Intelligent. Innovative. Income. Corporate Capital Trust

Commitment to Privacy

Corporate Capital Trust, Inc. (the “Company,” “we,” “us” or “our”) recognizes and respects the privacy expectations of each of our shareholders (“shareholder” or “you”) and we believe the confidentiality and protection of our shareholders’ nonpublic personal information (“Information”) is one of our fundamental responsibilities. The policies and practices described in this policy apply equally to our current and former customers.

While new technologies have dramatically changed the way information is gathered, used and stored, the importance of preserving the security and confidentiality of Information remains a core value of ours. In addition, we ask all of our service providers who may become privy to any shareholder Information to certify they have procedures in place to protect such Information.

Collection of Information

We collect, retain and use Information only where we reasonably believe it would be useful to the Company or you and only to the extent as allowed by law. We do not sell Information about customers to third parties for their independent use.

Information collected by, or on behalf of, the Company generally comes from the following sources:

• Subscription agreements or other required forms, correspondence (written or electronic), or from telephone contacts with customers inquiring about us;
• Transaction history of a shareholder’s account; and
• Through our service providers.

Disclosure of Information

We do not disclose any Information about you or any former shareholder to anyone, except as required or permitted by law, including as set forth below. Information may be shared with the Company’s service providers and their affiliates, however only as necessary for the servicing of your account.

We may disclose Information about you or any former customer to the following types of third parties:

• Financial service and other service providers that assist us in maintaining or servicing the Company or your accounts, such as data processing companies, securities broker-dealers, printers, and the Company’s managing dealer, custodian and transfer agent;
• Companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements;
• Government entities, in response to subpoenas or to comply with laws or regulations;
• In accordance with governing law and our Articles, which requires that we provide a shareholder list to any person or group of persons who together are and for at least six months have been shareholders of record of at least five percent (5%) of the Company’s outstanding equity Securities. This shareholder list will contain your name, address and number of shares owned.
• Others, such as joint account holders and those with whom you have provided your consent to our sharing your Information;

We may also disclose all of the Information we collect to protect against fraud.

Security of Information

The Company and its service providers:

• Maintain policies and procedures designed to assure only appropriate access to, and use of, the Information by those employees who need to know that Information in order to provide services to shareholders; and
• Maintain physical, electronic and procedural safeguards that comply with federal standards to guard the Information.

Availibility of Information

The Company’s shareholders purchase their shares through non-affiliated brokers or dealers, therefore you will not receive this Privacy Policy from us directly. However, we are committed to the protection of your Information and keeping you advised as to our policies and procedures in this regard. You will find a summary of our Privacy Policy in the prospectus as filed with the Securities and Exchange Commission, which is available on their website at www.sec.gov. If you have any questions concerning the privacy of your Information, we welcome your inquiry. Please contact Client Services toll-free at (866) 650-0650.

Back to top

Our Commitment to Privacy

This is the Internet Privacy Policy for CORPORATE CAPITAL TRUST, INC. This Internet Privacy Policy addresses Corporate Capital Trust's privacy practices with respect to information collected online via this website only. Information provided to us via this website is also governed by the Privacy Policy of Corporate Capital Trust, Inc. governing the privacy of customer information generally which should be read in conjunction with this Internet Privacy Policy . This Policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us via this website and to assist you in making informed decisions when using our website. This statement will be continuously assessed against new technologies, business practices and our customers' needs.

By using our website or submitting information containing personal non-public information, you consent to our collection of your personal information as described in this Internet Privacy Policy as well as in Corporate Capital Trust's Privacy Policy. If we change our privacy policies and procedures, we will post those changes on our website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Where required to do so by law, we also will provide you with a notice by mail or email of any changes to this Internet Privacy Policy.

Users who are not resident to the United States should not submit their personal information to our website or by submitting documents containing such information unless they agree that their personal information will be treated in accordance with United States laws and the terms of this Internet Privacy Policy. If you have any questions about the use of your personal information, please contact us before submitting your personal information.

What Information Do We Collect?

You may provide us with two types of information: (1) personal information you knowingly choose to disclose to us through information submitted on this website; and (2) website-use information collected as you and others browse and use the website.

• Personal Information Submitted by You

When you submit information to us, when you register on our website, and/or when you choose to request forms or information through our website, you may be asked to give personal information. For example, you may be asked to provide the following information:

• Name
• Postal or legal address
• E-mail address
• Home and business phone number
• Other personal information (i.e., mother's maiden name)

When you invest in Corporate Capital Trust, request forms or information or otherwise complete online forms or submit information online, we may collect any information you provide in such documentation or communication.

• E-mail Information

In addition to providing the foregoing information collected through your submission of information to Corporate Capital Trust or your use of our website, if you choose to correspond further with us through e-mail, we may retain the content of your e-mail messages together with your e-mail address and our responses.

• Website Use Information and "Cookies"

Similar to other commercial websites, our website utilizes a standard technology called "cookies" and web server logs to collect information about how our website is used. Cookies can remember what information a user accesses on one web page to simplify subsequent interactions with that website by the same user or to use the information to streamline the user's transactions on related web pages. Cookies should make your online experience easier and more personalized. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our website, and the websites visited just before and just after our website. This information is collected on an aggregate basis. None of this information is associated with you as an individual. If your browser is set to reject cookies, you may still use our site, but your ability to use or navigate some areas of our site will be impaired.

How Do We Use the Information That You Provide to Us?

Broadly speaking, we use your personal information for purposes of administering our business activities, providing customer service and making other products and services available to you. Occasionally, we may also use the information we collect to notify you about important changes to our website, new services and special offers we think you will find valuable. You will be given the opportunity to notify us on the website of your desire not to receive these offers. We use website browser software tools such as cookies and web server logs to gather information about our website users' browsing activities in order to constantly improve our website and better serve our customers. This information assists us to design and arrange our web pages in the most user-friendly manner and to continually improve our website to better meet the needs of our customers and prospective customers.

Sharing Information With Third Parties

We may provide information collected on our website, website traffic patterns, related website information to our affiliates or reputable third parties, but this information will not include personally identifying data, except as otherwise provided in this Internet Privacy Policy and the Privacy Policy of Corporate Capital Trust, Inc..

This website is administered by CNL Financial Group, an affiliate of CNL Fund Advisors Company who serves as the Administrator to Corporate Capital Trust. As such, any personal information submitted via this website will be provided to the service providers of Corporate Capital Trust however these affiliates are required and are committed to protect your information as specified within this policy.

We may enter into strategic marketing alliances or partnerships with third parties who may be given access to certain personal information including your name, address, telephone number and e-mail for the purpose of providing you information regarding products and services that we think will be of interest to you. In connection with strategic marketing alliances or partnerships, we will retain all ownership rights to the information, and we will not share information regarding your social security number or other non-public personal financial data.

In the event that Corporate Capital Trust or any of its affiliates and/or some of our assets are sold or transferred or used as security, the information collected on our websites may be transferred to third parties as part of that transaction. Corporate Capital Trust may also provide such information or provide access to such information to our affiliates or to our business partners, vendors and/or service providers; however we will do so subject to appropriate confidentially agreements that obligate such partners, vendors and/or service partners to maintain and protect the confidentiality of such information.

If Corporate Capital Trust is requested by law enforcement officials or judicial authorities to provide information on individual users, we may, without your consent, provide such information. In matters involving claims of personal or public safety, Corporate Capital Trust may provide your personal information to appropriate authorities without your consent or court process.

Notice of New Services and Changes

Occasionally, we may also use the information we collect to notify you about important changes to our website, new services and special offers we think you will find valuable. You will be given the opportunity to notify us of your desire not to receive these offers by clicking on a response box when you receive such an offer or by sending us an e-mail request at CCTprivacypolicy@cnl.com.

How Do We Secure Information Transmissions?

When you enter confidential personal information on our website, secure server software which we have licensed encrypts all information you input before it is submitted to us. The information is scrambled en route and decoded once it reaches our website.

E-mail that you may send to us may not be secure unless we advise you that security measures will be in place prior to your transmitting the information. For that reason, we ask that you do not send confidential information such as Social Security or account numbers to us through an unsecured e-mail.

How Do We Protect Your Information?

We know that security is a concern for our customers and we have developed and implemented administrative, technical and physical security practices and procedures designed to protect the confidentiality of your personal information and the security of our website. We will take measures which we believe are reasonable and appropriate to protect your information from unauthorized access or disclosure and accidental loss, alteration or destruction.

How Can You Access and Correct Your Information?

You may request access to all your personally identifiable information that we collect online and maintain in our database by e-mailing CCTprivacypolicy@cnl.com. Such requests will likely take at least four to six weeks to process. We may retain in our files information you have requested be removed from our databases in some circumstances, such as to resolve disputes, troubleshoot problems, enforce the Terms of Use of our website, or as required by applicable law, rule or regulation. Further, such information is never completely removed from our databases due to technical constraints and the fact that we back up our systems and are required to retain certain information by law or regulation. Therefore, you should not expect that all of your information will be completely removed from our databases in response to your requests.

What About Other Websites Linked to Our Website?

We are not responsible for the practices employed by websites linked to or from our websites nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our website. Please remember that when you use a link to go from our website to another website, our Internet Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which have a link to our website, is subject to that website's own rules and policies. Please read over those rules and policies before proceeding.

Conclusion

Corporate Capital Trust restricts access to your personal and account information to those of its employees and affiliates who need to know that information to provide products or services to you. Corporate Capital Trust maintains physical, electronic, and procedural safeguards to guard your nonpublic personal information. We will continue to adhere to the privacy policies and practices as described in this notice, whether or not you become a shareholder in Corporate Capital Trust.

If you have any questions concerning Corporate Capital Trust privacy policies and procedures, please feel free to contact us. Thank you.

Back to top