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PRIVACY POLICY

The effective date of this Privacy Statement (the “Policy”) is December 22 , 2016.

This Policy describes the privacy practices of Sutherland Asset Management, LLC (“Sutherland”) when you visit and use www.SutherlandAM.com (the “Site”) or any other website or online service where this Policy is posted. By using the Site, you are consenting to the collection, use, and disclosure of your information as described here. If you do not agree with this, please do not use the Site.

Scope of Policy

Terms and Conditions

This Policy is part of the Terms and Conditions for the Site.

Privacy Notices

This Policy includes any separate privacy notices and/or notices posted on particular pages of this Site that may provide more detail regarding the information we collect on those pages, why we need that information, and choices you may have about the ways we use that information.

Links to Other Sites

This Site contains links to other third party websites. This Policy does not apply to such unaffiliated websites.

Access to Site from Outside the United States

Your information is currently collected and stored on servers located in the United States, although we may transfer your information to our service providers and others located in the United States or another country for the purposes described in this Policy. No matter where your information is collected, used, transferred or stored, if it was collected through this Site, it will be governed by this Policy.

BY USING THIS SITE, YOU ARE CONSENTING TO THE COLLECTION, USE, TRANSFER AND STORAGE OF YOUR INFORMATION IN OR TO THE UNITED STATES OR TO ANY OTHER COUNTRY IN THE WORLD SUBJECT TO THE TERMS OF THIS POLICY.

Types of Information We Collect

Sutherland collects the following types of information from you when you use the Site.

Information You Volunteer

Sutherland collects information you knowingly and voluntarily provide when you use this Site. For example, we may collect your name, address, phone number, email address, organization or any other information you choose to provide when you request information from us.

Information Sent by Your Web Browser

We collect information that is sent to us automatically by your Web browser. This information typically includes your IP address (identifies your computer’s “location” and may be linked to account information that identifies you personally), the identity of your Internet service provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. Please check your browser if you want to learn what information your browser sends or how to change your settings.

Information We Receive from Third-Parties

We may receive information about you from third parties including public sources, our related companies, your organization, your representatives, information service providers, social media and the parties with whom we exchange information as described here.

Cookies and Similar Technologies

We may collect information about you when you visit the Site through the use of “cookies.” Cookies are small text files placed in visitors' computers to store their preferences. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to our website and will last for longer. We may use cookies and other methods to determine your domain name and what browser and operating system you are using, your Internet Protocol (IP) address, the date and time of your request if any, and the device you are using.

We may use cookies to:

  • remember that you have visited our Site before; this means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get;

  • customize elements of the promotional layout and/or content of the pages of our Site; and

  • collect anonymous statistical information about how you use our Site, including how long you spend on the Site and where you have come to our Site from, so that we can improve the Site and learn which parts of it are most popular with visitors.

As described in the following chart, some of the cookies used by our Site are set by us, and some may be set by third parties who are delivering services on our behalf.

Category

Purpose

Type and duration [i.e. session only or persistent]

Persistent Cookie

Saves user information that may be accessed every time a user visits our site.

Persistent – outlasts session duration.

Session Cookie

Saves user information that may be accessed only as long as the browser session exists.

Session – lasts only as long as the session duration.

Third Party

These cookies save information on the user’s computer and are accessed from domains different from the one shown in the address bar.

Persistent – outlasts session duration.

In addition to cookies, tracking GIFs may be set by us or third parties on our Site and in newsletters and emails. Tracking GIFs are small image files within the content of our Site or the body of our newsletters so we, or third parties, can understand which parts of the Site are visited and whether particular content is of interest.

Most web browsers automatically accept cookies but all computers have the ability to decline cookies. This can be done by activating the setting on your browser that enables you to decline the cookies. Please note that if you choose to decline cookies, you may be unable to access parts of our Site or use all of the functionalities on our websites. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers.

How We Use Your Information

In general, we use the information we collect through this Site:

  • to provide the information, products and services you request.

  • to better understand your needs and interests.

  • to improve the content, functionality and usability of this Site, including through the use of analytics services that may be provided by third parties.

  • to contact you with information and notices related to your use of this Site.

  • to improve our marketing and promotional efforts.

  • for security or fraud prevention purposes, and

  • for any other purpose identified in any other agreement between us.

We may aggregate and/or de-identify Information collected through the Site. We may use de-identified or aggregated data for any purpose and may share it with any third parties.

How We Share Your Information

Third-Party Vendors

We may share information collected through this Site with third-party vendors who act for or on behalf of Sutherland. These third-party vendors may need information about you to perform their functions.

Sutherland Related Companies

When you provide information through this Site we may share such information with Sutherland employees, our corporate parent Waterfall Asset Management, and any related companies. Any Sutherland related company is required to handle information collected through this Site in accordance with this Policy.

Business Negotiations/Transfers

We may contemplate, for strategic or other reasons, selling, buying, merging, or otherwise reorganizing one or more of our businesses. In negotiating with a third party about entering into such an arrangement, we may need to disclose your information. Your information may also be transferred to a successor organization if, for example, we transfer the ownership or operation of this Site to another organization or if we merge with another organization.

Compliance with Laws and Protection of Our Rights and the Rights of Others

We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce or apply our Terms and Conditions or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

Aggregate and/or De-Identified Information

We may share or disclose to any third parties information about you that has been aggregated and/or de-identified. This Policy does not restrict how we may collect, use or share aggregated or de-identified information.

Your Choices

In General

We respect your right to make choices about the ways we collect, use, and disclose your information. As noted above, you have choices about the delivery of cookies to your computer through this Site. Furthermore, you always have the choice to not provide information to us by not providing such information through the Site.

Emails

If we choose to send you commercial emails, we will provide with you option in those emails to unsubscribe. Alternatively, if at any time you wish to be taken off any Sutherland mailing list, please contact us at 212-257-4600. Once we have the information we need, we will remove you from our mailing lists as you have requested.

How to Access, Update or Correct Your Personal Information

If you wish to access, update, or correct your information, please contact us at 212-257-4600. We will respond to you within a reasonable time and, in any case, within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identify.

Online Analytics

We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers use cookies and similar technologies to help us analyze how users use the Site, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Site. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

California Online Privacy Protection Act Notice Concerning Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.

Steps We Take to Safeguard Your Personal Information/Security

We maintain administrative, physical, and technological measures to protect the confidentiality and security of the information you submit on or through this Site. These measures vary based on the sensitivity of the information that we collect. Unfortunately, no website, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that your information will not be disclosed, misused or lost by accident or by the unauthorized acts of others.

Children Under the Age of Thirteen

The Site is not intended for children or minors under the age of thirteen years. We do not knowingly collect “Personal Information” (as that term is defined under the Children’s Online Privacy Protection Act) from, or market online to, children under 13.

This Policy May Change

We reserve the right to update or modify this Policy at any time, without prior notice, by posting the revised version of this Policy behind the link marked “Privacy Policy” at the bottom of each page of the Site. Your continued use of this Site after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy.

Contact Us

If you have questions about this Online Privacy Statement, please contact us at 212-257-4600 or write to us at Sutherland Asset Management Corporation, LLC 1140 Avenue of the Americas, 7th Floor, New York, NY 10036.

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Contact

To contact Sutherland Asset Management Corporation please use the information below: 


Waterfall Asset Management, LLC 
1140 Avenue of the Americas, 7th Floor
New York, NY 10036


Bevin Black
Waterfall Asset Management, LLC
212-257-4629
bblack@waterfallam.com

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