Website Privacy Policy

Last updated: March 10, 2025

1. INTRODUCTION

Moore Capital ("Moore Capital", "we", "us", "our") respects your privacy. This Privacy Policy and our GLBA Privacy Notice that is provided to our customers explain how Moore Capital collects, processes and uses your Personal Data when you visit or use our website, https://www.moorecap.com/ ("Website"), use our services or otherwise communicate with us.

For the purposes of this Privacy Policy, "Personal Data" means any information which directly or indirectly identifies or otherwise relates to an individual, which is in the possession or under the control of Moore Capital (or its representatives or service providers). Such Personal Data may include, without limitation, the name, age, government identification numbers, Social Security number, email address, address, telephone number, location data, financial data (such as checking account information, wire transfer instructions, account balances and payment history), or online identifier of an individual.

This Privacy Policy does not apply to information collected through third-party websites or third-party services that you may access through the Website. Linked sites may have their own privacy notices or policies, which you should review. Moore Capital is not responsible for the content of links or third party websites and your use of such third party websites is at your own risk.

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. Regardless of your consent to receive text messages, any related data, including your phone number and consent information, will be kept confidential and will not be disclosed to third parties, ensuring that your opt-in data is excluded from external marketing activities.

By using the Website or using our services, you agree to the terms of this Privacy Policy.

2. THE TYPES OF PERSONAL DATA WE COLLECT

Moore Capital may collect and process the following categories of Personal Data about you from the sources identified as follows:

  1. Website Data. When you browse the Website, we may collect information submitted to us through the Website (including, but not limited to, name, age, date of birth, email address, address, and telephone number).
  2. Identity Verification Data. We may collect identity verification information from you, such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws, or other authentication information.
  3. Communications Data. We may collect Personal Data that you provide when you contact Moore Capital for any reason, such as to express an interest in obtaining additional information about our services, direct questions or concerns about our services to us, use the contact information listed in the "Contact Us" webpage, or sign up for our emails or attend an event. Such information may include contact information such as name, job title, company name, phone number, location, and email address.
  4. Financial Information. We will collect and use your financial information that you provide on our subscription documents and otherwise during the course of using our services. This information may include checking account information, wire transfer instructions, account balances, and payment history.
  5. Reputation & Background Check Data. If you are a service provider or a business partner or are a representative of one of our service providers or business partners, we may collect Personal Data from you and from third parties that includes contact details, information concerning business practices, creditworthiness, reputation and business history, and job titles, or roles. We may also use this information to check against government sanctions lists and for other "Know Your Customer" purposes.
  6. Data Moore Capital Generates. We may generate Personal Data about you when we interact with you or perform services for you. This data may include information about your relationship with us or the services we are providing you.

Please note that if you do not provide certain Personal Data to Moore Capital when requested (and where relevant, provide your consent) we may not be able to provide you with access to all areas of the Website and our services.

3. HOW WE COLLECT YOUR PERSONAL DATA

Moore may collect the types of Personal Data in the following ways:

  1. Directly from you, including, for example, through your use of the Website, when you send us an email, complete subscription documents, visit our premises, or otherwise contact or communicate with us;
  2. From our affiliates and business partners;
  3. From a third party acting on your behalf, for example, an intermediary, investment advisor, lawyer or service provider;
  4. From publicly available sources; and
  5. From other organizations, for example, fund administrators and other service providers.

4. HOW WE USE YOUR PERSONAL DATA

Your Personal Data may be collected, stored, disclosed and processed by Moore Capital for the following purposes:

  1. to provide you with marketing communications and inform you about news and information relating to our business and services, including new product launches, product updates and general business news;
  2. to share your Personal Data with other financial companies for their marketing purposes; if you want to limit this sharing, please contact us using the contact information provided below;
  3. to assess your application and subscription documents for Moore Capital’s products and services, where applicable;
  4. to understand your needs and interests and to respond to your inquiries;
  5. to analyze and improve our services and Website;
  6. for the management and administration of our business;
  7. to provide you with the products and services for which you subscribe or request;
  8. to comply with and to assess compliance with applicable laws, rules and regulations, industry codes, voluntary codes we are bound by, or good practice, anywhere in the world and internal policies;
  9. to confirm and verify your identity and to conduct due diligence, background and related checks. We will also screen against publicly available government and/or law enforcement agency sanctions lists. We may use third party providers to conduct these verifications and searches;
  10. to detect, investigate and prevent fraud and other crimes or malpractice;
  11. for the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings) or requests from law enforcement;
  12. to obtain legal advice or to establish, exercise or defend legal rights;
  13. the administration and maintenance of databases storing Personal Data;
  14. to comply with our contractual obligations;
  15. for ongoing review and improvement of the information, content and services provided on the Website to ensure they are user friendly and to prevent any potential disruptions such as cyber-attacks;
  16. to analyze and report on the Website's traffic, marketing and usage trends;
  17. to allow you to use and access functionality provided by the Website;
  18. to conduct analysis required to detect malicious data and understand how this may affect your IT system;
  19. for statistical monitoring and analysis of current attacks on devices and systems for the on-going adaption of the solutions provided to secure systems and devices against current attacks;
  20. for in-depth threat analysis;
  21. as a part of a corporate transaction, such as a sale or transfer of company assets, merger, consolidation, bankruptcy proceeding, or as otherwise legally permitted or required; and
  22. for purposes otherwise set out in this Privacy Policy or in compliance with applicable laws.

Moore Capital is entitled to use your Personal Data for these purposes because one or more of the following legal bases applies:

  1. Moore Capital needs to do so in order to perform its contractual obligations to you (for example, in order to manage your investments and verify the information you provide);
  2. Moore Capital has obtained your specific and informed consent (which may include written consent);
  3. Moore Capital has legal or regulatory obligations that must be discharged;
  4. Moore Capital needs to do so in order to establish, exercise or defend its legal rights or for the purpose of legal proceedings; or
  5. the use of your Personal Data is necessary for our legitimate business interests or the legitimate interests of a third party provided such interests are not overridden by your rights or interests.

If you are located in a jurisdiction which requires us to obtain your consent to collect, use, store, process and disclose your Personal Data, you understand that by accepting the terms of this Privacy Policy you expressly provide your consent to Moore Capital collecting, using, storing, processing and disclosing your Personal Data as set out in this Privacy Policy.

5. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

Moore Capital may share, disclose, or provide access to your Personal Data among its affiliates and business units and third party agents, service providers and contractors outside of Moore Capital for the following purposes:

  1. Business Management. For the purpose of the management and administration of Moore Capital’s business;
  2. Provision of Services. In order to facilitate the provision and enhancement of services to you;
  3. Database Management. For the purpose of the administration and maintenance of the databases storing Personal Data;
  4. Vendor Services. For the purposes of Moore Capital receiving services. These third parties will be expected to be subject to confidentiality requirements (either by contract, professional obligation, duty or otherwise) that require them to only use your Personal Data as described in this Privacy Policy;
  5. System Protection. For the purpose of detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible; debugging to identify and repair errors that impair intended functionality;
  6. Compliance with Law. To the extent required by law or to establish, exercise or defend its legal rights. This may include disclosure to regulatory bodies or government agencies, law enforcement or courts, and in order to investigate unauthorized attempts to modify the Website, install harmful files or cause damage to the Website or to Moore Capital;
  7. Business Transactions. As part of a transaction, financing, or for other business needs; or
  8. Change of Control. If Moore Capital or any of its affiliates, divisions or business units is acquired by a third party, including in the event of a bankruptcy, in which case the Personal Data held by Moore Capital about you will be accessible to, and may be acquired by, the third party buyer.

Moore Capital may share anonymous or aggregated data with third parties such as service providers in order to facilitate our business operations.

6. TRANSFERS OF PERSONAL DATA

Moore Capital is based in the United States, and the Website designed for users in, and operated from, the United States. If you reside outside the United States and use our Website or otherwise provide information to us, you acknowledge that your information will be transferred to and processed in the United States, which may not provide the same levels of privacy protection as the laws in your jurisdiction.

7. HOW WE SAFEGUARD YOUR PERSONAL DATA

Moore Capital has implemented commercially reasonable controls to protect Personal Data, taking into account the sensitivity of the data. Although we exercise reasonable care in providing secure transmission and storage of the Personal Data you provide to us through the Website, no method of transmission over the Internet, and no means of electronic storage, is absolutely secure. Accordingly, we cannot and do not guarantee the absolute security of your Personal Data.

8. RETENTION AND DESTRUCTION OF PERSONAL DATA

The period for which Moore Capital will hold your Personal Data will vary and will be determined by the following criteria:

  1. The purpose for which Moore Capital is using it. Moore Capital is required to retain the Personal Data for as long as is necessary to satisfy or meet the purposes for which it was obtained including applicable legal or regulatory requirements; and
  2. Legal Obligations. Laws or regulations may set a minimum period for which Moore Capital must retain your Personal Data.

    3. Moore Capital will take reasonable steps using appropriate technical methods in the circumstances to delete or destroy your Personal Data when we no longer have a legal basis to retain it or to ensure that the information is anonymized or irrecoverable.

    9. CHILDREN’S PERSONAL DATA

    The Website is intended for use by those over 18 only. We do not knowingly solicit or collect Personal Data on or through the Website from children under the age of 18.

    10. PROCESSING OF PERSONAL DATA FOR MARKETING PURPOSES

    You may provide us with Personal Data so that we may contact you by mail, e-mail, SMS/text, telephone and other electronic means to provide you with information on products and services that we believe will be of interest to you. If you do not want to receive such communications from us please contact us via the details set out below or by using the opt-out facilities provided within the relevant marketing material.

    Your option not to receive promotional and marketing material: (a) shall not preclude us from corresponding with you, by email or otherwise, regarding your relationship with us (for example, your account status and activity or our responses to questions or inquiries you pose to us); (b) shall not preclude us, including our employees, directors, officers, contractors, agents and other representatives, from accessing and viewing your Personal Data for our internal business purposes; and (c) shall not preclude us from disclosing your Personal Data as described in this Privacy Policy for purposes other than sending you promotional and marketing materials.

    11. Modifications to this Privacy Policy

    We reserve the right to modify this Privacy Policy at any time by posting the revised version on the Website and updating the last modified date. We encourage you to review the Privacy Policy whenever you access the Website or otherwise interact with us to stay informed about our privacy practices.

    12. California Shine the Light Notice

    California residents may request and obtain from us, once a year and free of charge, information about categories of Personal Data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in this Privacy Policy.

    13. YOUR PRIVACY RIGHTS

    Depending on where you reside, you may have rights with respect to our collection, use, and disclosure of your Personal Data. To enquire about the rights which apply to you, please contact us. The legal rights that you may have in relation to the Personal Data about you that Moore Capital holds may include:

    • Access. The right to request information about how we have collected and used your Personal Data, such as (i) the specific pieces of Personal Data we have about you; (ii) the categories of Personal Data we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Data was collected; (iv) the purpose for collecting your Personal Data; (v) the categories of your Personal Data that we disclosed for a business purpose.
        
    • Refuse or object. The right to refuse to provide any Personal Data and the right to object at any time to the processing of your Personal Data. Please note that such refusal or objection may prevent us from providing services to you.
        
    • Withdrawal of consent. Where consent was provided for certain processing activities, the right to withdraw your consent to the collection, processing, use and/or disclosure of your Personal Data at any time. Please note, however, that this will not affect the lawfulness of any collection, processing, use or disclosure undertaken before your withdrawal and that we may still be entitled to process your Personal Data if it has another legitimate reason (other than consent) or a consent exception for doing so. In some cases, withdrawing your consent to the collection, use process or disclosure of some or all of your Personal Data may prevent us from providing services to you;
        
    • Deletion. The right to request that we delete the Personal Data that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to retain the information to comply with our legal obligations or complete a transaction for which your Personal Data was collected. If we deny your request for deletion, we will let you know the reason why.
        
    • Correction. The right to request that we correct any inaccurate Personal Data that we maintain about you. Moore Capital will use commercially reasonable effort to correct the inaccurate Personal Data.
        
    • Limit. Some of the information we collect may be considered “sensitive” Personal Data. You may have the right to request that we limit the use and disclosure of your sensitive Personal Data to that use which is necessary to provide you with services you have requested and for certain other limited purposes as provided for under applicable law.
        
    • Opt-out. Residents of some jurisdictions may have the right to opt out of the sale of your Personal Data to third parties and/or the sharing of your Personal Data for cross-context behavioral advertising.
        
    • Automated Decisions. Residents of some jurisdictions may have the right to opt out of certain automated decision-making (e.g., profiling). Moore Capital does not currently use automated technologies for profiling or to make automated decisions based on your Personal Data.
        
    • Appeal. Residents of some jurisdictions may have the right to appeal our decision not to take action on your request to exercise one of your privacy rights.

    Request Verification and Response. We will take steps to verify your identity before processing your request. We may not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Data. We will only use the Personal Data provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the Personal Data for another purpose. If we cannot verify your identity to comply with a request, we will explain the reason in our communication to you.

    Authorized Agent. You may use an authorized agent to submit a request. When we verify your agent’s request, we may verify both your and your agent’s identity and request documentation from you that authorizes your agent to make the request on your behalf. To protect your Personal Data, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

    Non-Discrimination. If you choose to exercise any of these rights, Moore Capital will not discriminate against you.

    Complaints to Privacy Regulators. We request that you contact us if you have any questions or complaints about how we have processed your Personal Data. We are typically able to resolve privacy questions or concerns promptly and effectively. Depending on your jurisdiction, you may have the option to escalate concerns to the applicable privacy regulator in your jurisdiction. For more information about how to lodge a complaint in the EU, please refer here.

    14. QUESTIONS AND CONCERNS

    If you have any questions or concerns about Moore Capital’s handling of your Personal Data or about this Privacy Policy, please contact us using the contact information set out below.

    15. HOW TO CONTACT US
    Email: [email protected]
    By Phone: (212) 782-7000