As required under the United States Federal Trade Commission’s “Privacy of Consumer Financial Information Rules” we are providing this notice to you in order to inform you of our privacy policies and practices with respect to your personal, nonpublic information.
It is important to note that we have always treated the personal information we receive with sensitivity and plan to continue that practice. Certain disclosures are “permitted under the rules” and the rules allow an individual investor to elect to “opt out” of any other disclosures to unaffiliated third parties. We believe that all of our existing and future anticipated disclosures are permissible under these new rules and will therefore not be affected by an “opt out” election. In the unlikely event we deem it necessary to disclose information, which is not permitted under the rules, we have provided you with an election to “opt out” of such disclosure.
In connection with the formation and ongoing activities of our private investment funds, we collect and maintain nonpublic personal information about our individual investors from the following sources:
- Information we receive from you on subscription agreements, investor questionnaires or other forms that you submit to us (including, without limitation, any anti-money laundering, identification and verification documentation) or contracts that you enter into with us;
- Information related to your transactions with us and our affiliates;
- Information related to your transactions with nonaffiliated third parties;
- Information obtained from you in meetings, telephone conversations, voicemails, written correspondence and via email or other forms of communication;
- Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms and any information captured via “cookies”.
We may disclose any of the information we collect, as described above, to third parties and to our affiliates for our everyday business purposes, such as to complete investments by our investment funds, to maintain your accounts, to complete transactions that you request, to respond to court orders, legal investigations and examinations and other customary uses in connection with the activities of our investment funds. For example, we may disclose the information we collect, as described above, to:
- Financial service providers, such as broker-dealers, custodians, banks and others used to finance or facilitate transactions by or operations of our investment funds;
- Actual and potential portfolio companies, purchasers thereof and potential co-investors, and each of their respective advisors if requested in connection with an investment or disposition.
We may also disclose nonpublic personal information about you to nonaffiliated third parties as permitted by law or regulation and in accordance with the agreements governing your investment in our private funds, including, but not limited to:
- Other service providers to our investment funds and/or their general partners, managers and affiliates, such as those who provide accounting, legal, or tax preparation services;
- Other partners and potential investors in our investment funds;
- Transfer agents, portfolio companies, brokerage firms and the like, in connection with distributions to our partners.
With respect to former limited partners, we maintain nonpublic personal information of our former limited partners and apply the same policies that apply to current limited partners.
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
Disclosure Opt Out
If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties, you may opt out of those disclosures (other than disclosures permitted by law or the agreements governing your investment in our private funds); that is, you may direct us not to make those disclosures (other than disclosures permitted by law or the agreements governing your investment in our private funds). To opt out of disclosures to nonaffiliated third parties, please request an Opt Out Form from us. If you have previously returned an Opt Out Form to us, it is not necessary to return it again.