Website Privacy Policy


Cross Ocean Partners Management LP and Cross Ocean Adviser LLP (alternately, “Cross Ocean”, “we”, “us” or “our”) respects your privacy and are committed to complying with this website privacy policy (“Privacy Policy”), which describes what information we collect about you, including how we collect it, how we use it, with whom we may share it and what choices you have regarding our use of your information.   

This Privacy Policy applies to information collected on our website located at (the “Site”), all interactive features, applications, widgets, social networks and social network “tabs”, and other online or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device or other technology or any associated content, material, or functionality contained on the Site (collectively, the “Services” and, together with the Site, the “System”).

For the avoidance of doubt, this Privacy Policy does not affect the terms of any privacy policy set out in a subscription document a user may have in place with Cross Ocean or its advised or sub-advised funds (a “Subscription Privacy Policy”), and to the extent that the terms of this Privacy Policy and the terms of a Subscription Privacy Policy conflict, the terms of that user’s Subscription Policy prevail.

Changes to our Privacy Policy

We may change this Privacy Policy at any time.  The most recent version of the Privacy Policy is reflected by the version date located at the bottom of this Privacy Policy. All such updates and amendments are effective immediately upon notice thereof, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Site. You should view this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the System signifies your continuing consent to be bound by this Privacy Policy. We expressly reserve the right to make any changes to this Privacy Policy at any time, without prior notice to you. The version of this Privacy Policy posted on the Site on each respective date you visit the Site shall be the Privacy Policy applicable to your access and use of the System on that date.

What information do we collect?

As described in detail below, we reserve the right to collect certain identifying information from or about you in connection with your use of, or any of your submissions to, the System (collectively, the “Collected Information”).  Collected Information includes, without limitation, any information that may be used to identify an individual, including, but not limited to, a first and last name, a phone number or an email address.


We appreciate your questions and comments about the System and Services and welcome your messages at our “Contact Us” page, which you can find here: If you correspond with Cross Ocean through the System or via email, the Collected Information may include the content of, and metadata regarding, any correspondence you may have with us. We may share your messages with those within our organization who are most capable of addressing the issues contained in your message. We may archive your message for a certain period of time or discard it.

How do we use the information that we collect?

Cross Ocean and our third party services providers may collect and use the Collected Information to operate the System and deliver the Services, including to provide certain services and improve the user experience, address System integrity or security issues, and conduct research and analysis to maintain, protect, develop, and improve the System and, additionally, use any information submitted by users as described below or elsewhere in this Privacy Policy or the Terms.

We may send you information that you request from us, promotional materials regarding Cross Ocean or any third party entity or individual affiliated with members of Cross Ocean, and any other communication for any other legitimate and lawful business purposes. Additionally, we may retain and use certain Collected Information to facilitate and otherwise address certain inquiries or requests regarding the Services or the System, or respond to your questions or requests for information about or from Cross Ocean.  We may also use Collected Information as necessary to ensure compliance with any Cross Ocean policies and any applicable law, regulation or order. 

Except as set forth in this Privacy Policy, Cross Ocean will not use, disclose, or transfer your Collected Information unless:

(1)             you expressly authorize Cross Ocean to do so,

(2)             it is necessary to allow Cross Ocean’s service providers, agents, or other third parties to provide products or services for or to Cross Ocean,

(3)             it is necessary in order to provide the System or the Services,

(4)             Cross Ocean is sending you other information that may be useful to you,

(5)             subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on Cross Ocean’s behalf or to other entities with whom Cross Ocean has joint marketing agreements,

(6)             it is necessary to protect the confidentiality or security of your records,

(7)             it is necessary in connection with other business purposes including, without limitation, investigating complaints about the System, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends and dispute resolution,

(8)             it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity;

(9)             subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all of the assets of Cross Ocean or the merger of Cross Ocean into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which Cross Ocean is not the survivor, or

(10)         it is otherwise necessary for Cross Ocean to disclose it as required or permitted by law.

With whom do we share information that we collect?

In addition to the uses mentioned or described elsewhere in this Privacy Policy or in the Terms, we may catalogue and add Collected Information to our database.

We do not sell, rent, or lease our user lists or the identity of individual users to third parties. However, Cross Ocean may use and disclose certain aggregated, anonymized information, such as System usage data, to our trusted business partners. 

We may also disclose Collected Information if we become subject to a subpoena or court order, or if we are otherwise legally required to disclose information. We may also use and disclose Collected Information to establish or exercise our legal rights, to enforce the Terms, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

As Cross Ocean grows and develops its business, it is possible that its corporate structure or organization might change or that it might merge or otherwise combine with, or that it or portions of its business might be acquired by, another company. In any such transactions, Collected Information may also transfer.

What choices do you have?

When submitting information, corresponding, making requests for information, and otherwise interacting with Cross Ocean and its representatives through or in connection with the System, you choose what information to supply or submit, whether you wish to receive further information, and how you may be contacted. Please take care to share only such information as is needed or that you believe is appropriate.

How do we protect information collected about you?

Cross Ocean takes commercially reasonable measures to secure and protect information transmitted via or stored on the System. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the System may happen to transmit or otherwise supply will be totally secure. You agree to immediately notify us of any breach of System's security, this Privacy Policy or the Terms of which you become aware.

User-provided content

Any information, communications, or material of any type or nature that you submit to the Website by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”) is done at your own risk and without any expectation of privacy.  We cannot control the actions of other users of the System and we are therefore not responsible for any Submissions contained on the Website. By visiting any of our pages that are contained on the Website, you are representing and warranting to us that you have reviewed this Privacy Policy and the Terms and that you will abide by all such provisions contained therein.

Social media platforms and websites

Any Submission that you submit to any of our pages contained on a social media platform or website by e-mail, posting, messaging, uploading, downloading, or otherwise is done at your own risk and without any expectation of privacy.  We cannot control the actions of other users of a social media platform and we are therefore not responsible for any Submissions contained on a social media platform or website. By visiting any of our pages that are contained on any social media platform or website, you are representing and warranting to us that you have reviewed the applicable privacy policy and terms of use of such website or social media platform and that you will abide by all such provisions contained therein.


The System (including the Site and Services included therein) is intended for a general audience and is not intended for use or view by children. We do not knowingly collect information about children or sell products to children. Consistent with the US’s Children's Online Privacy Protection Act, we will not knowingly collect any information from children.

Visiting the System from outside the United States

If you are visiting the System, or any part thereof, from outside of the United States of America, please be aware that your information may be transferred to, stored or processed in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy.  By using any portion of the System, you understand and consent to the transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy.

Do Not Track Requests

California and Delaware laws require that we indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. “Do Not Track” is a standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Privacy Policy and do not monitor or follow any Do Not Track browser requests.

This Privacy Policy was last updated on 25 July 2017.