Privacy Policy
Last Updated: October 23, 2024
Commitment to Privacy
老夫子传媒, LP and its advisory affiliates and related persons (collectively, 鈥老夫子传媒,鈥 鈥we,鈥 鈥us鈥 or 鈥our鈥) are committed to responsibly handling personal information that we collect or otherwise process regarding our investors (including, for the purposes hereof, a potential investor or former investor) and individuals who visit our website (the 鈥Website鈥) or otherwise communicate or engage with us (鈥you鈥 or 鈥your鈥).
Our intention with this privacy policy (this 鈥Privacy Policy鈥) is to provide you with clear, transparent and easily understandable information about how 老夫子传媒 uses and otherwise processes your personal information and certain rights you may have relating to such use and other processing. We reserve the right to change this Privacy Policy at any time, as circumstances or requirements change. All updates are effective immediately when we post them here and they apply on a go-forward basis. For this reason, we encourage you to review this Privacy Policy whenever you visit the Website so you are aware of any updates, as they will be applicable to you and your personal information.
Your access to and use of the services provided by 老夫子传媒 is subject to this Privacy Notice. By visiting the Website, completing any of our online forms or otherwise submitting personal information to us, you agree to the terms of this Privacy Policy, and you hereby consent to our collection, use, disclosure and other processing of your personal information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the services provided by 老夫子传媒, access the Website or otherwise submit personal information to us.
Collection of Personal Information
The types of personal information collected by or on behalf of 老夫子传媒 about you varies based on 老夫子传媒鈥檚 interactions with you (for example, whether you are an investor or an individual visiting the Website).
Personal information collected by or on behalf of 老夫子传媒 about individuals visiting the Website is obtained directly from you or certain third parties. For purposes of this Privacy Policy, 鈥減ersonal information鈥 has the meaning given to such term (or to terms of similar intent, such as 鈥減ersonal data鈥) under applicable law, as and to the extent applicable to your rights and our obligations with respect to such information, including (as and to the extent applicable): (i) 鈥減ersonal information鈥 as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the 鈥CCPA鈥), (ii) 鈥渘on-public personal information鈥 as defined under the Gramm-Leach-Bliley Act (Public Law 106-102) (the 鈥Gramm-Leach-Bliley Act鈥), and/or (iii) 鈥減ersonal data鈥 as defined under the General Data Protection Regulation (EU) 2016/679 (the 鈥GDPR鈥) or the UK General Data Protection Regulation (i.e., the GDPR as implemented into the laws of the United Kingdom (the 鈥UK鈥), the 鈥UK GDPR鈥). The personal information we collect about you in the course of your interaction and correspondence with us via the Website includes, but is not limited to, the following:
any personal information that you submit when you contact us using our contact details on the Website, such as your name or email address;
IP address and other online identifiers/web beacons;
details of your online browsing activities on the Website, including, for example, the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including, for example, date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
your browser type, language and version, relevant plug-ins, operating system and platform;
your time zone settings; and
in relation to any personal account you create on the Website:
usernames, passwords and other log-in information;
your account settings, including, for example, any default preferences;
a log of your browsing activities during your visit to the Website; and
any preferences we have observed, such as the types of products that interest you, or the areas of the Website that you visit.
If you are an investor, additional personal information collected by or on behalf of 老夫子传媒 about you is obtained directly from you, your professional advisors or other third parties, through the Website or from sources such as subscription agreements, investor/purchaser questionnaires, other required forms, documents and agreements or other correspondence (including, for example, written, telephone, videoconference or electronic contacts) with you regarding your accounts or transactions with non-affiliated third parties. The personal information we collect about you as an investor in the course of your interaction and correspondence with 老夫子传媒 and its representatives includes, but is not limited to, the following:
basic personal details, including, for example, your name and address (and proof of name and address), email address, telephone number, any other contact details you may supply, social security number, passport number, driver鈥檚 license, state identification card, tax details, nationality, citizenship, tax residency, date of birth and family connections;
details of your company鈥檚 directors, shareholders, secretaries, authorized signatories and other comparable officers and/or beneficiaries, and identification documents;
financial information, including, for example, wire transfer information and/or banking details;
information regarding your assets, income and/or financial dealings including, for example, net worth, account transactions, investment history, credit history, reason for investment and source of funds;
personal characteristics, including, for example, your signature and physical characteristics or description;
details of any criminal convictions, regulatory or court orders, or suspensions or expulsions from membership in, or association with a member of, a self-regulatory association to which you are subject, or any investigation or proceeding associated with the foregoing;
details of business advisers you may employ, including, for example, wealth managers and independent financial advisers;
records of all communications, including, for example, recordings of your attendance (or your representative鈥檚 attendance) at certain meetings/phone calls, and electronic communications with 老夫子传媒鈥檚 staff and meeting notes (see below for more details); and/or
personal information about transactions with us, our affiliates or others, such as ownership of certain types of accounts or other account data.
If you are an investor, 老夫子传媒 also may collect or receive personal information about you from third parties such as service providers to 老夫子传媒鈥檚 sponsored funds, investor advisors (including, for example, independent financial advisors), vendors, tax authorities, governmental agencies and publicly available sources such as company websites. We may collect or receive any of the personal information noted above from such third parties, and in addition, we may collect or receive the following:
details of any complaints made by you with respect to your dealings with the relevant service provider to the fund;
data received from due diligence activities (such as due diligence relating to anti-money laundering, politically exposed persons and sanctions checks); and/or
fraud inquiries (for example, information from police reports).
In addition, if you are an investor, 老夫子传媒 obtains personal information about your interests in funds (such as capital account balances and percentage interests) from the funds themselves and their other non-affiliated service providers.
Of the above categories of personal information that we may collect about you, the following may be considered 鈥渟ensitive鈥 categories under certain applicable laws: social security number, passport number, driver鈥檚 license, state identification card, and financial account information. This Privacy Policy, and the practices described herein, applies equally to our collection, use, disclosure and other processing of such 鈥渟ensitive鈥 personal information.
As described further below, the categories of personal information listed above are collected, used, retained, and shared by us and designated third parties only as necessary and proportionate to achieve the purposes disclosed to you in this Privacy Policy or as otherwise disclosed at or before the time of collection or based upon your subsequent consent.
We automatically collect basic technical information from all visitors to the Website. We collect this technical information during your visit to the Website through our automatic data collection tools, which may include cookies and other commonly used technologies (e.g. web beacons). Please see the section entitled 鈥淐ookies鈥 below for a discussion of our use of cookies on the Website.
The Website is not intended for children and we do not knowingly collect data relating to children (including any minors under the age of 16).
Use of Personal Information Collected
老夫子传媒 uses your personal information for the following business purposes:
to provide you with services that you have requested, administer the relationship between you and us (including subscription acceptance, communications, record-keeping, reporting or monitoring of activities, and investor relations activities) and to fulfill 老夫子传媒鈥檚 contractual obligations, including, for example, any contractual obligations as the general partner(s), the manager(s) and/or the investment advisor to a fund in which you have subscribed (including, for the avoidance of doubt, the preparation of Schedules K-1 and other tax forms or other filings);
to operate the Website and our other IT systems, and safeguard their security;
to understand the demographics, interests and behavior of users of the Website in order to personalize your visit to the Website;
to fulfill our contractual obligations to other third parties to whom you have provided your information;
for 老夫子传媒鈥檚 internal business administration, record keeping and security purposes;
for legal and regulatory compliance purposes, including, for example, as necessary for anti-money laundering, fraud prevention, tax reporting or sanctions reporting or to respond to governmental, regulatory or law enforcement agency requests;
where required or considered appropriate, including, for example, prior to admitting you to a fund, prior to accepting capital contributions or making a capital distribution, carrying out 鈥渒now-your-client鈥 (KYC) checks as deemed appropriate and other procedures that 老夫子传媒 undertakes in the course of 老夫子传媒鈥檚 ongoing business relationship with you; and/or
to provide information to future or potential purchasers or merger partners of all or a portion of 老夫子传媒 or any of its funds, or to provide information as may be necessary in connection with other corporate transactions, such as financings or restructurings; and
for purposes otherwise set out in this Privacy Policy.
老夫子传媒 generally does not send marketing messages; however, from time to time, 老夫子传媒 will provide you with information on 老夫子传媒-sponsored funds that we may be raising. You have the right to ask us not to send you marketing messages by post, telephone or e-mail or any combination of these at any time; however, you acknowledge that such information may be included in general update letters and while you may choose not to receive such updates, we are under no obligation to provide redacted versions of such letters or otherwise create separate reports on your behalf excluding such marketing information. You can also let us know at any time that you wish to change your mind and to start receiving such messages. You can do this by replying directly to the marketing message or at any time by contacting us.
We do not use or otherwise process your personal information, including 鈥渟ensitive鈥 personal information, for purposes of automated decision-making, including profiling.
We do not use or otherwise process your 鈥渟ensitive鈥 personal information other than as described herein. To the extent we collect any sensitive categories of personal information about you, including, for example, certain financial, health, and/or geolocation information, we will limit use of such information to that which is necessary to perform services or provide goods reasonably expected. To the extent you have any questions or concerns regarding our collection and use of sensitive categories of personal information, please contact us by using the information found at the end of the Privacy Policy.
We may aggregate, anonymize, or otherwise de-identify your personal information and use it for any purpose permitted by applicable law, and we may use information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable laws. We also may use your information for any other purposes disclosed to you at the time of collection, that you have previously authorized, or with respect to which you subsequently provide your consent.
Do Not Track
Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.
Consequences of Failing to Provide Personal Information
If you do not agree with our processing of your personal information as set forth in this Privacy Policy, you should not submit your personal information to us. However, where personal information is required to satisfy a statutory obligation (including compliance with applicable laws) or a contractual requirement, failure to provide such personal information may result in any of your subscriptions in our funds being rejected or your interest in such funds becoming subject to compulsory redemption or withdrawal, as applicable. Where there is suspicion of unlawful activity, failure to provide personal information may result in, to the extent permitted under applicable laws, the submission of a report to the relevant law enforcement agency or supervisory authority. Further, if you exercise your rights in such a manner to prevent us from processing your personal information, please note that we may not be able to do business with you or otherwise perform some of the tasks we need in order to provide certain products or services to you.
Disclosure of Personal Information
We do not disclose any personal information about you except as detailed in this Privacy Policy. We disclose your personal information to the following categories of recipients:
our employees and affiliates (including, for such purposes, Snow Phipps Group, LLC), for purposes of operating our business;
vendors and service providers needed to operate the Website, and the fund(s) in which you are invested, including, for example: (i) legal counsel, (ii) accountants, (iii) audit firms, (iv) banks, (v) administrators, (vi) tax consultants, (vii) tax preparers, (viii) placement agents, (ix) financial advisors, (x) broker-dealers, (xi) transfer agents, (xii) custodians, (xiii) investor portal service providers, (xiv) persons or entities that are assessing our compliance with industry standards, and (xv) vendors supporting the Website or our other IT systems;
third-party financial companies, and their affiliates, as general partners and/or managers of funds that we and such other third-party financial companies sponsor together, for purposes of providing services related to, or marketing, such funds;
marketing companies engaged to contact you about a 老夫子传媒 offer in support of your business needs or to conduct online surveys to understand better our customers鈥 needs;
law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. (including, for example, the U.S. Securities and Exchange Commission) or of other countries with whom a fund (or a fund鈥檚 portfolio company) transacts who request or require such information in order to issue business or regulatory licenses or permits;
any person or entity, including, for example, any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over us or our affiliates, if (i) we determine in our discretion that such disclosure is necessary or advisable pursuant to or in connection with any United States federal, state or local, or non U.S., law, rule, regulation, executive order or policy, including, for example, any anti-money laundering law, the USA PATRIOT Act of 2001 or any subpoena, court order or judicial process, and (ii) such disclosure is not otherwise prohibited by applicable law, rule regulation, executive order or policy; and
third parties with whom a fund (or a fund鈥檚 portfolio company, or a business that issues a fund鈥檚 investment) transacts who require information to comply with local anti-money laundering laws, including, for example, banks and other financing counterparties.
In addition, we may disclose personal information as follows:
to law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. (including, for example, the U.S. Securities and Exchange Commission) or of other countries, where we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligations, or if we reasonably consider that such disclosure is necessary or advisable to help prevent or detect fraud or other crimes or to protect our rights, property, or safety, or that of our clients, investors or others. Such disclosure (including, for example, tax status, identity or residency or other personal or payment information, documents or self-certifications) may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
if we are under a duty to disclose or share your personal information with tax authorities, such information requested by such tax authorities, who may transfer such information to the government or the tax authorities in another country where you may be subject to tax. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
subject to any contractual confidentiality obligations, we may disclose investor names, investors鈥 participation on any limited partner advisory committee, and investors鈥 respective jurisdictions and/or commitment sizes, in each case, to other limited partners or prospective investors of a 老夫子传媒-sponsored fund;
if you use a financial or other adviser (as indicated on your subscription agreement or subsequently communicated to us), the details of your investments and valuations may also be provided to such adviser(s);
to future or potential purchasers or merger partners (i) for due diligence purposes on a need to know basis, (ii) as necessary for pre-closing integration planning, or (iii) in connection with the consummation of a sale or merger transaction; and/or
on a need to know basis to current, future or potential lenders or other relevant persons as necessary in connection with other corporate transactions, such as financings or restructurings.
We also may disclose your information to any other third party where you have provided consent to such disclosure. We do not sell or offer to sell any personal information about you to third parties or share your personal information with third parties for purposes of cross-context behavioral advertising.
Data Retention
We will keep your personal information for as long as necessary depending on the purpose for which it was provided and otherwise in order to meet our statutory, regulatory, or other obligations under applicable law. Details of retention periods for different aspects of your personal information are available in our retention policy, information about which you can request by contacting us. When determining the relevant retention periods, we take into account factors, including, for example, the following:
our contractual and business relationships with you;
legal obligations under applicable law to retain personal information for a certain period of time;
the amount, nature and sensitivity of your personal information;
the potential risk of harm from unauthorized use or disclosure of your personal information;
statutes of limitation under applicable law;
(potential) disputes; and
guidelines issued by relevant supervisory authorities.
Data Security
We acknowledge that the personal information you provide may be confidential, and we maintain policies and procedures designed to maintain the confidentiality of and protect your personal information in accordance with our normal procedures and applicable law. We maintain physical, electronic, and administrative measures designed to safeguard your personal information and prevent unauthorized access thereto.
Unfortunately, the storage and transmission of electronic information is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of information stored on our or our vendors鈥 servers or transmitted via email or through the Website; you transmit personal information to us at your own risk. In addition, links on the Website may take you to third-party websites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies or cookie policies on those linked websites. We are not responsible for any linked websites.
Further, you may have created or may in the future create an account with our third-party fund administrator(s) (including through its vendor(s)). We are not responsible for the websites of our third-party fund administrator(s) or its vendor(s), and you should review any separate privacy policies or cookie policies that they provide to you or that they post on their websites.
If you create an account on the Website, you are responsible for all actions taken with your username and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your username or password to access or use any part of our Website. If your password has been compromised for any reason, you should contact us immediately for a new password.
Cookies
What are Cookies?
Cookies are small, sometimes encrypted text files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit a website. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. A cookie will usually contain the name of the website from which the cookie has come from, the 鈥渓ifetime鈥 of the cookie (i.e., how long it will remain on your device) and a value, which is usually a randomly generated unique number. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit .
How we use Cookies
When you visit the Website, one or more 鈥渃ookies鈥 are generated and deployed with your consent (if required) using Google Analytics and Squarespace. We use cookies to make the Website easier to use and to better tailor our web presence and products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on the Website. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our web properties and to help us improve web structure and content. These cookies do not identify you as an individual. All data is collected and aggregated anonymously.
Two types of cookies may be used on the Website 鈥 鈥渟ession cookies鈥 and 鈥減ersistent cookies.鈥 Session cookies are temporary cookies that remain on your device until you leave the Website. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or 鈥渓ifetime鈥 of the specific cookie and your browser settings).
Our Website uses 鈥減erformance鈥 and 鈥渁nalytical鈥 cookies that help us understand how visitors interact with our web properties by providing information about the areas visited, the time spent on the Website, and any issues encountered, such as error messages. They help us improve the performance of the Website, alert of any concerns and more. Squarespace may also use some 鈥渘ecessary cookies,鈥 because they allow visitors to navigate and use key features on the Website.
Google may adjust its cookies from time to time. Please visit the following website to review its latest details on cookies: .
Squarespace may adjust its cookies from time to time. Please visit the following website to review its latest details on cookies: .
Your choices with respect to Cookies
If you do not agree to our use of cookies, you should set your browser settings accordingly or not use the Website. Most internet browsers are initially set up to automatically accept cookies. You can change the settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies.
For one way to opt out of the aggregation and analysis of data collected about you on the Website by Google Analytics, if you so choose, visit and download and install the Google Analytics Opt-out Browser Add-on.
For one way to opt out of the aggregation and analysis of data collected about you on the Website by Squarespace, if you so choose visit and follow the instructions provided.
Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.
If you disable the cookies that we use, this may impact your experience while using the Website. For example, you may not be able to visit certain areas of the Website.
If you use different devices to view and access the Website (e.g., your computer, smartphone, tablet), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.
Additional Information for Individuals Whose Personal Data is Subject to the GDPR or the UK GDPR
Residents of the European Economic Area (鈥EEA鈥) and the UK (such residents of either, 鈥EEA/UK Residents鈥) have certain rights with respect to their personal data[1] pursuant to the GDPR or the UK GDPR, as applicable and as further described in this section. If you are an EEA/UK Resident and do not agree with 老夫子传媒鈥檚 use of your personal data as set forth in this Privacy Policy, you should not submit your personal data to 老夫子传媒. However, if you do not submit certain personal data to 老夫子传媒, or if you exercise your rights to prevent 老夫子传媒 from using such personal data, you should be aware that 老夫子传媒 may not be able to do business with you.
For the purposes of applicable data privacy legislation, 老夫子传媒 is a 鈥渃ontroller鈥 of EEA/UK Residents鈥 personal data. We transfer, use, store and/or otherwise process your personal data outside of the EEA or the UK, primarily in the U.S. (and may do so in certain other countries), and the laws of the U.S. and certain other destination countries may not offer the same standard of protection for personal data as countries within the EEA or UK. EEA/UK Residents鈥 personal data also may be processed by staff operating outside the EEA or UK who work for us or for one of our vendors (for example, those who supply support services to us).
In cases of cross-border transfers to countries outside of the EEA or UK, as applicable, if your personal data will be processed in a country with laws that may not be equivalent to, or as protective as, the laws of your home country, 老夫子传媒 will take appropriate steps, in accordance with applicable laws, to require or maintain an adequate level of protection and security for your personal data. For additional information regarding such steps, please contact us using the details set forth at the end of this Privacy Policy.
1. Our bases for collecting and using personal data
We are entitled to use your personal data in the ways set out in this Privacy Policy on the following bases:
the use of personal data is necessary for the performance of a contract with you for provision of our products and/or services (including, for example, fund subscription agreements and fund limited partnership agreements, or other agreements contained in fund subscription materials) or to take steps at your request prior to entering into such a contract;
we have legal obligations that we are required to discharge (including, for example, legal obligations set forth in fund limited partnership agreements, investment advisory agreements, subscription materials and/or other operative documents);
the use of your personal data is necessary for our legitimate interests (including, for example, in marketing to prospective investors for the fund in which you are invested, successor funds thereto or other 老夫子传媒-sponsored funds);
you have consented to such use; and/or
to establish, exercise or defend our legal rights for the purposes of legal proceedings.
We do not expect to process 鈥渟ensitive鈥 or 鈥渟pecial鈥 categories of personal data under the GDPR or UK GDPR;[2] however, if we were to process such personal data, we would do so only where we have asked for your explicit consent, or otherwise where necessary for the establishment, exercise or defense of legal claims, or as otherwise may be permitted under applicable laws.
Provision of certain of your personal data is a legal and contractual requirement to becoming an investor in any 老夫子传媒-sponsored fund or other pooled vehicle. If you choose not to provide such personal data, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you. If you choose to provide your consent with respect to certain processing of your personal data, you can withdraw such consent at any time by contacting us.
2. Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
request access to your personal data (commonly known as a 鈥渄ata subject access request鈥). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully;
request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected;
object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also may have the right to object where we are processing your personal data for direct marketing purposes;
request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see above);
request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and/or
request the transfer of your personal data to another party in a machine-readable, commonly used and structured format.
If you want to exercise any of these rights, please contact us using the details set forth at the end of this Privacy Policy. The various rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your personal data needs to continue for other lawful purposes, such as fulfillment of a legal or contractual requirement.
We will respond to your request within one month of receipt of your request. In some cases, we may not be able to fulfill your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.
3. Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your working relationship with us.
4. Fees
You will not have to pay a fee to access your personal data (or to exercise any of the other above-listed rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the relevant information. Alternatively, we may refuse to comply with the request in such circumstances.
5. What we may need from you
To access your personal data (or to exercise any of the other above-listed rights), we may need to request specific information from you to help us confirm your identity and ensure your right to access the personal data (or to exercise any of your other above-listed rights). This is another appropriate security measure designed to ensure that personal data is not disclosed to any person who is not entitled to receive it.
6. Right to complain
If you wish to request further information about any of the above-listed rights, or if you are unhappy with how we have handled your personal data, please contact us using the details set forth at the end of this Privacy Policy. If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with the GDPR, UK GDPR or other applicable data privacy legislation, you can make a complaint to the supervisory authority in your country. For example, in the UK you should contact the Information Commissioner鈥檚 Office: or 0303 123 1113.
Additional Information for Individuals Whose Personal Information is Subject to the CCPA
Residents of the state of California have certain rights with respect to their personal information[3] pursuant to the CCPA and as further described in this section. Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act (12 CFR 1022) and/or the California Financial Information Privacy Act.
Under certain circumstances, under the CCPA, you may have the right to:
request that we disclose, free of charge, the categories and specific pieces of personal information we collect about you (and, if applicable, sell or otherwise disclose to a third party and the categories of such third parties), the sources from which such personal information was collected, and the business purpose for collecting, selling or disclosing such personal information;opt out of the sale of your personal information (as noted above, we do not currently sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising);
opt out of the sale of your personal information (as noted above, we do not currently sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising);
request that we delete the personal information we have collected about you; and
request that we correct any inaccurate or outdated personal information we have collected about you.
We will not discriminate against any California resident who seeks to exercise the rights set forth in this section.
You have the right to appoint an authorized agent to exercise these rights on your behalf. If you want to exercise any of these rights, or have your authorized agent exercise any of these rights on your behalf, then please contact us using the details set forth at the end of this Privacy Policy. To exercise any of these rights, we may need to request specific information from you or your authorized agent to help us confirm your identity and ensure your right to exercise these rights.
These rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you are currently an investor in one of our funds and you request that we delete the personal information we have collected about you, the CCPA may permit us to deny such request and retain certain categories of your personal information to the extent necessary to manage the applicable fund and our business relationship with you in connection with that fund.
For consumers with disabilities who need to access this Privacy Policy in an alternative format, please contact us using the details set forth at the end of this Privacy Policy.
Contact Us
Should you have any questions or concerns relating to this Privacy Policy or the processing of personal information we hold about you, please contact us:
By post: 545 Madison Avenue, 10th Floor, New York, New York 10022
By phone: 212-508-3300
By email: contact@truarcpartners.com
Footnotes
[1] For the purposes of this section, 鈥減ersonal data鈥 has the meaning given to such term in the GDPR or UK GDPR, as applicable.
[2] 鈥淪pecial鈥 or 鈥渟ensitive鈥 categories of personal data include, among other things, data concerning your health, revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or concerning your sexual orientation.
[3] For the purposes of this section, 鈥減ersonal information鈥 has the meaning given to such term in the CCPA.