Effective Date: January 31, 2023
Blue Owl Capital Inc. and its affiliates and subsidiaries (collectively, “Blue Owl”) respect your concerns about privacy. This Privacy Notice describes the types of personal information we collect, how we use the information, with whom we may share it and the rights and choices available to you regarding our use of the information. We also describe measures we take to protect the security of the information and how you can contact us about our privacy practices.
This Privacy Notice applies to all the products and services offered by Blue Owl, including on www.blueowl.com and sites that automatically are redirected to our websites (“Sites”), except where a product or service has a separate privacy statement that does not incorporate this Privacy Notice. Blue Owl Capital Inc. is the entity responsible for the processing of personal information described in this Privacy Notice. Please see the “How to Contact Us” section below for further information.
If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Notice called “California Consumer Privacy Statement.”
Click on one of the links below to jump to the listed section:
- Information We Obtain
- How We Use Personal Information We Obtain
- Information We Share
- Data Transfers
- How We Protect Personal Information
- Retention of Personal Information
- Your Rights and Choices
- Children’s Privacy
- Links to Third-Party Services and Features
- Updates to Our Privacy Notice
- How to Contact Us
Information We Obtain
The types of personal information we may obtain include:
- Contact information, such as your name, telephone number, and postal and email address;
- User-generated content related to comments, questions and answers;
- If you are a client or investor, we obtain information about you and your organization such as Social Security number (or its equivalent), assets, income, investment/transaction information, bank details and other information required to establish a client or investor relationship, such as information you provide to us in contracts, correspondence or interactions with our representatives, and information we generate to service your account, such as capital account statements;
- Social media information, such as social media handles, content and other data shared with us through social media pages (such as our social media pages or other pages accessible to us);
- Information you provide in the course of applying for a job with us, such as details about your education, work and military history, legal work eligibility status, and background check information; and
- Other information you choose to provide, such as through our “Contact Us” feature or other forms available on our Sites.
Personal information that you provide directly to us will be apparent from the context in which you provide it, for example:
- If you fill out a form on our Sites, you may provide your name, contact details (postal address, email address and telephone number) and other information requested by the form, such as the reason for your inquiry;
- If you sign up to receive electronic marketing communications from us, you may be asked to provide your name, email address and other contact information;
- If you are a client or investor, when you log into a client portal, while we obtain your login credentials, your information is otherwise collected by the third-party that operates the portal and is subject to that third party’s own privacy notices. Once you log in, additional information about you will be included in the portal, such as your name, work email address, phone number, time zone, postal address and investor status, if applicable; and
- If you sign up to a feature on our Sites, you may be asked to provide your name and contact information and other information necessary to access the feature.
Each form on our Sites varies in the information required and collected. In most cases, an asterisk (*) indicates the required information on a form. You may choose to provide additional information within fields that are not required.
In addition, you may choose to submit personal information to us if you attend an event that we or one of our affiliates or partners has organized or if you otherwise communicate with us on social media or by sending us an email.
We also may collect personal information about you from third party data providers or publicly available sources for anti-money laundering, background check or similar screening purposes, to protect our business and to comply with legal and regulatory obligations.
While the personal information you choose to provide is voluntary, providing certain personal information may be necessary to offer you the relevant product or service. If you choose not to provide certain information, this may affect our ability to provide you with certain products or services.
When you visit our Sites, we may obtain certain information by automated means, such as cookies, web beacons, web server logs and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits.
We use these automated technologies on our Sites to collect information about your equipment, browsing actions, and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Sites; (3) tailor the Sites around your preferences; (4) measure the usability of our Sites and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services, and help ensure they are working properly.
Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to use all of the features of our Sites. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
The Sites are not designed to respond to “do not track” signals from browsers.
Third Party Analytics Services
We may use third-party analytics services on our Sites, such as Google Analytics. The information we obtain through the Sites may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/. To opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.
How We Use Personal Information We Obtain
We use the personal information we gather on our Sites for the following legitimate business purposes:
- Provide our products and services;
- Authenticate and authorize access to our services;
- Communicate with you, respond to inquiries, offer support and process complaints in connection with our products and services;
- Establish and manage our business relationships;
- Prepare investor disclosure materials;
- Operate, evaluate, and improve our products, services and business (including administering the Sites; developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; analyzing our client base and Sites; performing data analytics; and performing accounting, auditing and other internal functions);
- Perform market research and surveys;
- Advertise and market our products and services;
- Personalize your user experience on our Sites and determine the effectiveness of our advertising and marketing;
- Manage career opportunities at Blue Owl, including conducting recruitment and talent management activities;
- Maintain and enhance the safety and security of our Sites, products and services and prevent misuse;
- Maintain business records;
- Conduct data storage and information technology activities;
- Diagnose and address technical and service issues;
- Exercise our rights and remedies and defend against legal claims;
- Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
- Comply with and enforce applicable legal requirements, regulatory obligations, relevant industry standards and Blue Owl policies.
We use the personal information for these purposes because we have a legitimate business interest in providing our services. In accordance with applicable law, we take reasonable measures to ensure that the interests we pursue are balanced with your interests, rights and freedoms, which we can explain upon request.
Where required by applicable law, we will obtain your consent to send you marketing communications about our products, services, offers and promotions, and to invite you to events and to participate in surveys.
Where we have a contract with you, we process your personal information as necessary to perform our contractual relationship with you, provide our products and services, and manage our relationships, including to:
- Manage accounting, auditing, billing and collection activities and other internal functions;
- Process transactions in connection with your investment;
- Offer legal support and manage contracts and orders; and
- Manage accounts.
We may also use the information in other ways for which we provide specific notice at the time of collection. To the extent required by law, the notice will also describe our legal basis for processing personal information.
Information We Share
We share personal information we obtain about you with our affiliates and subsidiaries. We also share personal information with service providers that perform services on our behalf, such as those that perform website hosting, marketing, and data analytics.
We also may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity or (6) otherwise with your consent.
We reserve the right to transfer any personal information we have about you in the event of an actual or proposed sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).
We may transfer the personal information that we collect about you to recipients in countries other than the country in which the personal information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal information. When we transfer your personal information to recipients in other countries, we will protect that personal information as described in this Privacy Notice.
We will comply with applicable legal requirements by providing adequate protection for the transfer of personal information to data recipients in countries outside of the European Economic Area (“EEA”), the United Kingdom and Switzerland. To the extent these data recipients are in countries that are not recognized by the European Commission or another relevant body as providing an adequate level of data protection, we provide appropriate safeguards aimed at ensuring a required level of data protection, including by entering into Standard Contractual Clauses issued by relevant authorities, such as the European Commission. To obtain a copy of the safeguards we have put in place, please contact us as indicated below.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect the personal information we obtain against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use.
Retention of Personal Information
Your Rights and Choices
We offer you certain choices in connection with the personal information we obtain. You can tell us at any time not to send you marketing communications by email by clicking on the unsubscribe link in the marketing emails you receive from us or by sending an “opt out” request to the address indicated on the email. You also may ask us not to contact you in connection with any new product, service, update, news, or event by contacting us as described below.
For California Residents
If you are a California resident, please see our California Consumer Privacy Statement for more information about your rights with respect to your personal information.
For Residents of the EEA, United Kingdom or Switzerland
If you are located in the European Economic Area (“EEA”), the United Kingdom or Switzerland, you may have the following rights in relation to personal information we hold about you:
- To request confirmation of whether we process personal information about you and, if so, to request a copy of that information;
- To request that we rectify or update your personal information that is inaccurate, incomplete or outdated;
- To request that we erase your personal information in certain circumstances;
- To request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted like a request that we update your personal information;
- To object to our processing of personal information on grounds relating to your particular situation;
- Where you have given us consent to process your personal information, to withdraw your consent; and
- To request that we provide a copy of your personal information to you in a structured, commonly used and machine readable format in certain circumstances.
You may contact us by email or as described in the “How to Contact Us” section below to exercise these rights. You also have the right to file a complaint with the data protection supervisory authority in your country if you are not satisfied with our response.
Our Sites are designed for a general audience and are not directed to children. In connection with the Sites, we do not knowingly solicit or collect personal information from children under the age of 16. If we learn that we have collected personal information from a child under age 16 without parental consent, we either will seek parental consent or promptly delete that information. If you believe a child under age 16 may have provided us with personal information without parental consent, please contact us as specified in the How To Contact Us section of this Privacy Notice.
For your convenience and information, our Sites may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Blue Owl, we are not responsible for these third parties’ information practices.
Updates to Our Privacy Notice
We may update this Privacy Notice from time to time and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the notice when it was most recently updated.
How to Contact Us
You can update your preferences, ask us to remove your information from our mailing lists, submit a request, exercise your privacy rights or ask us questions about this Privacy Notice by emailing us at Privacy@blueowl.com or writing to us at:
Blue Owl Capital Inc.
399 Park Avenue, New York NY 10022
If you are a client or investor from the EEA, the United Kingdom or Switzerland, the Blue Owl entity responsible for the processing of your personal information is Blue Owl Capital UK Limited, 16 Berkeley Street, London, W1J 8DZ, United Kingdom.
CALIFORNIA CONSUMER PRIVACY STATEMENT
Effective Date: January 1, 2023
This California Consumer Privacy Statement (“Statement”) supplements the Blue Owl Privacy Notice. It applies solely to California consumers, which includes Blue Owl job applicants and personnel working on behalf of our business clients and partners.
This Statement does not apply to (1) Blue Owl personnel (i.e., employees, officers, directors, or medical staff members), their emergency contracts or their relatives for whom we administer benefits; or (2) information collected, processed or disclosed in connection with the provision of financial products or services pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.
This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act of 2020 (the “CPRA”), and its implementing regulations (the “CCPA/CPRA”).
- Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status
- Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Sensory Information: audio, electronic, visual, and similar information
- Employment Information: professional or employment-related information, such as information relating to your job position (e.g., job title, job description and office location), talent management information (e.g., résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information) and emergency contact information
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Privacy Notice and for the following business purposes specified in the CCPA/CPRA.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services
- Providing advertising and marketing services to you, except for cross-context behavioral advertising
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
- Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us
- Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes
- Debugging to identify and repair errors that impair existing intended functionality
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
We do not collect or process sensitive personal information with the purpose of inferring characteristics about California consumers covered by this Statement.
- Retention of Personal Information
- Sources of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:
- Directly from you, such as when you contact us
- Your devices, such as when you visit our Sites
- Our affiliates and subsidiaries
- Vendors who provide services on our behalf
- Professional services organizations, such as auditors and law firms
- Our business clients
- Our business and joint marketing partners
- Your employer, if you are a representative of a business client or partner
- Other individuals, such as in connection with a referral
- Recruiting and talent agencies
- Data analytics providers
- Internet service providers (“ISPs”) and operating systems and platforms
- Social networks
- Data brokers, such as credit bureaus, credit reporting service providers and background check services.
- Disclosure of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with : (1) Government entities, such as law enforcement authorities and regulators; (2) Self-regulatory organizations; and (3) third parties in connection with an actual or proposed corporate transaction, such as a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation.
Blue Owl does not sell or share for cross-context behavioral advertising purposes personal information about California Consumers covered by this Statement.
- California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
- Access:You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
- Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
- Deletion:You have the right to request that we delete certain personal information we have collected from you.
How to Submit a Request. To submit an access, correction or deletion request, email us at Privacy@blueowl.com or call us at 888-215-1944. To submit a request as an authorized agent on behalf of a consumer, contact us at Privacy@blueowl.com. For questions or concerns about our privacy policies and practices, contact us at Privacy@blueowl.com.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to, or correction or deletion of, your personal information, we may require you to provide any of the following information: name, phone Number, and email address. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information. If you choose to exercise any of your rights under the CCPA/CPRA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.