Privacy Policy

Respecting and protecting investor privacy has always been vital to our business. This Privacy Policy describes how Apollo Global Management, Inc. (together with its subsidiaries and affiliates “Apollo”, “we”, “us”, “our” and the “Company”) gathers and uses information about your interaction with Apollo’s websites that link to this Privacy Policy (including AGM.com, AGMFunds.com, Apolloic.com, and Apolloreit.com, and any sites that are automatically redirected to them, collectively, the “Sites”). This Privacy Policy does not apply to websites, apps, or online services that have their own privacy statements.

This Privacy Policy provides you with information about how we collect information about you when you visit the Sites, and how we use and share such information. Please read this Privacy Policy carefully, and consult our Terms of Use for more information about the general terms and conditions regarding your use of the Sites.

In the event that you have any questions or concerns about this Privacy Policy please contact us at privacy@apollolp.com.

A. The Types of Information We Collect

When you visit and browse the Sites, you may provide us with information, and we may collect certain information automatically.

1. Information You Provide to Us

In order to access certain services provided via the Sites or to request certain information from Apollo via the Sites, you may be required to provide information such as your name, postal address, e-mail address, telephone number, facsimile number, investor status, or other information about yourself. And you may be required to provide a username and password to access certain features. If you choose to not provide us with information, you might not be able to gain access to certain information and services on the Sites.

2. Information We Collect Automatically

We may also collect information about you automatically. For example, when you visit the Sites, we may collect your IP address, your browser type, your operating system, the pages you view on the Sites, the pages you view immediately before and after you access the Sites, and the search terms you enter on the Sites.

We may collect this information using cookies. (Cookies are small files that a website sends to your computer or device while you are viewing the website.) We and other companies use cookies for a variety of purposes. For instance, when you return to our Sites after logging in, cookies provide information to the Sites so that the Sites will remember who you are. You may be able to have your computer warn you each time a cookie is being sent, or you may be able to turn off all cookies. You do this through your web browser settings. Each browser is different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won't have access to many features that may make your browsing of the Sites smoother, like the features mentioned above, and some of our services may not function properly.

The Sites may also use other technical methods to track visitor usage, including web beacons. (“Web beacons” are small pieces of data that are embedded in images on the pages of a website.) We use these technical methods to analyze the traffic patterns on the Sites, such as the frequency with which our users visit various parts of the Sites. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send visitors to the Sites to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails.

3. Additional Information Collection Practices

The Sites may contain links to websites operated by third parties. 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 do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third party website (whether or not such site is linked on or to the Sites). These links are provided to you for convenience purposes only, and you access them at your own risk.

We may link the information that we collect automatically with the information you provide us. And we may combine the information we collect online with information we collect offline or that is collected by third parties.

Also, some of our third-party partners may ask you voluntarily 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. How We Use the Information We Collect

We may use information we collect about you for a number of purposes, including, without limitation, using information to:

• respond to your requests for forms, literature, or information;
• process transactions;
• provide you with the services you have requested;
• prepare investor disclosure materials;
• improve the Sites and learn about how visitors use the Sites;
• communicate with you about our products and services, including providing you with information about features on the Sites and possible changes to our Privacy Policy or terms of use;
• comply with legal obligations; and
• protect our rights, your rights, and the rights of others.

We may use information that does not reasonably identify you for any purpose. For example we may prepare aggregated reports about how visitors tend to interact with the Sites for research purposes.

C. How We Share the Information We Collect

1. In Connection with Third Party Offers

We may share information about you with third parties when you engage in certain activities on the Sites that are sponsored by third parties. For example, you may choose to purchase products or services offered by a third party or elect to receive information or communications from a third party. When you engage in such third-party offerings, we may share information (e.g., your e-mail address) with third parties in association with the offerings.

2. Service Providers

Sometimes we engage companies that act on our behalf in association with the operation of the Sites. For example, and without limitation, such companies may deliver products or services, improve the functionality of the Sites, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you. Except as otherwise disclosed in this Privacy Policy or as otherwise communicated to you, Apollo takes reasonable steps require these companies to collect, store, and use information about you only on our behalf and in accord with this Privacy Policy.

3. Analytics Providers

We may engage third-party analytics providers to help us understand how users engage with the Sites. These third parties may use cookies and similar technologies to collect information about your use of the Sites as well as information about your use of other websites over time. The third-party services we use include, but may not be limited to: Google Analytics and Adobe, which may provide you with choices about how they collect and use information.

4. Additional Sharing Practices

We may share your information with our affiliates and subsidiaries. Apollo also may provide information to our attorneys, banks, auditors, securities brokers and other service providers. From time to time, we may partner with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we may share your information with our co-sponsor(s) and partners.

We may disclose information when we believe in good faith that such disclosures:

• are required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency's request;
• will help to protect our rights or enforce our Terms of Use;
• will support our detection, prevention, or response to fraud or intellectual property infringement;
• will help protect your safety or security, including the safety and security of property that belongs to you; and
• will protect the safety and security of the Sites, databases, and/or third parties, including the safety and security of tangible and/or intangible property that belongs to us or to third parties.

We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.

Additionally, we reserve the right to share with third parties information that does not reasonably identify you for any purpose.

D. 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 commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. From time to time, we review and consider updates for our security procedures. Please be aware though that, despite our ongoing efforts, no security measures are perfect or impenetrable.

E. Updating Your Contact Information

You may be able to update your contact information and/or modify your communication preferences by sending us an e-mail to the address listed above, and we may provide tools on the Sites that facilitate such updates or modifications.

F. Children’s Information

The Sites is intended for use by those over 18, and minors under the age of 13 may not use the Site. We do not knowingly solicit or collect personal information on the Sites from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Site, 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 child or others as required by law).

G. Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals. Third parties, such as our analytics providers, may collect data that relates to you on our Site, across time, and over other websites. 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.

H. 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 privacy@apollolp.com.

I. Additional Access Requests

If you believe that personal data relating to you is held by an entity within Apollo's group that is subject to data protection legislation that provides you with a right to obtain information about the personal data that the entity holds about you, please contact us at privacy@apollolp.com. To the extent permitted by applicable law, Apollo reserves the right to charge a reasonable administrative fee for this service.

J. Where Is Information Processed?

We process information collected via the Sites 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. By using the Online Services, you consent to such transfer to, and processing in, the United States and these other countries.

K. Amendments to this Privacy Policy

We may change this Privacy Policy. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Policy to review any changes. Your continued use of the Sites after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.

Last updated April 2018.