Privacy Policy

Your Privacy on this Website

We collect information about your visit www.firstreserve.com through cookies and web beacons. You can opt out through your browser, but then you will not have access to all the functions of the website. To learn more, click here to read our Privacy Policy.

 
Introduction

This Cookie Statement explains how First Reserve Management, L.P. (“First Reserve,” “we,” “us,” or “our”) uses cookies on our websites and online services, and the choices you have.

This Cookie Statement provides you with clear and comprehensive information about the cookies we use and the purposes for using cookies. To review the privacy policies that apply to users of www.firstreserve.com, please read our Privacy Policy.

Definition of “Cookies”

Cookies are small pieces of text used to store information on web browsers. Cookies are widely used to store and receive identifiers and other information on computers, phones, and other devices. We also use other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, including web beacons and pixel tags, for similar purposes. In this Cookie Statement, we refer to all of these technologies as “cookies.”

Types of Cookies

We use cookies to provide, protect, and improve our products and services, such as by personalizing content, offering and measuring advertisements, understanding user behavior, and providing a safer experience. We describe below the various types of cookies we use and the purposes they perform:

Browsing or session (essential) cookies: These cookies are strictly necessary to provide you with our websites and services and to enable essential features. If you disable these cookies, we will not be able to fulfill your requests.

Performance and functionality cookies: These cookies collect information about how you use our websites and services and allow us to remember the choices you make while browsing. The information these cookies collect allows us to optimize our websites and make them easier for you to use, and it does not personally identify you. If you disable or opt out of these cookies, you may not be able to use certain features of our websites and services. Additionally, it may reduce the support or information that we can provide you.

Analytics and customization cookies: These cookies collect information we use in aggregate form to help us understand how our websites, applications and services are being used and how effective our marketing campaigns are, and to help us customize our websites. If you disable or opt out of these cookies, you may not be able to use certain features of our websites, applications and services, and it may reduce the support or information that we can provide you.

Advertising (profiling) cookies: These cookies collect information about your browsing or shopping history and are used to make advertising messages more relevant to you. They perform functions like preventing the same advertisement from continuously reappearing, ensuring that advertisements are properly displayed, and in some cases selecting advertisements that are based on your interests. We may share this information with third parties to help create and deliver advertising personalized to you and your interests. If you disable or opt out of these cookies, you may not be able to use certain features of our websites, applications and services, and it may reduce the support or information that we can provide you.

Social networking cookies: These cookies are used to enable you to share pages and content on our websites and services through third-party social networking and other websites. These cookies may also be used for advertising purposes.

In detail, the cookies present on the First Reserve website are as follows:

Technical name Data Controller/ Provider Cookie type, function and purpose Duration
rc::a google.com HTML Persistent
rc::b google.com HTML Session
rc::c google.com HTML Session
_ga firstreserve.com HTML 2 years
_gat firstreserve.com HTML 1 day
_gid firstreserve.com HTML 1 day
ads/ga-audiences google.com Pixel Session
NID google.com HTTP 6 months
Cookies Placed by Third Parties

You may also encounter cookies on our websites, applications and services that are placed by third parties.

This Cookie Statement does not apply to the cookies, applications, technologies, or websites that are owned and/or operated by third parties, or such third parties' practices, even if they use or access our technology to store or collect information. To understand how third parties use cookies, please review their privacy and cookie policies. As an example, please refer to the Google policy here:

Google: Privacy Policy

Changing Your Cookie Settings

Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. To understand these settings, the following links may be helpful. Otherwise you should use the ‘Help’ option in your internet browser for more details.

Opting Out of Cookies

If you wish to withdraw your consent at any time, you will need to delete your cookies using your internet browser settings. For further information about deleting or blocking cookies, please visit: http://www.aboutcookies.org/Default.aspx?page=2.

If you choose to reject cookies, as noted above, you may not be able to use certain features of our websites and services.

Do Not Track

Some browsers include the ability to transmit “Do Not Track” signals. We do not process or respond to “Do Not Track” signals. Instead, we adhere to the standards described in our Privacy Policy and this Cookie Statement.

More Information About Cookies

All About Cookies

Useful information about cookies can be found at: http://www.allaboutcookies.org

Internet Advertising Bureau

A guide to behavioral advertising and online privacy has been produced by the internet advertising industry which can be found at: http://www.youronlinechoices.eu

Privacy Policy

First Reserve Management, L.P. and its affiliates (“First Reserve”, “we”, “us”, or “our”) are committed to protecting the privacy of personal information (as such term and similar terms are defined under applicable privacy laws) (“PI”) of individuals who interact with us, such as by visiting our website (including our investor portal) (the “Site”) or our premises, inquiring about or using services associated with our business available through our Site (the “Service/s”), expressing interest in our business, applying for employment with us, or engaging in email or other communications with us, all of which are subject to this Privacy Policy. Other than in relation to PI processed through our investor portal, this Privacy Policy does not address our privacy practices with respect to any PI we may collect from (i) investors or potential investors in investment vehicles that we sponsor or manage or (ii) our employees and contractors once employed or engaged with First Reserve. We address these practices in separate notices to such individuals as required by applicable laws.

This Privacy Policy explains certain of our PI-related policies and practices. It includes, but is not limited to, explanations of the types of PI we collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, some of the measures we take to secure the confidentiality of such information, your rights regarding your PI, and how to contact us to exercise those rights. Amendments to this Privacy Policy will be posted to the Site and will be effective when posted. Your continued interaction with us, including by visiting the Site or our premises, using the Services, applying for employment with us or engaging in email or other communications with us following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendments. If you do not agree with any provision of the Privacy Policy, you should not use our Services or the Site, visit our premises, apply for a job with us or otherwise provide information to us such as via email or otherwise.

Categories of PI We Collect

This section explains categories of PI that we may have collected over the last twelve (12) months when you use our Services, visit the Site or our premises or otherwise interact with us:

  • Identifiers and other customer records, including contact details, such as your full name, e-mail address, postal address, IP address, telephone number, usernames and passwords, financial account information and other PI provided;
  • Internet or other network activity and technical information, such as information regarding your use of the Site (e.g., cookies, browsing history and/or search history, page interaction information), as well as comments, feedback and other information you provide to us when you correspond with us in relation to inquiries;
  • Audio, electronic, visual or similar information, including photographs and CCTV footage;
  • Physical access information relating to details of your visits to our offices;
  • Commercial information and financial information, such as financial account information;
  • Mailing list information, such as interests and communication preferences, including marketing permissions where appropriate;
  • Certain sensitive PI, for example, government identifiers (e.g., SSN, driver's license) or complete account credentials;
  • Professional or employment-related information (e.g., employment details, occupational history or business relationships);
  • Education information; and
  • Other information you provide, or which may be incidentally processed, when you contact us.

We may collect PI from third-party sources, which may include publicly available sources of information. Additionally, we may collect and retain a record of all communications with you, in accordance with applicable laws.

The Site and our Services are not intended or designed to be used by children under the age of 18. We do not collect PI from any person we know to be under the age of 18 and children under 18 should not send us any information.

How We Obtain Your PI

We may collect and maintain your PI from the following sources:

  • Information from your communications with us in connection with the Services, the Site, your job application and/or information that is otherwise provided by you, including through online forms;
  • Information from your visits to our premises; and
  • Information captured on the Site or via your job application, including information captured electronically as a result of your use of same.

We may combine PI that you provide to us with information that we collect from or about you from third parties or publicly available sources. This may include information collected in an online or offline context. For example, we may receive payment information from the organization you use to pay us in order to correct our records. Additionally, to promote protection of your identity, we also may collect credit or identity information which we use to help prevent and detect fraud.

Purposes for Collecting Your PI

Depending on the nature of your interaction with First Reserve, we may use your PI for the following purposes:

  • Contacting you or your designated representative and responding to your requests and inquiries, such as by phone, email, fax, or mail;
  • Providing you or your representative with marketing communications related to our Services and/or other activities such as events;
  • Creating and managing your account with us;
  • Sharing information about our Services including investment research;
  • Facilitating financial transactions related to your account;
  • Fulfilling our legal, regulatory and/or compliance obligations and bringing and/or defending legal, regulatory and/or compliance claims; and
  • Any other purpose we have notified you about.

In addition, we utilize the aggregate Site usage information described above to better understand how visitors are utilizing the Site in order to enhance the Site experience.

Lawful Basis

There is a need to process PI for the purposes set out in this Privacy Policy as a matter of contractual necessity under or in connection with the applicable agreement, and in the legitimate interests of First Reserve to operate their respective businesses. From time to time, First Reserve may need to process the PI on other legal bases, including: to comply with a legal obligation; if it is necessary to protect the vital interests of an investor or other data subjects; or if it is necessary for a task carried out in the public interest. For the purposes listed above, First Reserve is relying on performance of a contract necessity and legitimate interests.

A failure to provide the PI requested to fulfill the purposes described in this Privacy Policy may result in First Reserve being unable to provide the services in connection with the terms of the subscription agreement.

Our Site and Use of Cookies

Please refer to our Cookie Statement

Automated Decision Making

We do not use automated processing, including profiling, to make decisions.

To Whom We Disclose Your PI

Within the last twelve (12) months, we may have disclosed each of the categories of PI we have collected to service providers and as described below.

In the regular course of business, we do not disclose any information collected from the publicly available areas of the Site to any parties outside of First Reserve other than service providers, professional advisors and affiliates pursuant to applicable law. We may disclose PI otherwise voluntarily provided by you (e.g., via email or through other interactions with us) to our affiliates, service providers, prospective or current investors in applicable funds, agents, contractors, professional advisors, business partners, lenders, data processors and persons employed and/or retained by them, and other third parties for the purposes of operating our business, delivering and improving the Services we provide to you, helping to facilitate transactions (including processing orders, event registrations, data storage, marketing communications and customer support), performing functions on our behalf and for other legitimate purposes permitted by applicable law and in order to fulfill the purposes described in this Privacy Policy. [For example, we may use third-party service providers in connection with the Site, such as Altvia Solutions, LLC, which we use as a service provider for our investor portal. More information on how Altvia Solutions, LLC uses your PI can be found at https://www.sharesecurely.com/privacy-policy/.

These entities and individuals may have access to the PI we collect from you as permitted by law and as needed to perform their functions, in compliance with our privacy practices and policies. We require that these entities and individuals otherwise keep this information confidential.

We may disclose your PI to third parties for the following additional purposes:

  • To applicable third parties (i) to protect your safety or security or the safety or security of tangible or intangible property that belongs to us, to you or to third parties or (ii) in connection with a potential or actual reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding or other disposition of all or any portion of our business, assets or shares.
  • First Reserve may share PI with regulatory bodies having competent jurisdiction over them, as well as with tax authorities, auditors and tax advisors (where necessary or required by law, rule or regulation).

To the extent that we request PI from you and you refuse to communicate that PI to us, this may affect our ability to maintain a business relationship with you or to comply with our legal obligations.

We do not use or disclose sensitive PI for purposes other than those specified in Section 7027(m) of the implementing regulations (the “CCPA Regulations”) of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together with the CCPA Regulations, collectively, the “CCPA”). We do not “sell” or “share” (as such terms are defined by the CCPA) any of your PI that we collect to third parties.

How Long We Retain Your PI

For each of the categories of PI that we collect (listed above), we retain such PI only for as long as reasonably necessary to fulfill the purposes we collected it for, including for purposes of satisfying any legal, regulatory, accounting or reporting requirements, unless a longer retention period is otherwise required or permitted by law.

Transfers of PI

Your PI may be transferred, processed and/or stored in a country other than the one in which your PI is collected. When transferring your PI to the US or other countries, we have implemented procedures to ensure that appropriate safeguards are in place to protect the PI regardless of where it is being transferred to.

First Reserve may transfer PI to a non-equivalent country (a country or territory other than (a) a member state of the EEA; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU law to ensure an adequate level of protection for PI), in order to fulfill the purposes described in this Privacy Policy and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer agreements, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact compliance@firstreserve.com.

Your EU Data Subject Rights

The European Union's General Data Protection Regulation (“GDPR”) is a sweeping piece of legislation that grants EU residents increased control over their PI. The GDPR allows consumers to access their PI and find out details of how that data is processed, to rectify inaccurate PI, to have their data erased (when certain conditions are met), to restrict processing of their data, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to ensure that PI is secured.

Specifically, the GDPR and other national privacy laws provide data subjects with certain rights regarding their PI. If you are an individual who resides in the EU and whose PI is collected and processed by First Reserve, you have the right to:

  • Request access to your data
  • Rectify your data
  • Take your data (in a readable, “portable” format) to another service provider
  • Erase your PI
  • Restrict or object to the processing of your PI
  • Lodge a complaint with a Member State Supervisory Authority
  • Withdraw previously given consent to collect and process PI (which will not impact PI processed before the withdrawal)
PI Rights for California Residents

The CCPA requires us to make certain additional disclosures and provides California residents with certain rights with respect to their PI. These disclosures and rights apply to you only if you are a California resident as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection and processing of their PI that is not set forth below is otherwise set forth in the Privacy Policy [above].

Please note that the below rights under the CCPA do not apply to (i) any PI we collect that is subject to the Gramm-Leach-Bliley Act (Public Law 106-102) or (ii) certain PI we collect that is subject to the Fair Credit Reporting Act (12 CFR 1022) under certain circumstances.

Only if you are a California resident (as determined in accordance with the CCPA) whose PI is collected or processed by First Reserve, you have the following rights with respect to such PI:

  • Disclosure and Access Rights: You have the right to request that we disclose to you, free of charge, certain information regarding our collection and use of PI specific to you over the last twelve (12) months. Such information includes:
    • the categories of PI we collected about you;
    • the categories of sources from which the PI was collected;
    • the categories of third parties to whom we disclosed the PI;
    • our business or commercial purpose for collecting such PI;
    • the specific pieces of PI we have collected about you; and
    • whether we disclosed your PI to a third party and, if so, the categories of PI that each recipient obtained.
  • Correction Rights: You have the right to request that we correct inaccurate PI about you.
  • Deletion Rights: You have the right to request that we delete any of your PI that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S. state and local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Non-Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying Services, suggesting that you will receive (or charging) different rates for Services or suggesting that you will receive (or providing to you) a different level or quality of Services.

Questions or Concerns and Exercising Your CCPA Rights

If you have any questions or concerns regarding the information in this Privacy Policy, or would like to exercise any of your rights under the CCPA as set forth in this Privacy Policy, please calls us toll-free at + 1 833 450 1282 or email us at compliance@firstreserve.com. Please include a description of what right you want to exercise (if applicable) and the information to which your request relates. Please note that you may only make a PI disclosure request twice within a 12-month period.

Verifying Your Identity

If you choose to contact us with a request under the CCPA, we will contact you to confirm receipt of your request and to request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (e.g., the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, to verify your request.

Authorized Agent

You have the right to appoint an authorized agent to make requests under the CCPA on your behalf if you provide a signed agreement verifying such authorized agent's authority to make requests on your behalf, and we may verify such authorized person's identity using the procedures above.

California's Shine The Light Law

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our website users who are California residents to request and obtain from us a list of their PI (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.

Accessibility Information

For consumers with disabilities who need to access this policy in an alternative format, please contact: compliance@firstreserve.com.

This Privacy Policy was last updated and posted on 01/23/2024