Privacy Policy

Last Updated: February 22, 2019

Respecting and protecting privacy has always been vital to our business. This Privacy Policy describes how MidCap Financial Services LLC (together with its subsidiaries and affiliates, “MidCap”, “us”, “we” or “our”) gathers and uses personal information about you when you visit MidCap’s website (www.midcapfinancial.com) (the “Site”); how we protect and share this information; and the rights you may have in relation to this information. Please read this Privacy Policy carefully, and consult our Terms and Conditions for more information about the general terms and conditions regarding your use of the Site.

In the event that you have any questions or concerns about this Privacy Policy, please contact our Privacy/Compliance Office at Compliance@midcapfinancial.com.

A. The Types of Information We Collect

We do not collect any personal or non-personal information about you via our website; however, you have the option to submit information to us via the email addresses listed on the Site. “Personal information” is any information relating to an identified or identifiable natural person. “Non-personal information” includes technical information that does not identify an individual personally.

The Site may contain links to websites operated by third-parties, and your personal information may be collected by those third-parties when you use their websites.

Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We are not responsible for the privacy policies and practices of any third-party website (whether or not such site is linked on or to the Site). These links are provided to you for convenience purposes only, and you access them at your own risk.

Some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies. Our use of information received from such a third-party will be dictated by the third-party’s privacy policy and not this Privacy Policy.

B. The Security Measures We Take to Safeguard Information

The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We have implemented reasonable technical, administrative, and physical security measures to protect the information that we receive. From time to time, we review and consider updates for our security procedures. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable. Consequently, you understand that any information you transmit to us is done so at your own risk. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues which may relate to you. We may post a notice via the Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

C. Updating Your Contact Information

You may update your contact information and/or modify your communication preferences by sending us an e-mail at Compliance@midcapfinancial.com.

D. Children’s Information

The Site is intended for use by those over 18. We do not knowingly solicit or collect personal information on the Site from users under the age of 18. If we learn that, despite these measures, someone under the age of 18 has submitted personal information to us, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the individual or others as required by law).

E. Do Not Track

We do not track your use of our Site. As such, do-not-track signals or other similar signals are not necessary. We do not currently respond to such signals.

We cannot control third-parties’ responses to do-not-track signals or other such mechanisms. Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

F. California Privacy Rights

If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you for the third-parties’ direct marketing purposes. If you wish to exercise those rights, please email us at Compliance@midcapfinancial.com.

G. Your Choices and Rights

If you no longer wish to receive marketing materials from us, you can let us know by contacting us at Compliance@midcapfinancial.com, or by clicking the ‘unsubscribe’ link or using other unsubscribe features that we provide in our marketing communications.

Subject to local law, you may have certain additional rights regarding your personal information.

If you are located in the EU, you have the following rights to:

  • access your personal information;
  • rectify the information we hold about you;
  • erase your personal information;
  • restrict our use of your personal information;
  • object to our use of your personal information (as described above);
  • withdraw any consent you have given to uses of your personal information;
  • receive your personal information in a usable electronic format and transmit it to a third-party (also known as the right of data portability); and
  • lodge a complaint with your local data protection authority.

If you would like to discuss or exercise the rights you may have, feel free to contact us at Compliance@midcapfinancial.com.

H. Where is Information Processed?

We process information provided by you in and subject to the laws of the United States, which may not provide the same level protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries. We may be required by law, regulation, professional standard or judicial process to disclose information to required authorities. You acknowledge you understand that by providing your personal information: (i) your personal information will be used for the uses identified above in accordance with this Privacy Policy; and (ii) in accordance with applicable law your personal information will be transferred to the United States and other jurisdictions as indicated above.

I. How Long Is Information Retained?

We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.

When deciding how long to keep your personal information after our relationship with you have ended, we take into account how long we need to retain the information to fulfill the purposes described above and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.

J. Amendments to this Privacy Policy

We may change this Privacy Policy from time to time. Should we do so, we will post the changes to this page. We will notify you of any material changes in the way we treat your information by placing a prominent notice on our Site. Your continued use of the Site after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.

K. How to Contact Us

If you have any questions regarding this policy or our privacy or data protection practices, please feel free to contact us using the information below:

MidCap Financial Services LLC
Privacy/Compliance Office
7255 Woodmont Avenue
Bethesda, MD 20814
Compliance@midcapfinancial.com