PRIVACY NOTICE FOR CALIFORNIA CONSUMERS (last updated February 2022)

This notice contains disclosures required by the California Consumer Privacy Act (“CCPA”), is only relevant to residents of California, and applies only to the collection or other use of “personal information” that is subject to the CCPA.  Consumers with disabilities may access this notice by requesting a PDF version by contacting us through one of the contact tools mentioned within this notice.

  1. INFORMATION WE COLLECT. 

In the past 12 months, we have collected the following categories of personal information about California consumers:  Identifiers; Other personal information categories, as listed in the California Customer Records statute; Protected classification characteristics under California or federal law; Internet or other similar network activity; Professional or employment-related information.

We collect personal information from the following categories of sources:

  • Investors or other “customers”; 
  • Service providers;
  • Portfolio companies of affiliated private funds; and
  • Government entities.
  1. USE OF PERSONAL INFORMATION. 

We may use the personal information we collect for one or more of the following purposes:

  • Marketing our private funds;
  • Providing performance information and other updates;
  • One or more of the following business purposes:
    • Performing services (for us or our service provider) relating to our private fund investment activities;
    • Auditing related to our interactions with you (e.g., counting ad impressions to unique visitors, verifying positioning/quality of ad impressions, and auditing compliance, etc.);
    • Legal compliance;
    • Detecting and protecting against security incidents, fraud, and illegal activity;
    • Internal operations; and
    • Activities to maintain and improve our services
  1. SHARING PERSONAL INFORMATION. 

We may disclose personal information in one or more of the categories identified above to:

  • Service providers, including but not limited to: administrators, lenders, banks, auditors, law firms, consultants, placement agents, employment agencies, credit bureaus;
  • Affiliates;
  • Legal or government regulatory authorities as required by applicable law; and
  • In connection with a potential business transfer.

In the past 12 months, we have not sold any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

  1. RIGHTS OF CALIFORNIA CONSUMERS. 

The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:

  • The right to request (a) the categories and specific pieces of personal information we collect, use, disclose, and sell about you, (b) the categories of sources from which we collected your personal information, (c) our purposes for collecting or selling your personal information, (d) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we have shared personal information;
  • For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties;
  • The right to request that we delete the personal information we have collected from you or maintain about you;
  • The right to opt out of our sale(s) (if any) of your personal information; and
  • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

You may submit requests relating to your exercise of rights under the CCPA to us:

by telephone at (833) 877-0120;

by submitting a request using this online form or

by email at [email protected]

 

We may need to request additional information from you to verify your identity or understand the scope of your request.  In verifying requests, we will require you to provide, at a minimum, your full address and telephone number.  If we are unable to verify your identity, we will need to deny your request.

You may designate an authorized agent to make a CCPA request on your behalf.  In such case, we will ask the agent to provide proof that you have given the agent signed permission to act on your behalf. In addition, we will ask you to (1) verify your identity directly with us in the manner described above and (2) directly confirm with us that you have provided the agent permission to make the request on your behalf.