Web Privacy Policy
Effective Date / Last Updated: December 12, 2025
OUR COMMITMENT TO PRIVACY: Z Capital Group, LLC (“ZCG”, “we”, “our”, & “us”) is providing this privacy notice (this “Privacy Notice”) to you to help you better understand why and how we collect certain personal information, the care with which we treat that information, and how we use that information on the sites and services where it is posted. You can view information about privacy rights requests and our notice at collection in the Your US State Privacy Rights section below.
This Privacy Notice describes the privacy policies and practices of ZCG, including our practices on the sites and services where this Privacy Notice appears. It does not apply to the privacy policies and practices of individual portfolio companies within the ZCG of companies. For information about the privacy policies and practices of a portfolio company within ZCG, please review the privacy policy for that portfolio company.
1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT: In connection with forming and operating our private investment funds, providing advisory services, performing asset management services for our limited partners and clients, and operating our websites, we may collect and maintain the following categories of personal information (depending on how you interact with us):
- Personal identifiers: contact information, including your name, company name, mailing address, email address, and phone number, and government identifiers (e.g., a Social Security Number or equivalent tax identification number);
- General location information: city, state, or geographic area;
- Internet and network activity information: your IP address, device identifiers, session IDs, cookie IDs, your browsing history on our sites, the length of time spent on certain pages, the website URL you came from and the URL you visit when you leave us, your device type, what browser you are using, Internet service provider information, the date/time of your visit, and information about your operating system. On certain of our sites, we may also use tools to look at mouse movements, clicks, keystrokes, data or text entered, and the pages you visit;
- Transactional and financial information: information about your assets, investment experience, transaction history, income, and financial accounts, including wire transfer instructions; and
- Other information you choose to provide: the contents of the message and/or attachments you may send us.
Some of this information, including government identifiers and financial account information, may be considered “sensitive” under the laws of certain jurisdictions (“Sensitive Information”). Whether information is Sensitive Information will depend on the laws of your jurisdiction.
2. SOURCES OF PERSONAL INFORMATION: We collect and maintain personal information from the following sources:
- Information we receive directly from you, including from investors in conversations over the telephone, in voicemails, through written correspondence, via e-mail, or on subscription agreements, investor questionnaires, applications or other forms;
- Information about investors’ transactions with us or others, including affiliates or non-affiliated companies; and
- Information captured on our website, including registration information and any information captured automatically via cookies, tags, and other tracking tools we and third parties use on our sites.
3. HOW WE USE PERSONAL INFORMATION: We use each of the categories of personal information we collect in various ways, including to:
- Provide, operate, and maintain our services and offerings, including investor and advisory services;
- Open accounts and process transactions;
- Improve, personalize, and expand our services and offerings;
- Market products and services to you, including targeting our advertising to you;
- Understand and analyze how you use our sites and services;
- Develop new services, offerings, features, and functionality;
- Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to our services and offerings, and for marketing and promotional purposes;
- Send you emails;
- Find and prevent fraud;
- Respond to court orders, regulatory inquiries, and legal investigations; and
- Comply with any legal obligations and enforce our legal rights.
To create aggregated and/or de-identified data, for other purposes we may describe to you at the time, and for other purposes as permitted or required by law. We do not attempt to re-identify de-identified data, except as permitted or required by law.
We use Sensitive Information for necessary or reasonably expected purposes – specifically, to provide you with our services (i.e., to allow account logins), to comply with our legal obligations, and as authorized by law.
4. DISCLOSURE OF INFORMATION: We share personal information within the ZCG family of companies, including with our subsidiaries, affiliates, and the entities listed in Section 9 of this Privacy Notice. We also share your personal information as we believe in good faith to be necessary or appropriate to comply with or as permitted by law (e.g., with regulators); as necessary, with service providers (e.g., to host and operate our website, to send you communications, or to service investor accounts), auditors, lenders, brokers, or fund administrators; with financial institutions with whom we have joint marketing relationships (e.g., placement agents); as directed by investors; and for compliance, fraud prevention, and safety purposes; and with third party partners for purposes of analytics and targeting our advertising. These partners may include analytics companies, ad networks, and social platforms. These third parties may use the information for their own marketing purposes or the marketing purposes of others. For information about your choices for this kind of sharing, see the “Your Choices” section, below. We will share your personal information if we are acquired by or enter into a merger with another company, if we sell all or part of our business, or otherwise reorganize our business. We may also share aggregated or de-identified information that cannot reasonably be used to identify you.
5. YOUR CHOICES:
- To stop receiving marketing emails, use the unsubscribe link at the bottom of each message or email us at unsubscribe@zcg.com. Even if you opt out of getting marketing messages, we may still send you transactional messages. These include responses to your questions.
- You can control cookies and tracking tools. If you would like to opt out of the use of certain cookies, pixels, and tracking tools, click the “cookie” icon in the bottom left corner of each page of our site, and use the available toggles to indicate your preferences.
Your browser may also give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. You can also opt out of use of certain kinds of tracking tools on our site or others for online behavioral advertising by visiting the DAA’s Consumer Choice page at http://www.aboutads.info/choices/. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.
We also use Google Analytics to evaluate the use of our site. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects personal information, review Google’s Privacy Policy and its opt-out tool at https://tools.google.com/dlpage/gaoptout. - Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to older, browser-based do-not-track signals that do not meet applicable state law requirements. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop. Certain options you select are browser- and device-specific.
6. YOUR US STATE PRIVACY RIGHTS: You may have the following rights, where provided under applicable state law, regarding your personal information (each of which are subject to various exceptions and limitations):
- Access. You may request that we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the categories of personal information sold or shared, the business or commercial purpose for collecting, selling, or sharing the personal information, the categories of third parties with whom personal information was shared, and the specific pieces of personal information collected about you.
- Correction. You may request that we correct inaccurate personal information collected from you.
- Deletion. You may request that we delete your personal information that we maintain about you, subject to certain exceptions.
- Opt Out. You have the right to opt out of the sale or sharing of your personal information or targeted advertising as these terms are defined under applicable U.S. state privacy laws. You can opt out of certain tracking tools on our website by clicking the “cookie” icon in the bottom left corner of each page of our site, where it appears. You can also click this icon to see a list of certain third parties to which we may have disclosed personal information.
- No Discrimination. You have the right not to be discriminated against for exercising these rights.
- Appeals. You have a right to appeal decisions concerning your ability to exercise your consumer rights.
- Submission of Requests. You may exercise the above rights by emailing us at customerservice@zcg.com. Note that we may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes.
- Authorized Agent. You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent and can show written permission from you to represent you. We may contact you directly to confirm that you have authorized the agent to act on your behalf and confirm your identity.
- Verification. Whether you submit a request directly on your own behalf, or through an authorized agent, we will take reasonable steps to verify your identity prior to responding to certain of your requests. The verification steps will vary depending on the sensitivity of the personal information.
For California Residents:
- For our Notice at Collection, please see Sections 1-4 and 7 of this Privacy Notice.
- Shine the Light. If you reside in California, you have the right to ask us once each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at customerservice@zcg.com, or call us using the contact information listed below. Indicate in your communication that you are a California resident making a “Shine the Light” inquiry.
7. INFORMATION SECURITY AND RETENTION: We employ standard physical, electronic and procedural safeguards to protect personal information in our possession or under our control. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security. We will keep your personal information for the time period necessary to achieve the purposes outlined in this Privacy Notice, taking into account applicable statute of limitation periods and records retention requirements under applicable law. Subject to applicable law, we will retain personal information as required by the company to meet our business and compliance obligations, for example, to comply with our tax and accounting obligations.
8. FORMER LIMITED PARTNERS AND CLIENTS: In order to remain in compliance with applicable legal and regulatory requirements, we may maintain non-public personal information of our former limited partners and clients and apply the same policies that apply to current limited partners and clients.
9. ENTITIES PROVIDING THIS NOTICE ARE AS FOLLOWS:
- Z Capital Partners Adviser, L.P.
- Z Capital Partners UGP, L.L.C.
- Z Capital Partners GP I, L.P.
- Z Capital Partners I, L.P.
- Z Capital Partners I-A, L.P.
- Z Capital Partners GP II, L.P.
- Z Capital Partners II, L.P.
- Z Capital Partners II-A, L.P.
- Z Capital Partners II-B, L.P.
- Z Capital Partners GP III, L.P.
- Z Capital Partners III, L.P.
- Z Capital Partners III-A, L.P.
- Z Capital Credit Partners, L.L.C.
- ZCG Liquid Opportunity Fund, L.P.
- Z Capital Liquid Opportunity Offshore Fund Ltd.
- Z Capital Liquid Opportunity Intermediate Fund, Ltd.
- Z Capital Liquid Opportunity Master Fund, Ltd.
- Z Capital CLO Management, L.L.C.
- Z Capital Credit Partners BSL CLO 2024-1 Ltd.
- Z Capital Credit Partners CLO 2021-1 Ltd.
- Z Capital Credit Partners CLO 2019-1 Ltd.
- Z Capital Credit Partners CLO 2018-1 Ltd.
- Z Capital Credit Partners Adviser, L.P.
- Z Capital Credit Tactical GP, L.P.
- Z Capital Credit Tactical Fund, L.P.
- Z Capital Credit Tactical Fund (Cayman), L.P.
- Z Capital Credit Tactical Co-Invest Fund-A, L.P.
- ZCG Strategic Equity GP, L.P.
- ZCG Strategic Equity Fund, L.P.