Oak HC/FT General Privacy Notice
Last Updated: July 23, 2026
At Oak HC/FT Management Company, LLC (collectively, with its affiliates, “Oak HC/FT,” “us,” “our” or “we”), we are committed to responsibly handling personal information1 that we collect, use or otherwise process regarding our investors (including, for the purposes hereof, potential investors or former investors and any individuals who are legal persons connected with an investor) and individuals who visit our website (the “Website”) or otherwise communicate or engage with us (“you” or “your”).
Oak HC/FT controls the collection and processing of this personal information. In this policy (“Privacy Policy”), we set out the principles governing our collection, use and other processing of personal information that we may obtain about you. Your access to the Website and use of the services provided by Oak HC/FT are subject to this Privacy Policy. By visiting the Website, completing any of our online forms or otherwise submitting personal information to us, you agree to the terms of this Privacy Policy, and you hereby consent to our collection, use, disclosure and other processing of your personal information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the services provided by Oak HC/FT, access the Website or otherwise submit personal information to us.
We reserve the right to change this Privacy Policy at any time, as circumstances or requirements change, and all updates are effective immediately when we post them here and they apply on a go-forward basis. For this reason, we encourage you to review this Privacy Policy whenever you visit the Website so you are aware of any updates, as they will be applicable to you and your personal information. If you have any questions or comments in connection with this Privacy Policy, please contact us at Oak HC/FT Management Company, LLC, 2200 Atlantic Street, Suite 300, Stamford, CT 06902, tel. (203) 717-1350 or info@oakhcft.com.
Personal Information that We Collect
The types of personal information collected by or on behalf of Oak HC/FT about you varies based on our interactions with you (for example, whether you are an investor or an individual visiting the Website).
The personal information we collect about you in the course of your interaction and correspondence with us via the Website includes, for example, the following:
- any personal information that you submit when you contact us using our contact details on the Website, such as your name or email address;
- your IP address and other online identifiers/web beacons;
- details of your online browsing activities on the Website, including, for example, the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including, for example, date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page;
- your browser type, language and version, relevant plug-ins, operating system and platform; and/or
- your time zone settings.
The personal information we collect about you as an investor in the course of your interaction and correspondence with Oak HC/FT and its representatives includes, for example, the following:
- contact information such as name, email address, telephone numbers, business and private addresses (and proof of name and address) and any other contact or other personal details you may supply, including passport number, social security number, driver’s license number, state identification card, tax details, nationality, citizenship, tax residency, date of birth and family connections;
- information about your business relationship with Oak HC/FT;
- information about your transactions with us, our affiliates and service providers, or others, such as your participation in each of our funds, your capital account balance, capital commitment, contributions and distributions and, in the case of an investor that is an individual retirement account, information with regard to such account;
- information about your business relationships with other parties (including, for example, certain of your investment transactions and holdings and details of business advisers you may employ, including, for example, wealth managers and independent financial advisers);
- details of your company’s directors, shareholders, secretaries, authorized signatories and other comparable officers and/or beneficiaries, and identification documents (including photo identification);
- biographical information such as your professional role, employer, background and interests;
- marketing, communication preferences and related information;
- feedback and survey responses;
- financial information or other information regarding your assets, income and/or financial dealings, such as billing address, bank account, wire transfer instructions, transaction history, other payment information, net worth, holdings, investment history, credit history, reason for investment and source of funds;
- personal characteristics, including, for example, your signature and physical characteristics or description;
- details of any criminal convictions, regulatory or court orders, or suspensions or expulsions from membership in, or association with a member of, a self-regulatory association to which you are subject, or any investigation or proceeding associated with the foregoing;
- records of all communications, including, for example, recordings of your attendance (or your representative’s attendance) at certain meetings/phone calls and electronic communications with our staff and meeting notes;
- personal information about transactions with us or others, such as ownership of certain types of accounts or other account data;
- details of any complaints made by you with respect to your dealings with the relevant service provider;
- data received from due diligence activities (such as due diligence relating to anti-money laundering, politically exposed persons and sanctions checks); and/or
- fraud inquiries (for example, information from police reports).
Of the above categories of personal information that we may collect about you, the following may be considered “sensitive” categories under certain applicable laws: social security number, passport number, driver’s license number, state identification card and financial account information2. This Privacy Policy, and the practices described herein, applies equally to our collection, use, disclosure and other processing of such “sensitive” personal information.
The Website is not intended for children, and we do not knowingly collect data relating to children (including any minors under the age of 16).
How We Collect Personal Information about You
We may collect personal information directly from you, your professional advisors or other third parties, or through the Website in the following ways:
- when you provide us your business card or contact information in person or via email;
- when you register to attend one of our events;
- when you enter into an investment advisory contract;
- when you complete subscription agreements, investor/purchaser questionnaires or other required forms;
- when you seek financial advice;
- when you tell us about your investment portfolio;
- when you provide us with information necessary to identify you and complete security checks when you visit our offices; and/or
- when you correspond with us (including, for example, written, telephone, videoconference or electronic contacts) regarding your accounts or transactions with non-affiliated third parties.
We may also collect or receive personal information about you from other sources, including:
- publicly available sources of information such as company websites;
- governmental agencies and regulatory bodies;
- credit agencies;
- tax authorities;
- third parties providing services to us; and/or
- investor advisors (including, for example, independent financial advisors).
We automatically collect basic technical information from all visitors to the Website. We collect this technical information during your visit to the Website through our automatic data collection tools, which may include cookies and other commonly used technologies (e.g. web beacons). Please see the section entitled “Cookies” below for a discussion of our use of cookies on the Website.
We may combine personal information that you provide to us with other sources in some circumstances.
Further, we obtain personal information about your interests in funds (such as capital account balances and percentage interests) from the funds themselves and their nonaffiliated service providers.
How We Use Your Personal Information
We will only use your personal information where we have a lawful reason to do so. Unless otherwise indicated, we process your personal information for business, Oak HC/FT (and not third-party) marketing, and/or regulatory and compliance purposes, including to provide services to you, to fulfill a contract with you or when we have a legal or regulatory duty with which to comply, including as follows:
- to provide you with services that you have requested, administer the relationship between you and us (including subscription acceptance, communications, record keeping, reporting and monitoring of our activities, and investor relations activities), and to fulfill our contractual obligations, including, for example, any contractual obligations as a/the general partner, manager and/or investment advisor to any fund in which you have subscribed;
- to operate, develop and improve the Website and our other IT systems and safeguard their security;
- to understand the demographics, interests and behavior of users of the Website in order to personalize your visit to the Website;
- to fulfill our contractual obligations to other third parties to whom you have provided your information;
- for our internal business administration, record keeping and security purposes;
- for legal and regulatory compliance purposes, including, for example, as necessary for anti-money laundering, fraud prevention, tax reporting or sanctions purposes or to respond to governmental, regulatory or law enforcement agency requests;
- where required or considered appropriate, including, for example, prior to admitting you to a fund, prior to accepting capital contributions or making a capital distribution, carrying out “know-your-client” (KYC) checks and other procedures that we undertake in the course of our ongoing business relationship with you; and/or
- to provide information to future or potential purchasers or merger partners of all or a portion of Oak HC/FT or any of its funds, or to provide information as may be necessary in connection with other corporate transactions, such as financings or restructurings.
From time to time, we may provide you with marketing information about the products and services of Oak HC/FT, such as Oak HC/FT-sponsored funds that we may be raising. You have the right to ask us not to send you marketing messages by post, telephone or email or any combination of these at any time; however you acknowledge that such information may be included in general update letters and while you may choose not to receive such updates, we are under no obligation to provide redacted versions of such letters or otherwise create separate reports on your behalf excluding such marketing information. You can also let us know at any time that you wish to change your mind and to start receiving such messages. You can do this by replying directly to the marketing message or at any time by contacting us.
We do not use or otherwise process your personal information, including “sensitive” personal information, for purposes of automated decision-making, including profiling.
We do not use or otherwise process your “sensitive” personal information other than as described herein.
We may aggregate, anonymize, or otherwise de-identify your personal information and use it for any purpose permitted by applicable law, and we may use information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable laws. We also may use your information for any other purposes disclosed to you at the time of collection, that you have previously authorized, or with respect to which you subsequently provide your consent.
Consequences of Failing to Provide Personal Information
If you do not agree with our processing of your personal information as set forth in this Privacy Policy, you should not submit your personal information to us. However, where personal information is required to satisfy a statutory obligation (including compliance with applicable laws) or a contractual requirement, failure to provide such personal information may result in any of your subscriptions in our funds being rejected or your interest in such funds becoming subject to compulsory redemption or withdrawal, as applicable. Where there is suspicion of unlawful activity, failure to provide personal information may result in, to the extent permitted under applicable laws, the submission of a report to the relevant law enforcement agency or supervisory authority. Further, if you exercise your rights in such a manner to prevent us from processing your personal information, please note that we may not be able to do business with you or otherwise perform some of the tasks we need in order to provide certain products or services to you.
How We Disclose Your Personal Information
We do not disclose any personal information about you except as detailed in this Privacy Policy. We may disclose your personal information to the following categories of third parties:
- vendors and service providers needed to operate the Website, and the fund(s) in which you are invested, including, for example: (i) legal counsel, (ii) accountants, (iii) audit firms, (iv) banks, (v) administrators, (vi) tax consultants, (vii) tax preparers, (viii) placement agents, (ix) financial advisors, (x) broker-dealers, (xi) transfer agents, (xii) custodians, (xiii) other entities that assist us with distributions to investors, (xiv) other persons or entities that are assessing our compliance with industry standards and (xv) vendors supporting the Website or our other IT systems;
- law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. (including, for example, the U.S. Securities and Exchange Commission) or of other countries with whom a fund (or a fund’s portfolio company) transacts who request or require such information in order to issue business or regulatory licenses or permits or where we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation, or if we reasonably consider that such disclosure is necessary or advisable to help prevent or detect fraud or other crimes or to protect our rights, property or safety, or that of our clients, investors or others. Such disclosure (including, for example, tax status, identity or residency or other personal or payment information, documents or self-certifications) may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
- any person or entity, including, for example, any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over us or our affiliates, if (i) we determine in our discretion that such disclosure is necessary or advisable pursuant to or in connection with any U.S. federal, state or local, or non-U.S. law, rule, regulation, executive order or policy, including, for example, any anti-money laundering law, the USA PATRIOT Act of 2001 or any subpoena, court order or judicial process, and (ii) such disclosure is not otherwise prohibited by applicable law, rule, regulation, executive order or policy;
- third parties with whom a fund (or a fund’s portfolio company, or a business that issues a fund’s investment) transacts who require information to comply with local anti-money laundering laws, including, for example, banks and other financing counterparties; and/or
- other financial companies, non-financial companies or others (for example, prospective investors in future funds).
In addition, we may disclose personal information as follows:
- if we are under a duty to disclose or share your personal information with tax authorities, such information requested by such tax authorities, who may transfer such information to the government or the tax authorities in another country where you may be subject to tax. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
- subject to any contractual confidentiality obligations, we may disclose investor names, investors’ participation on any limited partner advisory committee, and investors’ respective jurisdictions and/or commitment sizes, in each case, to other limited partners or prospective investors of an Oak HC/FT-sponsored fund;
- if you use a financial or other adviser (as indicated on your subscription agreement or subsequently communicated to us), the details of your investments and valuations may also be provided to such adviser(s);
- to future or potential purchasers or merger partners (i) for due diligence purposes on a need-to-know basis, (ii) as necessary for pre-closing integration planning or (iii) in connection with the consummation of a sale or merger transaction;
- on a need-to-know basis to current, future or potential lenders or other relevant persons as necessary in connection with other corporate transactions, such as financings or restructurings; and/or
- on a need-to-know basis to our affiliates and service providers (e.g., our attorneys, accountants and other entities that assist us with distributions to our service providers).
For clarity, Oak HC/FT and our affiliates (including, for example, any Oak HC/FT-sponsored funds) also share personal information amongst themselves. We also may disclose your information to any other third party where you have provided consent to such disclosure.
We do not sell or offer to sell any personal information about you to third parties or share your personal information with third parties for purposes of cross-context behavioral advertising.
Opt Out
This opt out notice applies to you if and only to the extent we are subject to the Gramm-Leach-Bliley Act (Public Law 106-102) (the “GLBA”) with respect to our processing of your “nonpublic personal information” as defined herein. If you prefer that we not disclose nonpublic personal information about you to unaffiliated third parties (other than our service providers), you may opt out of those disclosures, that is, you may direct us not to make those disclosures (other than, among other permissible disclosures under the GLBA, disclosures for our everyday business purposes, such as to process transactions and maintain accounts). If you wish to opt out of disclosures to such unaffiliated third parties, you may do so by contacting us as set forth above. Please note that this Privacy Policy, as well as the ability to opt out of certain disclosures, applies only to individuals and individual retirement accounts. Institutional and entity investors do not have the right to opt out of disclosures.
How We Retain Your Personal Information
We will retain your personal information for at least as long as necessary to fulfill the purpose for which we collected it, to comply with legal, regulatory or reporting obligations, to assert or defend against legal claims or as applicable laws and business best practices allow. Further details of our data retention policies and procedures are available in our retention policy, information about which you can request by contacting us. When determining relevant retention periods, we take into account factors, including, for example, the following:
- our contractual and business relationships with you;
- legal obligations under applicable law to retain personal information for a certain period of time;
- the amount, nature and sensitivity of your personal information;
- the potential risk of harm from unauthorized use or disclosure of your personal information;
- statutes of limitation under applicable law;
- (potential) disputes; and/or
- guidelines issued by relevant supervisory authorities.
How We Protect Your Personal Information
We acknowledge that the personal information you provide may be confidential, and we maintain policies and procedures designed to maintain the confidentiality of and protect your personal information in accordance with our normal procedures and applicable law. We restrict access to personal information about you to those employees who need to know that information to provide services to our funds and their investors. We maintain physical, electronic and procedural safeguards designed to guard your personal information and prevent unauthorized access thereto. In addition, we will continue to assess new technology for protecting information.
Unfortunately, the storage and transmission of electronic information is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of information stored on our or our service providers’ servers or transmitted via email or through the Website; you transmit personal information to us at your own risk. In addition, links on the Website may take you to third-party websites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies or cookie policies on those linked websites. We are not responsible for any linked websites.
Further, you may have created or may in the future create an account with our third-party fund administrator(s) (including through its service provider(s)). We are not responsible for the websites of our third-party fund administrator(s) or its service provider(s), and you should review any separate privacy policies or cookie policies that they provide to you or that they post on their websites.
If you are granted access to our investor portal, you are responsible for all actions taken with your username and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your username or password to access or use any part of the investor portal or our Website. If your password has been compromised for any reason, you should contact us immediately for a new password.
Cookies
What are Cookies?
Cookies are small, sometimes encrypted text files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit a website. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e., how long it will remain on your device) and a value, which is usually a randomly generated unique number. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
How we use Cookies
When you visit the Website, we, through our service providers (including Google Analytics), automatically generate and deploy a cookie or other online tracking device (e.g. web beacons). We use cookies in order to improve your experience on the Website by recognizing you when you visit the Website, such as by assigning a session ID, and to deliver content specific to your interests. The cookies we place may also collect information about your IP address, or click stream data within our Website (i.e. the actions taken in connection with the Website). This information helps us improve the functionality of the Website.
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). The Website also uses “performance” and “analytical” cookies, which 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.
Your choices with respect to Cookies
If you do not agree to our use of cookies, you should set your browser settings accordingly or not use the Website. Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the Website.
If you use different devices to view and access the Website (e.g., your computer, smartphone, tablet), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.
Do Not Track
Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. We do not modify your online experience based upon whether such a signal is broadcast.
Additional Information for Individuals Whose Personal Data is Subject to the GDPR or the UK GDPR
Under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) or the UK General Data Protection Regulation (i.e., the GDPR as implemented into UK law, the “UK GDPR”), residents of the European Economic Area (“EEA”) and the United Kingdom (“UK” and such residents of either, “EEA/UK Residents”) have certain rights with respect to their personal data3 as further described in this section. If you are an EEA/UK Resident and do not agree with Oak HC/FT’s use of your personal data as set forth in this Privacy Policy, you should not submit your personal data to Oak HC/FT. However, if you do not submit certain personal data to Oak HC/FT, or if you exercise your rights to prevent Oak HC/FT from using such personal data, you should be aware that Oak HC/FT may not be able to do business with you.
For the purposes of applicable data privacy legislation, Oak HC/FT is a “controller” of EEA/UK Residents’ personal data. We may transfer, use, store and/or otherwise process your personal data outside of the EEA or the UK, primarily in the U.S. (and may do so in certain other countries), and the laws of the U.S. and certain other destination countries may not offer the same standard of protection for personal data as countries within the EEA or UK. EEA/UK Residents’ personal data also may be processed by staff operating outside the EEA or UK who work for us or for one of our vendors (for example, those who supply support services to us).
In cases of cross-border transfers to countries outside of the EEA or UK, as applicable, if your personal data will be processed in a country with laws that may not be equivalent to, or as protective as, the laws of your home country, we will take appropriate steps, in accordance with applicable laws, to require or maintain an adequate level of protection and security for your personal data. For additional information regarding such steps, please contact us using the details set forth at the beginning of this Privacy Policy.
1. Our bases for collecting and using personal data
We are entitled to use your personal data in the ways set out in this Privacy Policy on the following bases:
- the use of personal data is necessary for the performance of a contract with you for provision of our products and/or services (including, for example, fund subscription agreements, fund limited partnership agreements or other agreements contained in fund subscription materials) or to take steps at your request prior to entering into such a contract;
- we have legal obligations that we are required to discharge (including, for example, legal obligations set forth in fund limited partnership agreements, investment advisory agreements, fund subscription materials and/or other operative documents);
- the use of your personal data is necessary for our legitimate interests (including, for example, in marketing to prospective investors for the fund in which you are invested, successor funds thereto or other Oak HC/FT-sponsored funds);
- you have consented to such use; and/or
- to establish, exercise or defend our legal rights for the purposes of legal proceedings.
We do not expect to process “sensitive” or “special” categories of personal data under the GDPR or UK GDPR4; however, if we were to process such personal data, we would do so only where we have asked for your explicit consent, or otherwise where necessary for the establishment, exercise or defense of legal claims, or as otherwise may be permitted under applicable laws.
Provision of certain of your personal data is a legal and contractual requirement to becoming an investor in any Oak HC/FT-sponsored fund or other pooled vehicle. If you choose not to provide such personal data, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you. If you choose to provide your consent with respect to certain processing of your personal data, you can withdraw such consent at any time by contacting us.
2. Your rights in connection with personal data
Under the GDPR and UK GDPR, your rights to your personal data include, among other things:
- the right to access your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully;
- the right to restrict the processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
- the right to have incomplete or inaccurate data corrected. This enables you to have any incomplete or inaccurate personal data we hold about you corrected;
- the right to ask us to stop processing your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also may have the right to object where we are processing your personal data for direct marketing purposes;
- the right to request for us to “port” your personal data in a portable, reusable format to other organizations, where applicable and possible; and/or
- the right to require us to delete your personal data in some limited circumstances. This enables you to ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see above).
If you are a resident of the EEA or UK and would like to exercise any of these rights, you must provide a written statement exercising that right. However, some of the personal data we collect may be necessary for us to provide requested services to you and if you do not wish to provide it, it will affect our ability to provide such services to you. In addition, the various rights are not absolute and each is subject to certain exceptions or qualifications. For example, in the event we encounter circumstances where we are compelled by law, rule or regulation or another applicable requirement to retain or disclose your personal data, we may need to do so even if you have exercised your right to opt out, or otherwise discuss with you whether our use of your personal data needs to continue for such lawful purposes.
We will respond to your request within one month of receipt of your request. In some cases, we may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.
3. Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your working relationship with us.
4. Fees
You will not have to pay a fee to access your personal data (or to exercise any of the other above-listed rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the relevant information. Alternatively, we may refuse to comply with the request in such circumstances.
5. What we may need from you
To access your personal data (or to exercise any of the other above-listed rights), we may need to request specific information from you to help us confirm your identity and ensure your right to access the personal data (or to exercise any of your other above-listed rights). This is another appropriate security measure designed to ensure that personal data is not disclosed to any person who is not entitled to receive it.
If you wish to request further information about any of the above-listed rights, or if you are unhappy with how we have handled your personal data, please contact us using the details set forth at the beginning of this Privacy Policy. If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with the GDPR, UK GDPR or other applicable data privacy legislation, you can make a complaint to the supervisory authority in your country. For example, in the UK you should contact the Information Commissioner’s Office at: https://ico.org.uk/global/contact-us/ or 0303 123 1113.
Additional Information for Individuals Whose Personal Information is Subject to the CCPA
Residents of the state of California have certain rights with respect to their personal information5 pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), and as further described in this section. Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed subject to the Gramm-Leach-Bliley Act (Public Law 106-102), the Fair Credit Reporting Act (15 U.S.C. § 1681 et seq.) and/or the California Financial Information Privacy Act.
Under certain circumstances, under the CCPA you may have the right to:
- request that we disclose, free of charge, the categories and specific pieces of personal information we collect about you (and, if applicable, sell or otherwise disclose to a third party and the categories of such third parties), the sources from which such personal information was collected, and the business purpose for collecting, selling or disclosing such personal information;
- opt out of the sale of your personal information. As noted above, we do not currently sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising;
- request that we delete the personal information we have collected about you; and/or
- request that we correct any inaccurate personal information we have collected about you
We will not discriminate against any California resident who exercises the rights set forth in this section.
You have the right to appoint an authorized agent to exercise these rights on your behalf. As noted above, if you want to exercise any of these rights, or have your authorized agent exercise any of these rights on your behalf, then please contact us using the details set forth at the beginning of this Privacy Policy. To exercise any of these rights, we may need to request specific information from you or your authorized agent to help us confirm your identity and ensure your right to exercise these rights.
These rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you are currently an investor in one of our funds and you request that we delete the personal information we have collected about you, the CCPA permits us to deny such request and retain your personal information to the extent necessary to manage the applicable fund and our business relationship with you in connection with that fund.
For consumers with disabilities who need to access this Privacy Policy in an alternative format, please contact us using the details set forth at the beginning of this Privacy Policy.
Additional Information for Individuals Whose Personal Information is Subject to the Data Privacy Laws of Other Jurisdictions
To the extent that data privacy laws other than the GDPR, the UK GDPR or the CCPA apply to our collection, use, disclosure or other processing of your personal information, you may have certain rights with respect to such personal information (including, depending on the jurisdiction, rights that may be comparable to those of EEA/UK Residents and/or California residents, as described above). In such case, we will follow such other applicable data privacy laws with respect to your rights, and the description herein of the rights of EEA/UK Residents and/or California residents, in each case as and to the extent applicable, shall be considered notice of your rights to the extent that we are required to provide you with such notice under such applicable data privacy laws.
1 For the purposes of this Privacy Policy, the term “personal information” has the meaning given to such term (or to terms of similar intent, such as “personal data”) under applicable law, as and to the extent applicable to your rights and our obligations with respect to such information, including (as and to the extent applicable): (i) “personal information” as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, (ii) “non-public personal information” as defined under the Gramm-Leach-Bliley Act (Public Law 106-102) and/or (iii) “personal data” as defined under the General Data Protection Regulation (EU) 2016/679 or the UK General Data Protection Regulation (i.e., the GDPR as implemented into the laws of the United Kingdom).
2 “Sensitive personal information” means: (1) personal information that reveals (A) a consumer’s social security, driver’s license, state identification card or passport number; (B) a consumer’s 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; (C) a consumer’s precise geolocation; (D) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a consumer’s mail, email and text messages, unless the business is the intended recipient of the communication; (F) a consumer’s genetic data; and (2)(A) the processing of biometric information for the purpose of uniquely identifying a consumer; (B) personal information collected and analyzed concerning a consumer’s health; or (C) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. Sensitive personal information that is “publicly available” pursuant to paragraph (2) of subdivision (v) of Section 1798.140 shall not be considered sensitive personal information or personal information.
“Special categories of personal data” include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
3 For the purposes of this section, “personal data” has the meaning given to such term in the GDPR or UK GDPR, as applicable.
4 “Special” or “sensitive” categories of personal data include, among other things, data concerning your health, revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or concerning your sexual orientation.
5 For the purposes of this section, “personal information” has the meaning given to such term in the CCPA.
