Privacy Policy

Last Updated: October 13, 2025

I. Who Are We?

Sankaty Jet Capital is a global alternative investment manager focused on opportunities in commercial aviation. Sankaty Jet Capital believes its unique investment strategy, relationships, and hands-on approach enable it to execute its mission of generating attractive risk-adjusted returns for clients across market cycles. With a global footprint, Sankaty Jet Capital is supported by a team of professionals across finance, technical, legal, risk management, and underwriting.

II. What is Covered By This Privacy Policy?

This Privacy Policy describes Sankaty Jet Capital’s policies and practices regarding its collection and use of personal data, and sets forth your privacy rights. It applies to both our online information-gathering and dissemination practices in connection with this website (the “Site”), and personal information we collect or receive offline, whether directly from you or from other sources.

If you have arrived at this Privacy Policy by clicking through a link on our Site, then this Privacy Policy applies to you. By using the Site, you consent to the use of your information in the manner described herein. This policy may change periodically as we adopt new practices, so please check back from time to time. Continued use of the Site constitutes acceptance of any revised policy.

Use of our Site is strictly limited to persons of legal age in their jurisdiction. You must be at least sixteen (16) years of age to use our Site. If you are not at least 16, please do not use or provide any information through this Site.

This Privacy Policy does not apply to any other websites owned or operated by third parties, including portfolio companies. When visiting other sites, you are subject to their respective privacy policies.

III. What Personal Information Do We Collect, From Where, And Why?

A. Information We Do Not Knowingly Collect

We do not knowingly solicit, collect, or receive information from or about minors (under the age of eighteen).

B. Information You Provide to Us Directly

You may voluntarily submit personal information to us (e.g., name, email address, phone number, resume, or inquiry message) through the Site or via correspondence. We may keep a record of your contact information and correspondence to respond to inquiries or offer customer service.

C. Information from Third Parties During Due Diligence

We may receive personal information from third-party entities in which we are considering an investment, as part of due diligence. Such information is handled confidentially and subject to nondisclosure agreements.

D. Information Automatically Collected Through the Site

As with most websites, our Site automatically collects certain information during your visit, such as IP address, browser type, operating system, and pages viewed. We use this information to improve the Site’s design, analyze usage patterns, and enhance performance.

  • IP Address: Used to identify users for security, optimization, and analytics purposes.
  • Cookies and Pixel Tags: Small data files used to recognize your browser, capture preferences, and improve functionality. You can manage or disable cookies via your browser settings.
  • Analytics: We use Google Analytics for aggregated, anonymized website traffic analysis. You can opt out by installing the Google Analytics Opt-Out Browser Add-On.

IV. What Personal Information Do We Share With Others?

A. We Do Not Sell Personal Information

Sankaty Jet Capital does not sell personal information to third parties for their own use. We have not sold any personal information in the past twelve (12) months and do not knowingly collect or sell data from minors under 16 years of age.

B. Sharing Information with Service Providers

In the course of providing services, we may share information with trusted service providers who assist us with professional, technical, or analytical support. These providers are contractually restricted from using personal information for any purpose other than to perform their services for us.

C. Sharing at Your Direction

We may share personal information with third parties when you have authorized us to do so.

D. Sale or Transfer of Company Assets

In the event of a sale or transfer of our business or assets, we reserve the right to transfer collected information to the acquiring party.

E. Legal Compliance

Sankaty Jet Capital may disclose information when required by law or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

F. Internal Use and Research

We may use and disclose de-identified, anonymized, or aggregated information for internal research, analytics, and other lawful purposes.

V. How Do We Protect Personal Information?

We implement reasonable technical, administrative, and physical safeguards to protect personal information against unauthorized access, alteration, disclosure, or destruction. Our data security policies are periodically reviewed and updated as necessary.

VI. Rights Under the California Consumer Privacy Act (CCPA)

A. Overview

The California Consumer Privacy Act (CCPA) grants certain rights to California consumers regarding their personal information, including the right to know, access, delete, and opt out of the sale of personal data.

B. Consumer Rights Summary

  • Right to know what personal information is collected, used, shared, or sold.
  • Right to access personal information held by a business.
  • Right to request deletion of personal information, subject to certain exceptions.
  • Right to opt out of the sale of personal information.
  • Right to non-discrimination for exercising CCPA rights.

C. Submitting CCPA Requests

If you are a California resident and wish to make a request under the CCPA, you may do so through the methods outlined on our Site. Requests will be verified and responded to in accordance with applicable law. We do not charge a fee for processing valid requests unless they are excessive, repetitive, or manifestly unfounded.

VII. Updates to This Policy

We may revise this Privacy Policy from time to time. The updated version will be indicated by an updated “Last Updated” date and will be effective as soon as it is posted. We encourage you to review this Policy periodically to stay informed of how we are protecting your information.

VIII. Contact

If you have any questions about this Privacy Policy or our privacy practices, please contact Sankaty Jet Capital through the form available on our website.