Website Privacy Policy

The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on these Website over the last twelve (12) months include the following:

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Category:Identifiers
Examples: Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).
Collected: YES

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Category: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Examples: Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets).
Collected: YES

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Category: Protected classification characteristics under California or federal law
Examples: Date of birth, citizenship and birthplace.
Collected: NO

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Category: Commercial information
Examples: Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).
Collected: NO

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Category: Biometric information
Examples: Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.
Collected: NO

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Category:  Internet or other similar network activity
Examples: Use of our Website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries
Collected: YES

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Category: Geolocation data
Examples: Physical location or movements.
Collected: NO

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Category: Sensory data
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: NO

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Category: Professional or employment-related information
Examples: Current or past job history or performance evaluations.
Collected: NO

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Category:  Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: NO

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Category: Inferences drawn from other personal information
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: NO

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Category:  Sensitive Personal Information
Examples: Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.
Collected: YES, as to the following types of information: account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only.

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We do not collect or use sensitive personal information other than:

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• To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;

• As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;

• As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;

• For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);

• To perform services on behalf of our business;

• To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and

• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.