website to learn which of its services are most often used. This helps us to determine what to improve, what to remove and what to leave the same.
- Authentication cookies: These cookies help the website determine if a user is logged in, and then deliver the right experience and features to that unique user.
- Security cookies: These cookies help the website to impose security measures. They also help detect unusual and suspicious activities.
You can manage cookies in your web browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you will not have access to many features that may make your browsing of our website smoother and some of our services may not function properly. Options you make are browser and device specific.
Our Do Not Track Policy
Do Not Track is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated Do Not Track signals. Third-parties, such as our analytics providers (such as those of Google Analytics), may collect data that relates to you on our Site. We cannot control third-parties’ responses to Do Not Track signals. Third-parties’ responsiveness to Do Not Track signals is governed by their respective privacy policies. Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application. You can learn more about Do Not Track here.
Specific Rights in Certain Jurisdictions
If you live in the EU, the UK, California, or jurisdictions with similar laws, you may have additional rights, depending on your relationship with us. These rights may include (subject to certain limitations) to confirm that Fortress is processing your personal information, to access the personal information we keep about you, to restrict or object to the processing of your personal information, or to rectify, erase, and port your personal information. Those rights are:
- Access and Portability: You have the right to obtain confirmation that we process your personal information and access to the personal information we have about you. In response to a verified request, we will provide:
-
- (1) the categories and specific pieces of personal information we have collected about you;
- (2) the categories of sources from which the personal information about you was collected;
- (3) the business or commercial purpose for which we collect or sell your personal information;
- (4) the categories of third parties with whom we share your personal information; and
- (5) the categories of personal information that we disclosed about you for a business or commercial purpose. EU and UK residents can ask us to move their information to a third party.
- Rectification: You have the right to have inaccurate personal information rectified.
- Erasure: You have the right to request that we delete your personal information. Please note that in certain instances we may not be able to process your request, such as (i) due to the existence of a legal obligation, (ii) to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, or (iii) in order to complete a transaction for which your personal information was collected.
- Restrict or Object to Processing: UK and EU residents, as an alternative to requesting the erasure of your personal information, you have the right to limit the way we use your personal information in certain circumstances. In some cases you also have the right to object to how we process information.
How it Works
To exercise your rights submit your request here, or you can contact us as follows: DSR@fortress.com, or call 1-833-459-0090. For verification purposes, we may request your first and last name, email address or physical address you may have used when interacting with us. We may also ask for a copy of your government-issued ID.
If you are submitting on someone else’s behalf we may ask for additional verification. This may include providing a signed letter verifying your right to make this request.
We will not discriminate against you because you exercised your rights under the CCPA. Please keep in mind that these rights are not absolute. In some situations we may not be able to process your request. This may include if a legal exception applies. We’ll let you know when or if a right doesn’t apply to you. If you disagree with our decision you can contact us as described at the end of this statement.
Nevada Residents
You may opt out of the future sale of your information to a third party so that they may license or sell that information. To do this email us at the contact information listed at the end of this privacy statement.
Notice of Right to Opt-Out of Sale/Sharing
Under California law, we are required to tell you if we "sell" information including information of Californians under 16. We do not believe we are engaging in selling as that term is defined under that law. We do not sell the personal information of minors under 16 years of age. Some browsers or browser extensions allow you to tell websites not to share your information for cross-contextual behavioral advertising. While we do not currently engage in that activity, if we do we will respond to this signal in a frictionless manner. You may also visit optout.aboutads.info to control cookies collected for behavioral advertising, however we do not currently engage in this practice.
What About Children?
Our sites are meant for adults. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or legal guardian and think your child under 13 has given us information, you can contact us at the email or address above. Please mark your inquiries “COPPA Information Request.” Parents can learn more about how to protect children's privacy online here.
How to Contact Us
Should you wish to make an inquiry or complaint about Fortress’ use of your personal information, you may contact Fortress as set out below.
EU and UK residents, you also have the right to lodge a complaint with the appropriate regulatory body/supervisory authority, in particular in the country where you reside, place of work or of an alleged infringement of the law. The UK supervisory authority is the Information Commissioner's Office (ICO). You can visit their website at www.ico.org.uk. If you are in the EU, you can find your local data protection authority here.
If you have any questions concerning our privacy practices described in this Notice please contact us at DSR@fortress.com, submit your request here, or call 1-833-459-0090.
Or write to us:
Data Subject Rights
Fortress Investment Group
1345 Avenue of the Americas
New York, NY 10105
Changes to this Privacy Statement
We reserve the right to change our Privacy Statement from time to time as necessary, including due to changes in the law or to our data processing practices or activities.