Privacy Notice 1
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Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our individual limited partners. We have a long-standing policy of protecting the confidentiality and security of information we collect about you. We are providing you with this notice to help you better understand why and how we collect certain personal information, the care with which we treat that information, and how we use that information.
Sources of Non-Public Information: In connection with forming and operating our private investment funds (or “funds”) for our investors, we collect and maintain non-public personal information from the following sources:
Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail or in subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation);
Information about your transactions with us or others; and
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.”
Categories of Personal Information We May Collect:
name, date of birth and birth place;
contact details and professional address (including physical address, email address and telephone number);
account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly);
information regarding your use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history);
risk tolerance, transaction history, investment experience and investment activity;
information regarding investors’ status under various laws and regulations, including social security number, tax status, income and assets;
accounts and transactions with other institutions;
information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses;
information regarding citizenship and location of residence;
source of funds used to make the investment in the applicable fund(s); and
anti-money laundering, identification (including passport and drivers’ license) and verification documentation.
Disclosure of Information: We do not disclose any non-public personal information about you to anyone, except as permitted or required by law or regulation and to service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental organizations and self-regulatory organizations, consultants and placement agents.
Former Investors: We maintain non-public personal information of our former investors and apply the same policies that apply to current investors.
Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your non-public personal information in our possession or under our control.
Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time. The examples contained within this notice are illustrations only and are not intended to be exclusive. This notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that may apply to you, including as set forth in our additional privacy notices.
PRIVACY NOTICE SUPPLEMENT FOR CALIFORNIA RESIDENTS
This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018 (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth above in the Privacy Notice. Consumers with disabilities may access this notice by contacting PLC for a version that may be printed as a separate document.
Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:
name, date of birth and birth place;
contact details and professional address (including physical address, email address and telephone number);
account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly);
information regarding your use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history);
risk tolerance, transaction history, investment experience and investment activity;
information regarding investors’ status under various laws and regulations, including social security number, tax status, income and assets;
accounts and transactions with other institutions;
information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses;
information regarding citizenship and location of residence;
source of funds used to make the investment in the applicable fund(s); and
anti-money laundering, identification (including passport and drivers’ license) and verification documentation.
We share the above categories of personal information with third-party service providers as set forth in “Disclosure of Information” in the Privacy Notice above.
Purposes for Collecting Personal Information: We may collect or share the personal information we collect about you for one or more of the following business or commercial purposes:
performing services for you, including but not limited to:
the administrative processes (and related communication) in preparing for the admission of investors to the fund(s);
ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund;
the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
auditing and verification’s related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and
complying with U.S., state, local and non-U.S. laws, rules and regulations.
We do not sell any of the personal information we collect about you to third parties.
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
The categories of personal information we collected about you;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting such personal information;
Categories of third parties with whom we share the personal information;
The specific pieces of personal information we have collected about you; and
Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, please submit a request using any of the methods set forth below.
Call us using the following number: (203) 307-5900
Email us at PLC
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 a current telephone number and current mailing address. 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 by mailing two forms of identification showing your first name, last name, and current address and a signed authorization allowing an agent to request information on your behalf.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline.