Effective Date of Current Policy: 25 May 2018

SHENKMAN CAPITAL MANAGEMENT, INC. and its affiliates and subsidiaries (collectively, “Shenkman Capital”, “we”, “us” or “our”) are committed to protecting the security and privacy of your personal information. This Privacy Policy seeks to help you understand the manner in which we may collect, process and disclose your personal information. For the purposes of EU data protection laws, Shenkman Capital is a data controller (i.e. the company responsible for, and which controls the processing of your personal information).

Personal Information We May Collect About You

When you contact us via telephone, email, or using the Email Form on this website, any personal information you provide (e.g. name, residential address, telephone number, company name or email address) will be collected and processed by us. We may also process your personal information, such as your username, when you use the Client Login function on the website.

In addition, for users of the website, we automatically collect basic technical information from all visitors to the website. Such technical information includes, without limitation, your web browser, location and Internet Protocol (IP) address. We collect technical information during your visit to the website through our automatic data collection tools, which may include cookies and other commonly used technologies (e.g. web beacons). Please see the Section on Cookies below for further information.

How We Use Your Personal Information

The provision of personal information by you may be necessary where we have a legitimate interest to: (i) contact you and respond to your enquiry or provide you access to specific information or offerings; (ii) support our relationship with you; (iii) understand how we can improve our products and services; (iv) personalize your visit to the website and to assist you while you use the website; (v) send marketing communications to you; (vi) improve the website by helping us understand who uses the website and improve the website experience; and/or (vii) comply with applicable laws, regulations or codes of practice. Please note that you have a right to object to the processing of your personal information where that processing is carried out for our legitimate interest or for direct marketing.

Sharing Your Personal Information

We may use selected third parties to provide us with services, including companies that provide us with technical support and assistance. All service providers are only permitted to use personal information for the purpose of performing services on our behalf in compliance with the privacy practices and policies of Shenkman Capital. Our affiliates and associated service providers, such as software companies, may also have access to personal information provided to us by you, including through or in connection with this website for the purposes set out in this Privacy Policy.

For users of the website, the servers used in the operation of the website automatically identify a computer by its IP address. If we, in good faith, determine that you have or are attempting to misuse or harm the website, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property. Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities.

Data Transfers

Given the global nature of Shenkman Capital’s activities, where you are located in the European Economic Area (the “EEA”), personal information collected, either directly from you and/or via the website, may be transferred to recipients including other Shenkman Capital entities in countries located outside the EEA, including the U.S., which are not considered by the European Commission to provide an adequate level of data protection.

You hereby expressly consent to the transfer of your personal information to recipients (including Shenkman Capital), as described in this Privacy Policy, which are located outside of the EEA. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Shenkman Capital has entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal information. You can request a copy of these Model Contracts by submitting your request via email to:

E-Mail Communications and Marketing

Occasionally, we may send you e-mail communications with information that may be useful to you, including information about the products and services of Shenkman Capital, its subsidiaries and other third parties with whom we have a commercial relationship. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional e-mails from us. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing or market research communications from us, or would like to stop processing your personal information in any other way, you can contact us as described below to let us know what types of communications you wish to stop receiving. However, if you are a client, supplier or otherwise have a commercial relationship with Shenkman Capital, to ensure that you receive important information, you agree that we may send you non-marketing related information when necessary. We do not disclose, sell or otherwise market your personal information to third parties, unless we are required to do so by law.

Your Rights

Individuals in Europe have certain data subject rights which may be subject to limitations and/or restrictions. These rights may include: (i) the right to request access to and rectification or erasure of your personal information; (ii) the right to obtain restriction of processing or to object to processing of your personal information; and (iii) the right to ask for a copy of your personal information to be provided to you, or to a third party, in a digital format. If you are based in the EEA and would like to exercise one of the above mentioned rights, please send us your request via email to: Individuals in the EEA also have the right to lodge a complaint about the processing of their personal information with their local data protection authority. Shenkman Capital asks that you contact in the first instance to give us the opportunity to address any concerns you may have.

Links to Other Websites

Our website may contain links to other websites. Shenkman Capital is not responsible for the privacy practices or the content of other websites. This Privacy Policy applies only to the information we collect through our website. We encourage you to read the privacy statements of all of the destination websites which you visit.


Shenkman Capital uses various methods to ensure the protection of your personal information against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure or access. While these methods are considered to be effective, Shenkman Capital does not guarantee the protection of your personal information as no data transmission over the Internet can be guaranteed to be completely confidential or 100% secure. You use our website and provide all such personal information at your own risk. Shenkman Capital retains personal information for as long as necessary to fulfil the purposes for which such personal information was collected or to comply with its legal obligations, resolve disputes or enforce agreements. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services and operate the business; (ii) the type of personal information collected; and (iii) whether Shenkman Capital is subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).


Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit

When you visit the website, we may place a “cookie” or other online tracking device (e.g. web beacons) in order to improve your experience by recognising you when you visit the website, such as by assigning a session ID and to deliver content specific to your interests. The cookies we place may also collect information about your IP address, or click stream data within our website (i.e. the actions taken in connection with the website). This information helps us improve the functionality of the website.

We also use cookies provided by Google Analytics to help us measure how visitors use the website. The information collected is used for a variety of purposes, including, but not limited to, site traffic reporting, unique visitor counts, and content optimization. Although Google Analytics logs the information coming from the website on our behalf, we control how the data may and may not be used. If you do not want to help us learn how to improve the website, you can opt-out of this website analysis tool by clicking:

Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the website.

Revisions to Our Privacy Policy

We evaluate our privacy policies and procedures to implement improvements and refinements from time to time. Shenkman Capital reserves the right to amend the terms contained herein in whole or in part for any reason. We therefore suggest that you review this Privacy Policy periodically.

Questions and Comments

If you have any questions or comments about our Privacy Policy or, if you are based in the EEA and would like to exercise your data subject rights, please feel free to contact us at


Terms of Service

By accessing this website and any of the pages herein (collectively, the “Site”), you signify your agreement with and understanding of the following Terms of Service pertaining to both this Site and any material on it. This Site is offered to you conditioned on your acceptance without modification of the terms, conditions, and notices contained herein. Your use of this Site constitutes your agreement to all such terms, conditions, and notices. SHENKMAN CAPITAL MANAGEMENT, INC. and its affiliates and subsidiaries (collectively, “Shenkman”) reserve the right to change the terms, conditions, and notices under which this Site is offered, and such changes are effective immediately. You are bound by such changes and thus should periodically visit this page to review the then-current terms and conditions. If you do not agree to be bound by and subject to these Terms of Service, you must not access or use this Site.

Ownership of Site and Trademarks

Shenkman owns and maintains this Site. Nothing on this Site shall be construed as granting, by implication, estoppel or otherwise, any license or right to use any image, trademark, logo or service mark on the Site. No act of downloading or otherwise copying from this Site will transfer title to any software or material on this Site to you. Anything that you transmit to this Site becomes the property of Shenkman, may be used by Shenkman for any lawful purpose, and is further subject to disclosure as deemed appropriate by Shenkman, including to any legal or regulatory authority to which Shenkman is subject. This Site is for your personal and non-commercial use. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any information, software, products, or services obtained from this Site. Shenkman reserves all rights with respect to copyright and trademark ownership of all material on this Site, and will enforce such rights to the full extent of the law. SHENKMAN®, ®, ®, SHENKMAN CAPITAL®, and any other trademarks used on this Site are registered trademarks of Shenkman Capital Management, Inc. All rights reserved.

No Offer of Securities or Advice

This Site sets forth general information about Shenkman and the services it provides. Under no circumstances should any material on this Site be used or considered as investment advice, an offering of advisory services, or an offer to sell or solicitation to buy any securities (including, without limitation, any interest in any investment fund managed by Shenkman) in any jurisdiction. Any offer or solicitation with respect to such fund will be made only by means of the prospectus or Confidential Private Offering Memorandum relating to the particular fund. Access to information about the funds is limited to investors who, among other requirements, either qualify as “accredited investors” and “qualified purchasers” within the meaning of the Securities Act of 1933, as amended, and the rules promulgated thereunder, or those investors who generally are sophisticated in financial matters, such that they are capable of evaluating the merits and risks of prospective investments.

Nothing contained on the Site constitutes tax, accounting, regulatory, legal, or investment advice.

Investment Risk

The investment strategies and services discussed on this Site may not be suitable for all investors. Shenkman makes no representations that the contents contained herein are appropriate in all jurisdictions or for all investors or counterparties.

Investment in any of the funds and/or strategies described on the Site carries substantial risk, including the possible loss of principal.

Past performance is not a guarantee of future results.

No Reliance

While Shenkman uses reasonable efforts to update the information on this Site, Shenkman makes no representations or warranties as to the accuracy, reliability or completeness of any information on this Site, and is under no obligation to make such updates. The contents of this Site are subject to change without notice.

Material to be Consulted in its Entirety

All materials on this Site are meant to be reviewed in their entirety, including any footnotes, legal disclaimers, restrictions or disclosures, and any copyright or proprietary notices. Any disclaimers, restrictions, disclosures or hedge clauses apply to any partial document or material in the same manner as they do the whole, and will be deemed incorporated in the portion of any material or document that you consult or download.

Linked Sites

Shenkman has not reviewed any of the sites linked to this Site, and is not responsible for the content of off-site pages or any other site linked or linking to the Site. The inclusion of such links is in no way an endorsement, representation or warranty by Shenkman with respect to any such site or the content contained through such site. Your linking to any off-site pages or other sites is at your own risk. You agree not to link this Site to any websites without the prior written consent of Shenkman.

Limitation of Liability

All materials on this Site are provided “as is” without warranty of any kind, either express or implied, to the fullest extent permissible pursuant to applicable law. Shenkman further assumes no responsibility or liability and makes no warranties that functions contained on this Site will be uninterrupted or error-free, that defects will be corrected, or that the Site or the server that makes it available will be free of viruses or other harmful components. Shenkman shall not be liable for any damages to, viruses that may infect, or services, repairs or corrections that must be performed, on your computer or other property on account of your accessing or use of this Site. Please note that some jurisdictions do not allow the exclusion of implied warranties, so some or all of the above exclusions may not apply to you.

To the extent permitted by law, Shenkman, its affiliates and each of their directors, officers, employees and agents expressly exclude all conditions, warranties, representations and other terms which might otherwise be implied by statute, common law or the law of equity. In no event will Shenkman or any of its affiliates be liable to any person for any indirect, special or consequential damages arising out of any use of, or inability to use, this Site or the information contained on it, including, without limitation, any lost profits, business interruption, loss of programs or data on your equipment or otherwise, even if Shenkman is expressly advised of the possibility or likelihood of such damages. This does not affect the liability of the Shenkman and its affiliates for any loss or damage which cannot be excluded or limited under applicable law.

Third-Party Disclaimers

From time to time, Shenkman may use index information and related data sourced from ICE Data Indices, LLC (“ICE BofAML”). Such index information and related data is used with permission. ICE BofAML PERMITS USE OF THE ICE BofAML INDICES AND RELATED DATA ON AN “AS IS” BASIS, MAKES NO WARRANTIES REGARDING SAME, DOES NOT GUARANTEE THE SUITABILITY, QUALITY, ACCURACY, TIMELINESS, AND/OR COMPLETENESS OF THE ICE BofAML INDICES OR ANY DATA.

The materials on this Site may contain information obtained from third parties, including ratings from credit ratings agencies such as Standard & Poor’s. Reproduction and distribution of third party content in any form is prohibited except with the prior written permission of the related third party. Third-party information contained on this Site was obtained from sources that Shenkman Capital considers to be reliable; however, no representation is made as to, and no responsibility, warranty or liability is accepted for, the accuracy, completeness, timeliness or availability of such information, including ratings. Neither Shenkman nor any third party content provider is responsible for any errors or omissions (negligent or otherwise), regardless of the cause, or for the results obtained from the use of such content. NEITHER SHENKMAN NOR ANY THIRD PARTY CONTENT PROVIDERS GIVE ANY EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE. NEITHER SHENKMAN NOR ANY THIRD PARTY CONTENT PROVIDERS SHALL BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, EXEMPLARY, COMPENSATORY, PUNITIVE, SPECIAL OR CONSEQUENTIAL DAMAGES, COSTS, EXPENSES, LEGAL FEES, OR LOSSES (INCLUDING LOST INCOME OR PROFITS AND OPPORTUNITY COSTS OR LOSSES CAUSED BY NEGLIGENCE) IN CONNECTION WITH ANY USE OF THIS CONTENT, INCLUDING RATINGS. Credit ratings are statements of opinions and are not statements of fact or recommendations to purchase, hold or sell securities. They do not address the suitability of securities or the suitability of securities for investment purposes, and should not be relied on as investment advice.

Jurisdictional Restrictions

The distribution of the information on this Site may be restricted by law in certain countries. This Site and the information and documentation herein are not addressed to any person resident in the territory of any country or jurisdiction where such distribution would be contrary to local law or regulation. Shenkman expressly disclaims all responsibility if you access this Site in breach of any local law or regulation in the country in which you are residing or of which you are a citizen.

For European Economic Area (“EEA”) Investors: Shenkman Capital Management Ltd is authorized and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom. This Site is directed only at persons who are classified as “professional clients” in accordance with the Markets in Financial Instruments Directive (Directive 2014/65/EU) (known as “MiFID II”) or as otherwise defined under applicable local regulations.

In relation to member states of the EEA that have implemented the EU Directive on Alternative Investment Fund Managers (Directive (2011/61/EU)) (“AIFMD”), interests in certain funds whose details may appear on this Site will only be offered or sold to investors in any such member state to the extent that the relevant fund: (i) is permitted to be marketed into the relevant member state pursuant to Article 42 of the AIFMD (as implemented into applicable local law); or (ii) where any marketing, offer and sale of interests of the fund occurs exclusively at the initiative of the relevant investor.


Questions concerning the Site or these Terms of Service can be addressed to Shenkman’s Legal Department at or +1 212 867 9090.