Our Commitment to Your Privacy:  We are sensitive to the privacy concerns of our prospective, former and current investors.  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.  This Privacy Notice applies to personal information that is collected on our website, through our marketing efforts or from information provided by you.

Gramm-Leach-Bliley Act:  The Gramm-Leach-Bliley Act, as may be amended from time to time (“GLBA”), requires all “financial institutions,” defined to include investment advisers and investment companies, to establish procedures and systems to assure privacy of the personal and financial information of its “customers.”  Strictly speaking, the GLBA requirements apply only to “customers” who are individuals.  However, as a matter of practice the following procedures apply to the conduct of the Firm’s business generally and not with respect to information of only individual clients or investors.

General Data Protection Regulation:  For individuals in the EU, the EU General Data Protection Regulation (the “GDPR”) governs the way we, as data controllers, and third parties we hire to process your personal information, as data processors, collect, use, share and retain your personal information.

California Consumer Privacy Act:  For individuals residing in California, the California Consumer Privacy Act (“CCPA”) governs the way businesses process and sell the personal information of California consumers and households.

Personal Information:  Personal information is any information relating to you or that we can otherwise link to you or your household.  The types of personal information we collect and share may depend on the product or service you have with us.  This information can include:

• name, date of birth, residence or citizenship,
• contact information (e.g., email address, physical address, telephone number),
• social security number or tax identification number,
• information to verify your identity (e.g., driver’s license number, passport),
• wire transfer instructions and other account details including account balances, assets and liabilities,
• source of wealth, and if applicable, employment information, education history, and income,
• investment experience and activity, risk tolerance and transaction history,
• technical information (e.g., IP address) generated from your visits to our website or in relation to materials we send to you electronically,
• any other information relating to you that you provide to us, and identities of authorized representatives or beneficial owners of an investor.

Some of this information we will only have access to if you provide it to us.  When you visit our website, we may collect information about you when you enter and browse our website through the use of “cookies,” web server logs and other electronic tools.  This information may include, without limitation, the number and frequency of your visits to our website, the websites accessed before and after you visit our website, the internet browser used by you and your IP address.

In addition to information collected from your use of our website, we may also collect personal information regarding our business contacts, current and prospective investors, vendors and other contacts.  We will collect some of this personal information if you contact our office or employees directly.

For the avoidance of doubt, in the case of institutional investors, personal information includes the information of individuals linked to such institution.

Sources of Nonpublic Information:  In connection with forming and operating our private investment Funds, we collect and maintain personal identifying information from the following sources:

1. Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via email, in subscription agreements, investor questionnaires or other forms;
2. Information about your transactions with us or others; and
3. Information captured on our website, including registration information and any information captured via cookies, if any.

We may also collect personal information from publicly available or accessible directories, databases and agencies.  If you are unsure as to whether information is nonpublic information, or as to the appropriate procedures to follow, you should contact our Firm’s Chief Compliance Officer.

Use of Information/Legal Bases:  We rely on various legal bases for using and processing your information, including:

1. To perform our contract with you, e.g.:

• administer and manage your subscription,
• manage your investments and maintain your account(s),
• verify your information,
• make capital calls, payments or distributions,
• report investment activity and fund performance, and
• generally administer the affairs of a private fund.

2. To comply with our legal obligations, e.g.:

• comply with federal securities laws,
• comply with laws applicable to investment advisers,
• fulfill our legal, regulatory, and compliance obligations, including identity verification, know your client (KYC), terrorist financing, anti-money laundering, and sanctions checks,
• respond to governmental inquiries or examinations, court orders and legal investigations.

3. To pursue our legitimate interests or those of a third party, except where such interests are overridden by your interests, fundamental rights, or freedoms, e.g.:

• perform accounting, billing, legal or tax audits,
• comply with our internal compliance requirements,
• to maintain our books and records,
• identify and prevent fraud and other unlawful activity,
• conduct credit and financial due diligence,
• facilitate investments, including related financings,
• respond to your inquiries,
• monitor and improve our relationships with investors,
• address or investigate any complaints, claims, proceedings, or disputes,
• seek professional advice, including legal, accounting, and other advice,
• manage and secure access to our offices, systems and online platform,
• market to you,
• perform data analyses,
• undertake a corporate business transaction (e.g., financing, merger, joint venture, sale of assets, bankruptcy),
• report to credit bureaus, and
• manage our legal, operational, financial, commercial, and investment risks.

4. Consent – you have given your consent to process your personal information (if we are relying on this legal basis we will make this clear to you at the time we ask for your consent).

Disclosure of Information:  We do not knowingly disclose personal identifying information about you to any other person or entity except our employees, third party professional vendors who are provided access to such information in order to carry out our operations, or as otherwise required by law or regulation.  These sharing practices are consistent with federal privacy and related laws, and in general, you may not limit the use of your personal information for these purposes under such laws.  We note that the federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you).

Where we engage a third-party processor, the processor will be subject to contractual obligations to:  (i) process in accordance with our prior written instructions, and (ii) use measures to protect the confidentiality and security of your personal information.  In addition, we may share anonymous or non-personally identifiable information with third parties for any purpose in accordance with this Privacy Notice.

We may transfer information about you to our affiliates or service providers outside of the applicable jurisdiction in the course of operating our business and to comply with our legal or contractual requirements.  We have safeguards in place so that any transfer of data outside of the applicable jurisdiction is subject to an adequate level of data protection as mandated by appropriate law.  You may request a copy of such safeguards.

We do not sell or transfer personal information to affiliates or third parties for value and do not anticipate selling personal information for value in the future.  All personal information is transferred to the appropriate parties for legitimate business purposes as described above and we do not profit from the transfer of personal information.  We will amend this Privacy Notice promptly upon any changes to this policy.

Former Investors:  We maintain personal identifying information of our former Investors and apply the same policies that apply to current investors.  We may continue to share your information as described in this Privacy Notice, subject to our record retention policies and applicable law.

Information Security:  We consider the protection of sensitive information to be a sound business practice, and to that end we employ reasonable physical, electronic and procedural safeguards to protect your personal identifying information in our possession or under our control.  These measures include electronic safeguards and secured files and buildings.  We limit employee access to customer information to those who have a business reason to know such information and are committed, by contract or statutory obligation, to confidentiality.  We educate our employees about the importance of confidentiality and investor privacy.

Data Retention:  We will store personal information received from you in accordance with our records retention policy, which generally means that we will keep such information throughout the duration of our business relationship, and as extended if we are required to preserve information in connection with litigation, investigations, or proceedings, or if a longer retention period is required or permitted by applicable law, or conforms with industry best practices.

Your personal information may be deleted when it is no longer relevant or when you withdraw consent, again within the parameters of applicable law.  If we send you emails and/or market to you, you may unsubscribe at any time from communications from us, and we will cease sending you further communications.

Your Rights:  Your rights described in this Privacy Notice are applicable only if you reside in a jurisdiction where the provision of such rights is required by the data protection and privacy laws of the governing regulatory authority, as outlined further below.  These rights may be limited and subject to further legal requirements.

California Consumer Privacy Act, 2020

• The right to be informed about what personal information is being processed and the rationale for the processing;
• The right to know whether and to whom your personal information is sold or disclosed and to opt out of the sale, if applicable;
• The right to access (i.e. view or request copies of) your personal information that is being processed;
• The right to request that we delete your personal information under certain circumstances; and
• The right to not be discriminated against for exercising your rights under the CCPA.

GDPR, 2018

• The right to be informed about what personal information is being processed and the rationale for the processing;
• The right to access (i.e. view or request copies of) your personal information that is being processed;
• The right to request that we rectify personal information if it is inaccurate or out of date;
• The right to request that we delete your personal information (the right to be “forgotten”) under certain circumstances;
• The right to restrict processing your personal information if you contest its accuracy, the lawfulness of its processing or if we no longer need it;
• The right to object to the processing of your personal information if processing is based on our legitimate interests or for direct marketing purposes;
• The right to be informed about and object to the existence of automated decision making, including profiling, and about its significance and consequences on you; and
• The right to request a transfer of your personal information to a third party in certain circumstances.

Breaches (GDPR):  In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information, we will notify the applicable supervisory authority in the EU within 72 hours of discovering the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons.  We will also notify each affected subject of a breach without undue delay if the breach is likely to result in a high risk to the rights and freedoms of natural persons.  We are not required to notify you of a breach if:

• the breached data is encrypted,
• if we have taken measures, such as wiping the data remotely, and such breach is unlikely to result in a material adverse effect, or
• if providing notice requires disproportionate efforts, in which case a public communication should be made, rather than notice to each person.

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 is intended to comply with the privacy provisions of applicable U.S. federal law, the GDPR and the CCPA.  There may be additional rights under other foreign or domestic laws that apply to you.

If you believe that we have breached GDPR requirements, a list of the EU data protection authorities is available at:  http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.  If you believe that we have breached our CCPA requirements, the law provides businesses with a 30-day right to cure, if possible.

If you have any questions concerning this Privacy Notice, please contact the Chief Compliance Officer at (630) 784-2200.