Privacy Policy

Scope

This policy covers the information we collect through this website, which is limited to submissions through the request form and documents shared in our secure data room, and related correspondence.

We do not hold estate data. The debtor's or estate's own records that may be evaluated or sold in a bankruptcy case move directly from the estate to an independent de-identification firm, not to us, and are not collected through this website. Those records are handled under the terms of a signed engagement, any applicable confidentiality agreement, orders of the bankruptcy court and applicable law.

Information we collect

Information you give us. When you submit the request form, we collect what you enter. The form has these fields, some optional: Full name; Role; Role (other); Firm or organization; Email; Phone; Case name; Court; Case number; Chapter; Debtor industry; Years of data; Data types; Data types (other); Approximate volume; Customer or employee information in the records; Privacy policy in effect at filing; Timeline and urgency; Key date; Notes; Acknowledgment; Consent to contact; Business website; When the business entered bankruptcy; Is the business still operating?; Approximate number of employees; Approximate number of customers served; Approximate annual revenue (US dollars, most recent full year); Software and tools the business uses or used. This includes your contact details (such as name, organization, role, email and phone) and information about a bankruptcy case or matter. We also collect what you send us by email or tell us in conversation.

Technical information. With each form submission we store a keyed, one-way hash of your IP address (not the IP address itself), your browser's user-agent string (shortened), the date and time, and a single-use security token used to prevent repeat or forged submissions. To limit abuse, the IP hash and a timestamp are also kept briefly in a rate-limit record, deleted after about 25 hours. Like most websites, our hosting provider keeps standard server request logs, which include IP addresses, browser details and the pages requested, for a limited period.

Secure data room. If we invite you to our secure data room, we process your account details (such as name and email), sign-in and multi-factor authentication records, records of activity needed to keep the room secure, and the documents shared there. The data room is for engagement documents, such as system-level inventories, exclusion lists, engagement letters, confidentiality agreements, court filings, and the independent firm's de-identification certificates and chain-of-custody confirmations. It is not used to transfer or hold estate data.

Please do not submit documents, privileged or confidential material, or personal information about individuals through the form. The form does not accept file uploads.

Cookies and similar technologies

The public pages of this website set no cookies and use no advertising or cross-site tracking tools. Fonts and scripts are served from the site itself, not from third parties. We use our hosting provider's cookieless analytics and performance measurement to count page visits and measure page speed in aggregate; it does not use cookies and does not track you across other websites. If you sign in to the secure data room, we use first-party cookies that are strictly necessary to keep you signed in and to protect your account.

How we use information

• To respond to your request, evaluate a potential engagement and communicate with you about it.
• To carry out an engagement, if one is signed, including any related court process.
• To operate, secure and improve the website, and to detect and prevent fraud, abuse and security incidents.
• To comply with law, court orders, professional obligations and lawful requests, and to establish, exercise or defend legal claims.

We do not use information collected through this website for automated decision-making that produces legal or similarly significant effects.

Legal bases (EU, UK and Israel)

If data protection laws such as the EU General Data Protection Regulation, the UK GDPR or Israel's Protection of Privacy Law apply to you, we rely on the following legal bases, as applicable:

• Steps you ask us to take before entering into an engagement, and performance of an engagement.
• Our legitimate interests in responding to professional inquiries, developing our business, and securing our website and systems, where those interests are not overridden by your rights.
• Compliance with legal obligations.
• Your consent, where the law requires it. You may withdraw consent at any time; this does not affect processing that took place before.

How we share information

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act as amended by the California Privacy Rights Act. We have not done so in the preceding twelve months. We may share information as follows:

• Service providers that host the website, store data and provide email and communications services for us. They may use the information only to provide their services to us.
• Information you submit about a bankruptcy matter may be shared, as needed, with the estate's professionals (such as its counsel, financial advisors, trustee or consumer privacy ombudsman) and with the bankruptcy court, including in filings required for a retention or sale.
• Our affiliates and professional advisors (such as attorneys and accountants), under duties of confidentiality.
• When required by law, subpoena or court order, or to protect the rights, property or safety of any person.
• In connection with a merger, acquisition, reorganization or sale of all or part of our business, subject to this policy.

Estate data and de-identification

We do not hold copies of estate data. It moves directly from the estate to an independent de-identification firm, which performs any de-identification a sale requires. White Knight Data does not itself de-identify, scrub or sanitize data. We confirm the chain of custody to the estate in writing and keep the audit trail.

Retention

We keep personal information for as long as needed for the purpose for which it was collected and to meet our legal obligations, including obligations arising from a bankruptcy case, and to resolve disputes and enforce our agreements. Rate-limit records are deleted after about 25 hours, as described above.

Security

We use reasonable administrative, technical and organizational measures designed to protect personal information, including encrypted connections (HTTPS), restricted database access and server-side validation of submissions. No method of transmission or storage is completely secure, and we cannot guarantee the security of information you send us.

International transfers

Our website and database are hosted in the United States. Our team and service providers may access information from other countries, including Israel. Pages may be delivered through a global network, so your connection may pass through a location near you. Where the law requires it, we use appropriate safeguards for international transfers, such as standard contractual clauses or reliance on an adequacy decision.

Your rights and choices

Depending on where you live, you may have the right to:

• Know or access the personal information we hold about you, and receive a copy in a portable format.
• Correct inaccurate information.
• Delete your information.
• Object to or restrict certain processing, and withdraw consent.
• Opt out of the sale or sharing of personal information (we do neither).
• Not be discriminated against for exercising your rights.
• Complain to a data protection supervisory authority.

To exercise a right, email bryant.oberg@whiteknightrestructuring.com. We will verify your request before acting on it and respond within the time the law requires. You may use an authorized agent where the law allows; we may ask for proof of the agent's authority. Some information may be kept where the law requires or permits, for example to comply with a court order or to establish or defend legal claims.

Do Not Track and Global Privacy Control

Our website does not track visitors across other websites. Because we do not sell or share personal information, browser Do Not Track signals do not change how we handle information. Where the law requires it, we treat a Global Privacy Control signal as a request to opt out of the sale or sharing of personal information from that browser.

Children

Our website is intended for professionals and is not directed to anyone under 18. We do not knowingly collect personal information from anyone under 18 through this website. If you believe we have, contact us and we will delete it.

Changes to this policy

We may update this policy from time to time. The updated version will be posted on this page with a new effective date. If changes are material, we will take additional steps to notify you where the law requires.

Contact

Questions or requests about this policy: bryant.oberg@whiteknightrestructuring.com. Postal address: White Knight Restructuring, LLC, 66 W Flagler Street, Suite 900, Miami, FL 33130.