Witt Lake Asset Management LLC

Privacy Policy

Last Updated: March 18, 2025

I. Who Are We?

Witt Lake Asset Management (“WLAM”) is an asset management platform offering a differentiated investment strategy across asset-based credit. WLAM combines industry experience with strategic asset allocation to generate attractive risk-adjusted returns across market cycles.

If you have any questions about this Privacy Policy or wish to make a request regarding your personal information, please contact us:

Witt Lake Asset Management
750 Washington Blvd, Suite 600
Stamford, CT 06901
+1 203-487-8200
info@wittlakeam.com

II. What Is Covered by This Privacy Policy?

This Privacy Policy describes how Witt Lake Asset Management LLC collects, uses, and shares personal data, and outlines your privacy rights.

This policy applies to:

  • Information collected through this website (the “Site”); and
  • Information collected offline, whether directly from you or from other sources.

By using the Site, you consent to the practices described in this Privacy Policy. We may update this policy periodically, and changes will take effect once posted. Continued use of the Site indicates acceptance of any updates.

Use of this Site is limited to individuals who are at least sixteen (16) years old. If you are under 16, please do not use this Site or provide any personal information.

This Privacy Policy does not apply to third-party websites, including those linked from our Site. Those websites are governed by their own privacy policies.

III. What Personal Information Do We Collect, From Where, and Why?

  1. Information We Do Not Knowingly Collect
    We do not knowingly collect information from individuals under the age of 18.
  2. Information You Provide Directly
    This may include your name, email address, mailing address, phone number, resume, contact preferences, and any messages you submit via our Site or other communications.
  3. Information from Third Parties
    We may receive information during due diligence processes, subject to applicable confidentiality agreements.
  4. Information Collected Automatically

    • IP Address: Used for system administration and diagnostics;
    • Cookies and Similar Technologies: Used to enhance functionality and user experience;
    • Do Not Track: We do not track users across third-party websites;
    • Analytics: Aggregated, anonymized data collected (e.g., via Google Analytics).

IV. What Personal Information Do We Share?

  1. No Sale of Personal Information: WLAM does not sell personal data.
  2. Service Providers: Information may be shared with trusted providers performing services on our behalf.
  3. At Your Direction: We may share information if you request or authorize it.
  4. Business Transfers: Information may be transferred in connection with a merger, sale, or restructuring.
  5. Legal Requirements: We may disclose information to comply with legal obligations.
  6. Internal Use: De-identified or aggregated data may be used for analysis and improvement.

V. How Do We Protect Personal Information?

We implement reasonable administrative, technical, and physical safeguards to protect your personal information.

VI. Your Rights Under the California Consumer Privacy Act (CCPA)

A. Definition of Personal Information

Personal Information (PI) includes data that identifies, relates to, or could reasonably be linked to an individual or household.

Your rights include:

  • The right to know what personal information is collected, used, or shared;
  • The right to access and request deletion of personal information;
  • The right to opt out of the sale of personal information;
  • The right to non-discrimination for exercising your rights.

B. Notice of Collection

We inform consumers of the categories and purposes of personal information collected at or before the time of collection.

C. Right to Know

Upon request, we will disclose:

  • Categories of personal information collected;
  • Sources of that information;
  • Business purposes for collection;
  • Third parties with whom it is shared;
  • Specific pieces of personal information collected.

D. Right to Delete

You may request deletion of your personal information, subject to certain exceptions, including:

  1. To complete transactions or provide services;
  2. To detect and prevent fraud;
  3. To comply with legal obligations;
  4. For internal uses aligned with reasonable expectations.

E. Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

F. Right to Opt-Out

Where applicable, you have the right to opt out of the sale of personal information.

G. Privacy Policy Requirements

This Privacy Policy describes your rights, how to submit requests, and categories of personal information collected or disclosed in the past 12 months.

VII. How Do I Make a CCPA Request?

A. Submitting a Request

California residents may submit a request by calling +1 203-487-8200. A confirmation and reference number will be provided.

B. Verification

You must provide sufficient information to verify your identity. Authorized agents must provide appropriate documentation.

C. Our Response

We will respond within 45 days. If we cannot fulfill your request, we will explain why. We do not charge fees unless requests are excessive or repetitive.

VIII. Contact Information

Call: +1 203-487-8200
Email: info@wittlakeam.com