Website Privacy Policy

OUR COMMITMENT TO PRIVACY

Visitors that are residents of the United Kingdom, the European Union or the European Economic Area should refer to our EU Privacy Notice supplement, below.

Your privacy is important to Hunter Point Capital LP and its affiliates (together, “HPC,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.

This Website Privacy Policy (this “Privacy Policy”) describes how we gather and use information for visitors of this website. Please read this Privacy Policy carefully. If you do not agree with any of the terms and conditions contained herein, please do not access or otherwise use this website.

This Privacy Policy constitutes a legally binding agreement between HPC and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, the Privacy Policy stated herein, our Terms and Conditions and all additional terms incorporated by reference herein. If you do not agree to this Privacy Policy, please do not access or use this website.

THE INFORMATION WE COLLECT AND HOW WE USE IT

We may collect various types of information from users of this website. For example, knowing how users use our website – tracking their movement through this website – helps us improve website design and usefulness. As a result, HPC’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (IP) addresses. HPC generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” page.

To the extent that you provide us with any personally identifiable information through or in connection with this website, we may use such information for HPC’s business purposes, but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to HPC, you consent to HPC’s use of such personally identifiable information for the purposes described in this Privacy Policy.

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.

CAPACITY

You represent to HPC that you have the authority to visit this website according to the Terms and Conditions. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

COOKIES

Information regarding how you access this website (e.g., browser type, access times and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

The information below summarizes the different types of cookies we use on the Website, together with their respective purpose and duration (i.e., how long each cookie will remain on your device).

Two types of cookies may be used on the Website – “session cookies” and “persistent cookies.” 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 “lifetime” of the specific cookie and your browser settings).

Type of Cookie
Performance/Analytical

What do they do?
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.

The Performance / Analytical cookies used on the Website include:

Name of Cookie: _ga
First/Third Party: First
Provider: Google
Purpose: Used to distinguish users

Name of Cookie: _gid
First/Third Party: First
Provider: Google
Purpose: Used to distinguish users

Name of Cookie: _gat_gtag_G_FKKPGREDEP
First/Third Party: First
Provider: Google
Purpose: Used to distinguish users

Name of Cookie: AMP_TOKEN
First/Third Party: First
Provider: Google
Purpose: Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.

Google may adjust their cookies from time to time. Please visit https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#analyticsjs to review their latest cookie details.

Do these cookies collect my personal information/identify me?
These cookies do not identify you as an individual. All data is collected and aggregated anonymously.

To opt out of the aggregation and analysis of data collected about you on the Website by Google Analytics, visit https://tools.google.com/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.

If you would like more information about cookies, we can recommend www.aboutcookies.org and www.allaboutcookies.org as helpful resources. Both websites also provide instructions on how to reject cookies if you would like to do so.

You may access any personally identifiable information we have about you by contacting Debra Bricker, Chief Compliance Officer of HPC, at dbricker@hunterpointcapital.com // info@hunterpointcapital.com.

NOTIFICATION OF CHANGES

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.

MISCELLANEOUS

The provisions in our Terms and Conditions are hereby incorporated by reference.

CONTACT US

If you have any questions or concerns about this Privacy Policy, please contact Debra Bricker, Chief Compliance Officer of HPC, at dbricker@hunterpointcapital.com // info@hunterpointcapital.com.

EU Privacy Policy

At Hunter Point Capital LP, we are committed to protecting and respecting your privacy. This policy explains how we collect and use any personal information (i.e., any information that relates to you and that identifies or can be used to identify you) that you share with us, including how we collect, process, protect and share your personal information.

You do not need to take any action as a result of this privacy policy, but you may have certain rights as described below.

We keep this privacy policy under regular review and will advise you of any updates or changes to this privacy policy. This privacy policy was last updated on 11/03/2020.

When you provide us with your personal information, Hunter Point Capital LP and its affiliated companies (together, “HPC”, “we”, “us” and “our”) act as a “data controller”. In simple terms, this means that we: (i) “control” the personal information that you provide, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal information, but only to the extent that we have informed you about the use or are otherwise permitted by law.

If you have any questions regarding our use of your personal information, please contact Debra Bricker, Chief Compliance Officer of HPC, at dbricker@hunterpointcapital.com // info@hunterpointcapital.com.

1. What information do we collect about you? The types of personal information we collect about you depends on the product or service you have requested from us and/or the nature of your interaction with us. The types of personal information we collect includes contact information (such as name, postal and email address and telephone number) and other personal information you submit to us, such as the information you provide to us when you correspond with us in relation to inquiries. The personal information collected about you will help us provide you with a better service and facilitate our business relationship. We do not knowingly collect or solicit personal information from anyone under the age of 16.
2. How we obtain your personal information We collect information about you directly when you provide it to us in online correspondence and in conversations (including via email and telephone). In an offline context, we also collect information about you from the forms and any associated documentation that you complete when subscribing for an investment, shares and/or opening an account with us, including KYC and anti-money laundering information. This will include information about your name, address, date of birth, passport details or other national identifier, driving license, your national insurance or social security number and income, employment information and details about your investment or retirement portfolio(s). We also collect personal information about you from third parties during our investment process, both during diligence on entities that we are considering purchasing or investing in and after making such investments, in each case from such potential or actual investment entities, as part of our continuing interest in such investments and compliance with legal obligations in relation to such investments. We will only collect and process personal information about you where we have lawful bases to do so (please see section 3 below). We may combine personal information that you provide to us with information that we collect from, or about you from publicly available sources. This will include information collected in an online or offline context.
3. Why we use your personal information We will use the personal information you provide us with for the following purposes, and pursuant to the corresponding legal bases: Purpose: To enter into, and perform, contracts with you that you have requested.
   Legal Basis: Contractual necessity Purpose: To improve our website and the products and services that we offer and notify you about changes to our services.
   Legal Basis: Legitimate interest Purpose: To respond to requests for information submitted by you through our website.
   Legal Basis: Legitimate interest Purpose: To keep a record of your relationship with us.
   Legal Basis: Legitimate interest and legal obligation Purpose: To monitor our investments and comply with our legal obligations in relation to them.
   Legal Basis: Legitimate interest and legal obligation Additionally, we will use your personal information to keep you informed of our products and services (e.g. future funds that we are raising), if you have provided your consent to us doing so, or based on our legitimate interest where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” link provided in all our marketing emails. No automated decision making, including profiling, is used when processing your personal information. If we require your personal information due to a legal requirement or obligation, or in order to perform a contract with you, we will make you aware of this at the time we collect your personal information and the possible consequences of you failing to provide this personal information (unless we are restricted from doing so under applicable law).
4. Who we share your personal information with: We will share your personal information with third parties as required by law or regulation. We will also share your personal information with affiliates and certain service providers and professional advisors, including: (i) fund managers, depositories, administrators, custodians and investment advisors; (ii) service providers; and (iii) our lawyers, auditors and other professional advisors, in order to provide services on our behalf, as necessary to fulfil the purposes set out in this privacy policy. We make sure any third party that provides a service to or for us:

   (i)	enters into an agreement with us and meets our standards for data security;
   (ii)	does not use your personal information for any purpose other than the clearly defined purpose relating to the service that such party is providing;
   (iii)	does not share your personal information with any organization without our consent (apart from us); and
   (iv)	holds your personal information securely and retains it only for such period of time as we instruct.

   We will also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment or other disposition of all or a portion of our business, assets or shares.
5. How we keep your personal information secure We are committed to protecting the personal information you entrust to us, and to that end we employ appropriate organizational, physical, technical and procedural safeguards to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use. We also train and instruct our employees that all personal information must be handled in accordance with this privacy policy and applicable privacy and data protection laws, and any misuse by employees is subject to disciplinary action.
6. Our retention of your personal information We will keep your personal information only for as long as is necessary for the purposes it was collected for, set out in section 3 of this privacy policy, unless a longer retention period is required under applicable law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. For further information regarding how long we will keep your personal information, please contact us using the details outlined in section 10 of this privacy policy.
7. Transfer your personal information To the extent that you reside in the European Union, or EU data privacy legislation applies to you, and we transfer your personal information to countries located outside of the European Economic Area (“EEA”), such transfers are made in compliance with applicable data privacy laws. Please contact us for information in relation to the particular safeguards or derogations used in any particular circumstance.
8. Your rights To the extent that you reside in the European Union, or EU data privacy legislation applies to you, you have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. We have explained these individual rights and controls below. To exercise these rights and controls, please contact Debra Bricker, Chief Compliance Officer of HPC, at dbricker@hunterpointcapital.com // info@hunterpointcapital.com.
   • Access: You have the right to ask for details of the personal information that HPC holds about you free of charge, however we may charge a ‘reasonable fee’ if we think that your request is excessive, to help us cover the costs of locating the information you have requested. We will respond to your request as soon as possible and (save for in certain circumstances) within one month.
   • Correction: If there are any inaccuracies in the information we hold about you, please contact us and we will correct them.
   • Deletion: If you think that we shouldn’t be holding or processing your personal information any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
   • Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (unless the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal information for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
   • Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; and/or (iii) where processing is based on legitimate interests.
   • Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
   • Withdrawal of consent: If you previously gave us your consent to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent. If you do not do so, we may continue to rely upon that previous consent to keep using and processing your personal information in the same way.

This website may contain links to other websites. HPC is not responsible for the privacy practices or the content of such third party websites. Please see our online Terms and Conditions for more information about our online terms and policies.

10. How to contract us For any questions regarding our processing of your personal information, please contact Debra Bricker, Chief Compliance Officer of HPC, at dbricker@hunterpointcapital.com // info@hunterpointcapital.com.
11. Complaints If you reside in the European Union, or EU data privacy legislation applies to you, and you should you wish to lodge a complaint with regards to how your personal information has been processed by HPC, please contact your local supervisory authority. In the UK, this is the Information Commissioner ( https://ico.org.uk/).