Privacy Policy | WSD Capital Management

Privacy Policy

WSD Capital Management, L.P. (the “Firm”) recognizes the importance of protecting your personal information when you visit the Firm’s website located at (the “Website”). The following information is designed to help you understand the information collection practices at the Website.

By visiting the Website, you are accepting the practices described in this Privacy Policy. If you do not agree to this policy, please do not use the Website. Please review the Terms of Use to learn of other terms and conditions applicable to your use of the Website.

Changes to this Privacy Policy

The Firm reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. Such changes shall be effective immediately upon posting. The Firm suggests that you review this policy periodically for changes. You acknowledge that by accessing the Website after the Firm has posted changes to this Privacy Policy, you are agreeing to the terms of the Privacy Policy as modified.

Information Collection and Use

Personally Identifiable Information: If you are accessing parts of the Website that are password protected, then once you submit your password and enter, the Website will recognize who you are and collect all information that you submit, including all electronic information.

Aggregate Information: The Website generally records certain usage information, such as the number and frequency of visitors to the Website. This information may include the websites that you access immediately before and after your visit to the Website, the Internet browser you are using and your Internet Protocol (IP) address. If the Firm uses such data at all, it will be on an aggregate basis and the Firm will not disclose to third parties any information that could be used to identify you personally.

Cookies: Cookies are small text files that are stored in your computer’s memory and hard drive when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website.

Cookies enable the Website to provide customized services and information. The Firm uses cookies on the Website for the following purposes (Cookie Usage Information):

  • Analytical purposes: Analytical cookies allow the Firm to recognize, measure and track visitors to the Website. This helps the Firm to improve and develop the way the Website works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of the site that are of the most interest to them.
  • Usage preferences: Some of the cookies on the Website are activated when visitors make a choice about their usage of the site. The Website then remembers the settings preferences of the user concerned. This allows the Firm to tailor aspects of the Website to the individual user.
  • Terms and conditions: The Firm uses cookies on the Website to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on the Website. This helps to improve the user’s experience of the site, for example, it avoids a user from repeatedly being asked to consent to the same terms.
  • Session management: The software that runs the Website uses cookies for technical purposes needed by the internal workings of the Firm’s servers. For instance, the Website uses cookies to distribute requests among multiple servers, authenticate users and determine what features of the site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for the site to function.
  • Functional purposes: Functional purpose cookies store information that is needed by the Website applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.

Third party cookies: When you visit the Website, you may receive cookies that are set by third parties. These may include cookies set by Google. These cookies are used for the purposes described in the bullet points above. The Firm does not control the setting of these third party cookies; thus, the Firm suggests to check the third party websites for more information about their use of cookies and how to manage them.

Amending cookie preferences: You can configure your browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so check the ‘Help’ menu of your browser to learn how to change your cookie preferences. You are always free to decline the Website cookies if your browser permits, although in that case you may not be able to use certain features on the Website. In addition, a number of companies offer utilities designed to help you visit websites anonymously.

Service Providers

The Firm may use internal or external service providers to operate the Website and employ other persons to perform work on the Firm’s behalf, such as sending postal mail and email. These persons may have access to the personally identifiable information you submit through the Website, but only for the purpose of performing their duties. These personnel are not permitted to use your personally identifiable information for any other purpose.

Compliance with Laws

The Firm does not automatically collect personally identifiable information from visitors to the Website, except to the extent the Firm is required to do so pursuant to regulation applicable to the Firm. The Firm will not provide any personally identifiable information to any other persons, except (a) if the Firm is required to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation, similar proceedings or regulatory examination, (b) to comply with applicable laws or regulations, (c) to enforce these Terms, or (d) to share information with the Firm’s affiliates or service providers in connection with providing services to you. The Firm can, and you authorize the Firm to, disclose any such information in those circumstances.

Email and Marketing

The Firm does not sell its subscribers’ email addresses, nor will the Firm provide your personal information to third parties for any marketing purposes. The Firm will not send you email messages without first receiving your permission. It is the Firm’s policy to include instructions for unsubscribing from these permission-based programs. The Firm recommends that you do not send any individual personal information via nonsecure methods of correspondence, including via public electronic communication channels, such as Internet email, which are generally not secure.

Business Transfers

If all or some of the business, stock or assets of the Firm are acquired or merged with another business entity, the Firm will share all or some of your information with this entity to continue to provide service to you. You will receive notice of such an event and the new entity will inform you of any changes to the practices in this Privacy Policy. If the new entity wishes to make additional use of your information, you may decline such use at such time.

Children’s Privacy

Although the Website is not targeted toward children, the Firm is concerned about the safety and privacy of children who use the Internet. Consistent with the Children’s Online Privacy Protection Act of 1998, the Firm will never knowingly request personally identifiable information from anyone under the age of 13 without prior verifiable parental consent. If the Firm becomes aware that a child under 13 has provided the Firm with personally identifiable information without verifiable parental consent, the Firm will use its best efforts to remove such information from the Firm’s files. If a parent or guardian becomes aware that his or her child has provided the Website with personally identifiable information without verifiable parental consent, he or she should contact the Firm.

Third Party Websites

The Firm may establish links between the Website and one or more websites operated by third parties. The Firm has no control over any such other websites, the contents therein or the products/services offered. Your access to and use of such linked websites is governed by the terms of use and privacy policies of those sites, and shall be at your own risk. The Firm disclaims responsibility for the privacy policies and customer information practices of third-party internet websites hyperlinked from the Website.


No data transmission over the internet can be 100 percent secure, which is why the Firm cannot ensure or warrant the security of any information you submit to the Firm through the Website.

Last modified on March 3, 2017.