This website (“Website”) is owned and operated by Sandbrook Capital Management LLC (collectively with its affiliates, “Sandbrook”). You may use this Website only if you agree, without modification, to these Terms and Conditions of use (“Terms”). Please read the Terms carefully. If you do not agree to these Terms, you must leave the Website.
This Website includes references to the investment experience of the principals of Sandbrook prior to Sandbrook’s founding. More information about this prior experience is available upon request from Sandbrook and references on this Website are intended solely to provide background information as to Sandbrook’s investment strategy and view of the market segments upon which Sandbrook focuses. Past performance of the principals, any other investment adviser, vehicle or account is not necessarily indicative of future performance of Sandbrook or any other party. This Website is not intended as advertising with respect to any investment vehicle or account, which will only be offered pursuant to the confidential offering and governing documents relating thereto.
By accessing this Website you signify your understanding and acceptance of our Terms. You may use your browser to download or print out a copy of these Terms for your records.
The information provided on this Website or in any communication containing a link to this Website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or that would subject Sandbrook to any registration requirement within such jurisdiction or country that is not already effective. Neither this information nor any opinion contained on this Website constitutes a solicitation, recommendation or offer by Sandbrook to buy or sell any securities or other financial instruments or provide any investment advice or service. Except as expressly authorized herein you may not reproduce, transmit, sell, display, distribute, publish, broadcast, circulate, modify, disseminate, or commercially exploit any information on this Website. The information is not intended for any recipient present or residing in any jurisdiction in which the disclosure of such information is regulated or unlawful. The dissemination of this information in any jurisdiction outside the United States may be required to be accompanied by additional disclosures which shall be deemed to be incorporated herein by reference and be considered an integral part of the information.
The information included on this Website may be subject to various requirements or limitations relating to their use or include various disclosures relating to the information therein which should each be reviewed carefully prior to your review of such information.
Disclaimer of Warranty and Limitation of Liability
The information on this Website is provided “as is.” Sandbrook does not warrant the accuracy or completeness of the information provided herein, or on any site accessed from this Website through a hypertext link, either expressly or impliedly, for any particular purpose and expressly disclaims any warranties of merchantability or fitness for a particular purpose. Sandbrook shall not be responsible for any loss or damage that results from interception by third parties of any information made available to you via this Website. Although the information provided to you on this Website is obtained or compiled from sources we believe to be reliable, Sandbrook cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose. It should be noted that Sandbrook believes the information to be accurate but only as of the date(s) noted herein. Sandbrook also makes no guarantee as to the accuracy, validity, timeliness, or completeness of any information on any site to which you gain access through a hypertext or other link from this website.
Neither Sandbrook nor any of its members, officers or employees, or any third party vendor, will be liable or have any responsibility of any kind for any loss or damage that you incur in the event of any failure or interruption of this Website, or that results from the act or omission of any other party involved in making or maintaining this Website or the data contained herein available to you, or from any other cause relating to your access to, inability to access, or use of the Website or any materials included on this Website, whether or not the circumstances giving rise to such cause may have been within the control of Sandbrook or of any vendor providing software or services support. Sandbrook and its members, officers, employees, and third party vendors also shall have no liability or responsibility of any kind for any loss or damage that you incur as a result of any information contained on any Web pages or site maintained by any third party that you access through a hypertext link or the client log-in screen of this Website. In no event shall Sandbrook or any such parties be liable to you for any direct, special, indirect, consequential, or incidental damages or any other damages of any kind even if Sandbrook or any other party has been advised of the possibility thereof.
Modification of Website
Sandbrook reserves the right, at its discretion, to change these Terms and the contents of this Website at any time and without notice. We suggest that you review these Terms periodically for changes. The Terms can be accessed from links on the home page and other pages of the Website. If you use this Website after we post changes to these Terms, you accept the changed terms. Sandbrook may also offer other services from time to time that are governed by different terms and conditions.
Monitoring of Website
Sandbrook expressly reserves the right to monitor any and all use of this Website. Sandbrook is under no obligation to do so and assumes no responsibility or liability arising from the use of this Website.
Privacy and Security
As a condition of use of this Website, you agree to indemnify Sandbrook from and against any and all actions, claims, losses, damages, liabilities and expenses (including reasonable attorneys' fees) arising from your use of this Website, including without limitation any claims alleging facts that if true would constitute a breach by you of these Terms and Conditions.
Security and Confidentiality of User IDs
Any user identification and password (hereinafter together referred to as “User ID”) that have been provided to you by Sandbrook are for your exclusive use only. By accepting your User ID you agree to protect the confidentiality and security of your User ID and of the Website and its contents and that such information will only be communicated within your organization to properly authorized employees and agents, where applicable. Sandbrook is not responsible for any damages or losses resulting from any breach of security caused by your failure to maintain the confidentiality of your User ID. You agree to notify Sandbrook immediately in the event of loss or theft of any or all of your User ID, or if you believe the confidentiality of any or all of your User ID has been compromised in any way, or in the event of your learning about a possible or actual unauthorized use of your User ID. Sandbrook reserves the right to suspend or terminate your access to the Website at any time, without prior notice.
Confidentiality of Information
The information contained in the Website is confidential, sensitive and proprietary and is intended solely for the information of the person to whom it has been provided. It is not to be reproduced, or transmitted, in whole or in part, to third parties. You agree to be bound by the confidentiality provisions hereof. Upon our request, you will as soon as practicable return all information to us and represent in writing to us that you have destroyed all copies of the information.
Copyright or Other Notices
All copyrights and intellectual property rights to materials on the Website belong to or are licensed to Sandbrook. If you download any information from this Website, you agree that you will not copy it or remove or obscure any copyright or other notices or legends contained in any such information.
Jurisdiction, Governing Law and Severability
Users of this Web site shall be bound by all applicable Federal laws of the United States of America and the laws of the State of Delaware.
The appropriate Delaware Federal or State court shall have exclusive jurisdiction for any action or dispute arising out of this agreement or website. If any of these Terms is held invalid or unenforceable, that part will be deemed modified as necessary to make it effective, and the remaining provisions of these Terms will remain in effect.
Sandbrook does not solicit or make its services available to the public. The content provided on or through the Website may include information regarding past and/or present portfolio companies and/or investments managed by Sandbrook, its affiliates and/or its personnel. It should not be assumed that investments made in the future will be comparable in quality or performance to the investments described herein. Further, references to past and present portfolio companies or investments should not be construed as a recommendation of any particular investment or security. Current and previous portfolio companies and/or investments listed on the Website are not to be considered a complete list of all investments historically made by Sandbrook. The investments listed should not be assumed to have been profitable. Any past performance information on the Website is not necessarily indicative, or a guarantee, of future results.
Certain information contained on the Website constitutes “forward-looking statements.” All forward-looking statements represent only the intent and belief of Sandbrook as of the date such statements were made. None of Sandbrook or any of its affiliates (i) assumes any responsibility for the accuracy and completeness of any forward-looking statements or (ii) undertakes any obligation to disseminate any updates or revisions to any forward-looking statement contained on the Website to reflect any change in their expectation with regard thereto or any change in events, conditions or circumstances on which any such statement is based. Due to various risks and uncertainties, actual events or results may differ materially from those reflected or contemplated in such forward-looking statements.
Certain statements about Sandbrook made by portfolio company executives herein are intended to illustrate Sandbrook’s business relationship with such persons, including with respect to Sandbrook’s facilities as a business partner, rather than Sandbrook’s capabilities or expertise with respect to investment advisory services. Portfolio company executives were not compensated in connection with their participation, although they generally receive compensation and investment opportunities in connection with their portfolio company roles, and in certain cases are also owners of portfolio company securities and/or investors in Sandbrook-sponsored vehicles. Such compensation and investments subject participants to potential conflicts of interest in making the statements herein.
Environmental, Social And Governance (“ESG”) Matters
ESG goals are aspirational and not guarantees or promises that all goals will be met, and there are distinctions and regional variations in the meaning and use of this term. There is no guarantee that Sandbrook or any of its portfolio companies will have or create a positive ESG impact, that consideration of ESG factors will enhance long-term value and financial returns for investors, or that ESG performance of Sandbrook will align with your or any investor’s ESG goals.
Last Updated: November 1, 2022
Our Commitment to Privacy
Your privacy is important to Sandbrook Capital Management, LLC and its affiliates (together, “Sandbrook ,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
The Information We Collect and How We Use It
We may collect various types of information from users of this website. For example, knowing how users use our website – tracking their movement through this website – helps us improve website design and usefulness. As a result, Sandbrook ’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (IP) addresses. Sandbrook generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” page.
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.
You represent to Sandbrook that you have the authority to visit this website according to the Important Disclosures. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
You may access any personally identifiable information we have about you by contacting firstname.lastname@example.org.
Notification of Changes
The provisions in our Important Disclosures are hereby incorporated by reference.
Last Updated: November 1, 2022
What information do we collect about you?
We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
- Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address);
- Other customer records, such as telephone number and personal information provided in connection with obtaining account access;
- Commercial information, such as account data;
- Professional or employment-related information;
- Education information; and
- Internet or other electronic network activity information, such as information regarding your use of our Website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.
We do not knowingly collect or solicit personal information from anyone under the age of 18.
How do we obtain your personal information?
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
- Information from your communications with us in connection with this Website, including any update notices provided by you.
- Information captured on our Website, including registration information, information provided through online forms and any information captured via cookies.
We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
How do we use your personal information?
We will use your personal information for one or more of the following business purposes:
- To perform services for you.
- To improve our Website and the products and services that we offer and notify you about changes to our products and services.
- To communicate with you, including responding to requests for information submitted by you through our Website.
- To keep a record of your relationship with us.
- Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
- To audit and verify the quality and effectiveness of our services and compliance.
- To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
- To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.
Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the "opt-out" or "unsubscribe" link provided in all our marketing emails.
Who do we share your personal information with?
We do not sell any of the personal information we collect about you to third parties.
We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth above in “What information do we collect about you?”
We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.
How do we keep your personal information secure?
We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
- the categories of personal information we collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties with whom we share the personal information;
- the specific pieces of personal information we have collected about you; and
- whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
Call us using the following number: +1 (475) 268-1450
Email us at the following email address: email@example.com
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.