Last Updated: January 1, 2023
This Privacy Notice (“Notice”) describes how Ares Management LLC and its affiliates, including its UK affiliate Ares Management Limited (“Ares”, “we” “us,” or “our”), collects Personal Information (as defined below) and our information practices regarding Personal Information, when you visit our website at www.aresmgmt.com (the “Website”) or otherwise interact with us (collectively our “Services”).
We are an LLC established in the United States with our registered office at 2000 Avenue of the Stars, 12th Floor, Los Angeles, CA 90067 and for the purpose of the General Data Protection Regulation (the "GDPR"), we are the data controller.
If you wish to contact Ares regarding your Personal Information (as defined below) or this Notice, please contact [email protected]. Where the General Data Protection Regulation (the “GDPR”) applies you may also contact our representative in the EU: Ares Management Limited at 5th Floor, 6 St Andrew Street, London, EC4A 3AE.
Please note, to the extent information is protected by the Gramm-Leach-Bliley Act (“GLBA”), please refer to our GLBA Notice.
QUICK REFERENCE GUIDE
- Personal Information We Collect
- How We Use Personal Information
- How We Disclose Personal Information
- Advertising and Tracking Cookies
- Links to Third-Party Sites
- Where Do We Store Personal Information
- Retention of Personal Information
- GLBA Notice
- Notice to Europe Residents
- Notice to California Residents
- How You Can Contact Us
1. Personal Information We Collect
We collect information that describes or relates to you (“Personal Information”). Personal Information does not include:
- Publicly available information as defined under applicable laws.
- De-identified or aggregated information.
Ares will collect Personal Information directly from you and automatically through our Website.
- Personal Information We Collect Directly From You
The Personal Information we collect from you depends on how you interact with our Services, but generally includes the following.
- Contact Information. For example, you may provide your name, institution name. address, city, state, zip/postal code, country, email address, phone number, and fax number.
- Communications Information. We may also collect other information that you choose to provide to us in your subject line and message when you contact us.
We collect additional Personal Information about registered investors and representatives of investors. Our information practices related to this Personal Information is governed by our Investor Privacy Notice.
- Intralinks: https://www.intralinks.com/privacy
- Dynamo: https://www.dynamosoftware.com/privacy-policy
- Investor Flow: https://www.investorflow.com/privacy.html
We also collect Personal Information from applicants for the positions described in the “Careers” section of the Website that is subject to a separate policy that describes our information practices with regard to applicants and candidates. For more information, please our Candidate Privacy Notice.
Where you sign up to receive email notifications from us on our Website, we will send the communications that you have requested (including information about corporate events, press releases, presentations and company documents). You can opt-out of receiving such communications at any time by contacting us as detailed under Section 14 below.
- Personal Information We Collect Automatically
Like most website operators, we collect Personal Information through cookies and other technologies on our Website. This includes the following Personal Information, depending on your browser and settings.
- Domain Name
- Country or region information.
- Browser type.
- Pages viewed and activities conducted.
- Links Clicked
- IP Address.
- Length of session.
- Referring URL for the website.
- Advertising ID
- Language Information
- Operating system, name, and version.
What are cookies? A cookie is a piece of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website using that browser. When you access our Website, we place cookies on your computer. Some cookies allow us to make it easier for you to navigate our Sites, while others are used to enable a faster log-in process or to allow us to track your activities on our Sites. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged in. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through the website. Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device.
3. How We Use Personal Information
We use the Personal Information we collect for the following purposes:
- Operating Services and Providing Related Support. To provide and operate our Services, communicate with you about your use of the Services, verify user eligibility to access restricted areas of our Website, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments and claims, communicate with you about the Services, and for similar service and support purposes.
- Analytics and Improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features, and for internal quality control and training purposes.
- Customization and Personalization. To tailor content we may send or display on the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
- Marketing and Advertising. For marketing and advertising purposes. For example, to send you information about our Services, such as offers, promotions, newsletters, and other marketing content, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content.
- Compliance and Legal Process. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.
- General Business and Operational Support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.
- Business Transfers. To consider and implement mergers, acquisitions, reorganizations, and other business transactions, and where necessary to the administration of our general business, accounting, recordkeeping, and legal functions.
4. How We Disclose Personal Information
We may disclose Personal Information with selected recipients. These categories of recipients include:
- Our Service Providers. We may disclose Personal Information we collect with our service providers who perform functions on our behalf. These service providers include IT service providers, website development and analytics providers, email management companies, and customer support. We require that these service providers do not sell, transfer or use your Personal Information gathered on this website other than in accordance with this Notice.
- Subsidiaries and Affiliates. We may disclose Personal Information we collect to our subsidiaries or affiliates.
- Third-Party Analytics Providers. We may disclose Personal Information to marketing analytics service providers such as Google Analytics.
We may disclose Personal Information to the parties listed above for the following purposes:
- Operating Our Website and Services. We may disclose Personal Information to provide and operate our Website and Services.
- Marketing and Communications. We may disclose Personal Information to third-party ad networks in order to serve advertisements on our Website and on third-party websites or other media. This enables us and these third parties to target advertisements to you for products and services in which you might be interested.
- Fraud Prevention. We may disclose user information when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity; to protect the safety, rights, or property of the company, and of its users, or others; or to exercise or protect legal rights or defend against legal claims.
- Law Enforcement and Litigation. To the extent permitted by law, any information collected over our Website or concerning its use may be disclosed to government authorities or third parties pursuant to a legal or regulatory request, subpoena, or other legal process. We may also use or disclose your information as permitted by law to protect the rights or property of Ares, our customers, our Website, its users, or third parties, or when we otherwise believe in good faith that the law requires it.
- Business Transfers. If Ares incurs a corporate change in control resulting from, for example a sale to, or merger with, another entity, or if all or a portion of its assets are sold, Ares reserves the right to transfer your Personal Information to the new party in control or the party acquiring assets. As part of the business transfer process, we may share certain of your Personal Information with lenders, auditors, and third-party advisors, including attorneys and consultants.
5. Advertising and Tracking Cookies
If you wish to prevent cookies or third-party advertisers from tracking your activity on our Website or visits across multiple websites, there are tools you can use to disable cookies and opt out of interest-based advertising. Using the resources below does not mean you will no longer receive any advertising through our Website, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular Website that you are viewing (i.e., contextually based ads). Your opt-out may not be effective if your browser is configured to reject cookies.
- Browser Solutions. You can decide if and how your computer will accept cookies by configuring the preferences option within your web browser, using the instructions provided in your browser. If you choose to decline cookies, however, some of the functionality of this Website might be impaired.
- Industry Solutions. Notwithstanding the above, visitors to our Website may follow the steps provided by initiatives that educate users on how to set tracking preferences for most online advertising tools, such as the Network Advertising Initiative (https://thenai.org/about-online-advertising/) and the Digital Advertising Alliance (https://digitaladvertisingalliance.org/).
- Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
6. Links to Third-Party Sites
Our Website and Services may contain links to third-party websites and applications. Any access to and use of such links are not governed by this Policy but is instead governed by the privacy policies of those third parties. Third parties are under no obligation to comply with this Notice if you provide information directly to those third parties. We are not responsible for the information practices of such third-party websites. Therefore, before visiting a third-party website and before providing any Personal Information or other information to any third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to protect their privacy.
We have implemented precautions designed to protect the Personal Information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
8. Notice for Residents of the European Union regarding International Data Transfers
Please note, this Website is hosted, and some Ares companies and contractors who process your Personal Information are located, in the United States and other countries noted above. These countries do not always provide the same level of protection for your information as required by the European Union’s General Data Protection Regulation (GDPR). In these circumstances, your Personal Information is transferred on the basis of one of the mechanisms set out below:
- Model Clauses: Ares will take steps to ensure that appropriate safeguards are in place to protect the Personal Information that we transfer to the United States or other jurisdictions that do not provide equivalent levels of data protection according to the European Commission, including by putting in place the Standard Contractual Clauses as approved by the European Commission and as approved by the UK Parliament. A copy of the Model Clauses may be obtained upon request. You may submit your request to us at [email protected] or (866) 501-0672.
- Adequacy Decision: Your Personal Information will be transferred to, and stored at/processed in Canada which was found to have an adequate level of protection for personal data under Commission Decision 2002/2/EC of 20 December 2001.
9. Retention of Personal Information
We retain Personal Information only as long as necessary and in alignment with our data retention schedules. Information may be retained to comply with applicable law, adhere to contractual requirements, in anticipation of litigation or a legal matter, or as otherwise necessary and proportionate to provide our Services. For example, we will retain your information as follows:
- If you give us your Personal Information via the Contact Us page, we will keep your data on the Ares exchange email system in accordance with our data retention policies and practices.
- Personal Information from cookies using Google Analytics will be kept for two (2) years. We retain information from other cookies for 24 hours.
10. GLBA Notice
ARES MANAGEMENT LLC (“Ares”) AND YOUR PERSONAL INFORMATION
Financial companies choose how they share your personal information. Federal law gives you the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
The types of personal information we collect and share depend on the product or service you have with us. This information may include, and is not limited to:
- your name, address, email address and phone numbers
- transaction history and assets
- investment experience and wire transfer instructions
- any other personally identifiable information including information contained on your driver’s license, passport or other form of identification
- information captured on our web, data room and/or investor portal via “cookies”
When you are no longer an Ares’ client, we continue to share your information as described in this notice.
All financial companies need to share clients’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their clients’ personal information; whether Ares chooses to share; and whether you can limit this sharing.
|Reasons we can share your personal information
|Does Ares share?
|Can you limit
|For our everyday business purposes—
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
|For our marketing purposes—
to offer our products and services to you
|We don't share
|For joint marketing with other financial companies
|We don't share
|For our affiliates’ everyday business purposes—
information about your transactions and experiences
|For our affiliates’ everyday business purposes—
information about your creditworthiness
|We don't share
|For non-affiliates to market to you
|We don't share
Contact: Legal Department
Tel: (866) 501-0672
Email: [email protected]
Who we are
Who is providing this notice?
Ares or an affiliate as defined below.
What we do
How does Ares protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings .
How does Ares collect my personal information?
We collect your personal information, for example, when you: .
- provide income information or provide your contact information
- provide account information or make a wire transfer
- tell us where to send money
Why can’t I limit all sharing?
Federal law gives you the right to limit only: .
- sharing for affiliates’ everyday business purposes—information about your creditworthiness
- affiliates from using your information to market to you
- sharing for non-affiliates to market to you
State laws and individual companies may give you additional rights to limit sharing.
Affiliates & Their Employees
Companies related by common ownership or control. They can be financial and nonfinancial companies.
- Our affiliates include, among others: Ares Commercial Real Estate Management, LLC; Ares Capital Management LLC; Ares Capital Management II LLC; Ares Management Capital Markets LLC; Ares Management Limited; Ares Management UK Limited; Ares Management Luxembourg; and several other subsidiaries and affiliates.
Non-affiliates & Their Employees
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
- Ares does not share with non-affiliates so they can market to you.
A formal agreement between non-affiliated financial companies that together market financial products or services to you.
11. Notice to European Residents
Where the GDPR applies, you have the following rights in respect of your personal information:
- Data rights. In certain circumstances, you have the right to access and receive a copy of information we hold about you, to rectify any Personal Information held about you that is inaccurate and to request the deletion of Personal Information held about you. Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you. You can exercise your rights by contacting us at [email protected].
- Marketing. You have the right to ask us not to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing at any time by contacting us at [email protected].
- Complaints. In the event that you wish to make a complaint about how we process your Personal Information, please contact us in the first instance at [email protected] and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with the supervisory authority.
For the purpose of the GDPR, we are the data controller.
12. Notice to California Residents
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively “CCPA”), California residents have the right to receive certain disclosures regarding our information practices related to “Personal Information,” as defined under the CCPA. To the extent you are a resident of California and we collect Personal Information subject to CCPA, the following applies.
Please note, this section does not apply to information that is exempt from CCPA, such as information protected under the federal financial privacy laws. The CCPA recognizes that such financial information is already protected by federal privacy law, so the CCPA does not apply to this information. For more information, please see our GLBA Notice below.
CCPA Right to Know Disclosure
While our information practices may vary based upon our relationship and interactions with you, the chart below describes the categories of Personal Information (as enumerated in the CCPA) that we collect, the categories of third parties for each category of Personal Information to whom Personal Information was disclosed, and the categories of third parties to whom Personal Information was sold or shared, if we “sell” or “share” Personal Information as defined by the CCPA. For more information about how we collect, use, and disclose Personal Information, please refer to Sections 1-4 and 9, above.
|Categories of Personal Information Collected
|Categories of Third Parties to Whom Personal Information is Disclosed
|Categories of Third Parties Whom Personal Information is “Sold” or “Shared”
Includes direct identifiers, such as name, contact information, online identifiers.
|Regulators, government entities and law enforcement
Business partners and affiliates
|Third party ad providers and networks
|Internet and electronic network activity information -
Including, but not limited to, browsing history, clickstream data, search history, and information regarding interactions with an internet website, application, or advertisement, including other usage data related to your use of any of our Services or other online services.
|Business partners and affiliates
|Third party ad providers and networks
Your California Privacy Rights
If you are a California resident, you may have the following rights to your Personal Information:
- Right to Access: With respect to the Personal Information we have collected about you in the prior 12 months, you have the right to request from us (up to twice per year and subject to certain exemptions): (i) categories of Personal Information about you we have collected; (ii) the sources from which we have collected that Personal Information; (iii) our business or commercial purposes for collecting, selling, or disclosing that Personal Information; (iv) the categories of third parties to whom we have disclosed that Personal Information; and (v) a copy of the specific pieces of your Personal Information we have collected.
- Right to Correct: You have the right to request that we correct inaccuracies in your Personal Information.
- Right to Delete: Subject to certain conditions and exceptions, you may have the right to request deletion of Personal Information that we have collected about you.
- Right to Opt-Out of Sale/Sharing: You may have the right to opt-out of the “sale” or “sharing” of your Personal Information. To opt out from the sharing or sale of information described above, please contact us at please contact us at [email protected] or call us toll-free at (866) 501-0672. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of the rights described in this section.
- Authorized Agent: You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf.
To make a request for the rights described above, please contact us at [email protected] or call us toll-free at (866) 501-0672. Please indicate you are making a request pursuant to your “California Privacy Rights.” You must provide us with the following information: (1) first and last name; (2) date of birth; (3) email address; and (4) residential or mailing address. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your request or, where necessary, to process your request. If we are unable to verify a request, we will notify the requestor.
Shine the Light
California residents have the right to request in writing from a business, (i) a list of the categories of Personal Information, such as name, address, email address, and the type of services provided, that a business has disclosed to third parties (including Independent Affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes, and (ii) the names and addresses of all such third parties. Contact [email protected] to make your request.
This Website is not intended for users under the age of 16. We do not knowingly collect any Personal Information from children under 16. If we become aware that an individual submitting information is under 16, we will attempt to delete the information as soon as possible.
15. How You Can Contact Us
If you would like to contact us about this Policy or our Website, please reach out to us via the Contact page. You can also write to or call our privacy team at [email protected] and (866) 501-0672, respectively.