1. Scope. Provider utilizes the Website to provide certain investment management, investor reporting, and communication services to you (the “Services”). In the course of providing the Services, Provider may collect “Personal Information”, which means any information relating to an identified or identifiable natural person (a “data subject”) (an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person).
   
2. Changes to this Policy. Provider reserves the right to update this Policy from time to time by posting a new Policy on this page, and in some cases where changes are material Provider may also contact you via electronic mail or post a notice on the homepage to let you know of such changes. You are advised to consult this Policy regularly for any changes. Your continued use of the Website after such changes have been made constitutes acceptance of those changes.

1. Information that You Provide. Provider collects any information that you voluntarily provide, including when you create an account on the Website, via cookies, communications through the Website or when you use the Services available through the Website. We collect and maintain the following categories of Personal Information:
   
   1. Contact Information: name, address, email, telephone number;
   2. Identification Information: signature, date of birth, place of birth, citizenship, location of residence, social security number, taxpayer identification number, driver’s license, passport, other government identification and numbers;
   3. Background Information: information required to perform, or revealed in, know-your-customer (“KYC”) and anti-money laundering (“AML”) due diligence, investor accreditation and consents;
   4. Financial Information: assets, income, net worth, amounts and types of investments, risk tolerance, capital account balances, capital commitments, capital contributions, account data, other investment participation information, funds transfer information, beneficiaries, positions, percentages of fund, share or option numbers and values, vesting information, investment history, transaction information, tax status and information;
   5. Investment Information: information about your interest in the relevant investment, including ownership percentage, capital investment, income and losses; and
   6. Technical or account information: electronic device and usage information (for example, from cookies and similar technology), registration information and online account data.
2. Obtaining Information. We collect and maintain Personal Information (i) from your communications with us in connection with this Website, including any update notices provided by you, and (ii) captured on the Website, including registration and account information, information provided through online forms, the “Contact Us” page and any information captured via cookies.
3. Automatically Collected Information. Provider may automatically collect certain technical information from your computer or mobile device when you use the Website, such as your Internet Protocol address, your web browser type and version, the name and version of your operating Website, the pages you view on the Website, the pages you view immediately before and after you access the Website, and the search terms you enter on the Website. This information allows Provider to recognize you and personalize your experience if you return to the Website using the same computer or mobile device, and to improve the Website and the Services.
4. Information about Legal and Other Materials. In addition, Provider may collect technical information from your computer or mobile device concerning your receipt of communications, access to materials and approval or execution of contracts, consents or other statements or agreements by means of the Website, including the Website’s Terms of Use and this Policy.
5. Combining Personal Information. Provider 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.
6. Cookies. Provider may collect this information using “cookies”, which are small text files that the Website saves on your computer or mobile device, or similar technologies. You can disable cookies in your browser settings, but doing so may affect the functionality of the Website. Provider may also collect information using “web beacons”, which are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon or using unique links that can distinguish when individual users click the link. Web beacons and unique links, alone or in conjunction with cookies, may help Provider compile information about your interactions with electronic mail sent to you in connection with the Services. For further information, see the Cookie Policy in Section 6 below.
7. Cross-Site Tracking. Provider does not utilize technical measures in the Website to track your activities across different web sites or online services, whether you configure your browser’s Do Not Track feature or otherwise. At this time, we do not currently respond to Do Not Track Signals.The Website does utilize third-party application programming interfaces controlled by third parties, such as to display maps and graphs, that may attempt to track your activity across other sites that utilize those interfaces.
8. Reviewing and Correcting Information. You may update or correct contact information and other Personal Information stored about you on the Website by accessing your account/profile page, or by sending a written request to the Provider.

Provider may collect, use, disclose, and otherwise process your Personal Information for a number of purposes, including, but not limited to:

1. Accessing the Website and Providing the Services. Provider uses your Personal Information to provide you with the Services, or products, services or information related to the Website or the Services, including: providing you with information about the Website, Services or required notices; customizing your experience when using the Website, such as by providing interactive or personalized elements on the Website; and providing you with content based on your interests. The legal basis for such use are the Website’s Terms of Use and this Policy.
2. Analysis. Provider uses your Personal Information for improving the Website and/or the Services, including by (i) combining or aggregating any of the information collected through the Website or elsewhere for generating and analyzing statistics about your use of the Website and user demographics and traffic patterns and (ii) using anonymized data that may or may not be derived from Personal Information but does not personally identify you, both for disclosure to third parties and for the purpose of enhancing the Services and developing new Service offerings. The legal basis for such use are the Website’s Terms of Use and this Policy and Provider’s legitimate interest in improving the Website and Services.
3. Security. Provider may use your Personal Information for safety and security purposes, including sharing of your information for such purposes, when it is necessary to pursue Provider’s legitimate interests in ensuring the security of the Website and Services, including detecting, preventing and responding to fraud, intellectual property infringement, violations of the Website’s Terms of Use, violations of law or other misuse of the Website; and when Provider believes in good faith that disclosure is necessary (A) to protect Provider’s rights, the rights of other users of the Website, the integrity of the Website, or your safety or the safety of others, or (B) to detect, prevent or respond to fraud, intellectual property infringement, violations of the Website’s Terms of Use, violations of law or other misuse of the Website.
4. Service Providers. Provider engages third-party service providers (such as payment processors, hosting providers and analytics and security providers) to assist in operating and marketing the Website. Provider’s engagement of third-party service providers is often necessary for Provider to provide the Services to you, particularly where such third-party service providers ensure that the Website and Services are operating and secure. In other cases, Provider has a legitimate interest in third-party service providers that can help improve the Website and the Services.
5. Other Disclosure. Provider may disclose Personal Information about you to others: (a) with your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of the terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims. Provider may also transfer your Personal Information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, acquisition or sale, joint venture, assignment, transfer or other disposition of all or any portion of Provider’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that Provider transfer Personal Information to will not be permitted to process your Personal Information other than as described in this Policy without providing you notice and, if required by applicable laws, obtaining your consent.

If you submit your information to a Provider via Juniper Square, Provider may provide you with information about the Website, Services or required notices. In addition, Provider may use collected information for delivering marketing communications that may be of interest to you. You have the right to ask Provider not to process your Personal Information for marketing purposes.

1. Jurisdiction. Information collected through the Website will be stored in, processed in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the Website, you acknowledge such transfer to, storage in and processing within the United States.
2. Security. Provider is committed to protecting your information from unauthorized access, use or disclosure. The Website and its operators maintain administrative, technical and physical safeguards designed to protect the information collected through the Website. For example, all information you transmit to the Website is encrypted using Transport Layer Security technology (TLS). However, no information or communication Website can be 100% secure, so Provider cannot guarantee the absolute security of your information. In addition, Provider is not responsible for the security of information that you transmit to the Website over networks that Provider does not control, including the Internet and wireless networks. measures here.
3. Retention. Provider will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. If you wish to access or correct any information Provider holds about you, you may have your data deleted, blocked or corrected (as long as compliant with applicable law). Provider also collects and retains information through the Website in an anonymized form, i.e. tracking the pages you visit and how long was spent on each page.

This section provides Provider’s cookie policy and describes how Provider uses Cookies and similar technologies. For more information on Provider’s general data privacy practices, please see the full Policy.

1. Cookies. Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. Provider uses cookies, web beacons and similar technologies (“Cookies”) to enhance your user experience, understand your usage of the Website and Services and to perform analytics. Cookies may also be set by other websites or services that run content on the page you are visiting. The provision of your data via Cookies is voluntary except for those Cookies that Provider places on your device because it is necessary for the performance of the Website or Services. Provider uses “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave the Website or Services. A persistent Cookie may remain on your device for much longer until you manually delete it.
2. Use. Cookies can contain the following information about you and your use of the Website: browser type, search preferences, data relating to which pages of the Website that you have visited and the date and time of your use. Provider uses Cookies for the following purposes:
   
   1. To enable and support security features, prevent fraud, and protect your data from unauthorized access.
   2. To enable features and help us provide you with personalized content.
   3. To analyze how you use the Website and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how you reached the Website.
3. Third-Party Cookies. Provider uses the following third-party Cookie on the Website:
   
   1. Google Maps and Google Charts. The Website includes mapping and charting services from Google. These services use cookies in their internal operations. See https://policies.google.com/privacy for details.
4. Opting Out. You can control and/or delete cookies as you wish – for details, see https://www.aboutcookies.org/. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work as intended by Provider.

The Website and communications from Provider may contain links to websites operated by third parties. You acknowledge and agree that Provider is not responsible for the collection and use of your information by such websites that are not under Provider’s control. Provider encourages you to review the privacy policies of each website you visit.

The Website is not directed to, nor does Provider knowingly collect information from, children under the age of 18. If you become aware that your child or any child under your care has provided information without your consent, please contact Provider immediately using the contact information provided below. The Website is only intended for individuals who are at least 18 years of age.

You may from time to time enter into binding legal agreements relating to certain Services available through the Website, which may have terms that are different from those of this Policy. In the event of any inconsistency, the terms of such other agreement shall control with respect to such Services.

Role of Juniper Square

1. Host and Operator. Juniper Square, Inc., a Delaware corporation (“Juniper Square”) hosts and operates the Website on behalf of Provider as a data processor. As operator of the Website, Juniper Square has access to, stores and processes all Personal Information received and collected about you by means of the Website, as well as information that Provider furnishes to Juniper Square about you, for the purpose of hosting and operating the Website and facilitating provision of products and services by Provider to you. Juniper Square does not direct or control Provider’s use or storage of Personal Information about you. Juniper Square’s collection, use and disclosure of your Personal Information is described in the Juniper Square privacy policy, which is available at https://www.junipersquare.com/legal/privacy_policy.html.
2. Business Transfer. If Juniper Square, or substantially all of Juniper Square’s assets, are acquired, or in the unlikely event that Juniper Square were to go out of business or enter bankruptcy, user information will be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Juniper Square may continue to use your Personal Information as set forth in this Policy (as it may be amended from time to time).

If you have any questions about this Policy, the collection or use of information about you or wish to exercise any rights in connection with, or access this Policy in an alternative format (each, a “Communication”), please write to Provider at [email protected] or 140 East 45th Street, 34th floor, New York, NY 10017.

We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information or your investor portal access credentials, if applicable in order to verify your Communication.

Date: March 2025

This California Website Privacy Policy (the “California Website Privacy Policy”) supplements the Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This California Website Privacy Policy 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 California Website Privacy Policy is otherwise set forth in the Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this California Website Privacy Policy apply to?

This California Website Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you?

We collect limited types of personal information through our website and investor reporting portals as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depend on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:

Category	Examples	Collected
A. Identifiers	Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and AML information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets).	YES
C. Protected classification characteristics under California or federal law	Date of birth, citizenship and birthplace.	YES
D. Commercial information	Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).	YES
E. Biometric information	Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.	NO
F. Internet or other similar network activity	Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.	YES
G. Geolocation data	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. Sensitive Personal Information (see further information on use of sensitive personal information below)	Social security, driver’s license, state identification card, or passport numbers; 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; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.	YES, as to the following types of information: social security, driver’s license, state identification card, or passport numbers; account log-in, financial account in combination with any required security or access code password; or credentials allowing access to an account only.

We do not collect or use sensitive personal information other than:

• To perform services or provide products as would reasonably be expected by an average consumer who requests those services or products;
• As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
• As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
• For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
• To perform services on behalf of our business; and
• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

How do we use your personal information?

We collect personal information for the business or commercial purposes and from the sources set forth in “Collection of Information” and “Obtaining Information”, respectively, in the Policy above. We retain the categories of personal information set forth above in the “What information do we collect about you?” section of this California Website Privacy Policy only as long as is reasonably necessary for those business or commercial purposes set forth in “Collection of Information” in the Policy above, except as may be required under applicable law, court order or government regulations.

Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or 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” or “unsubscribe” link provided in all our marketing emails.

Who do we disclose your personal information to?

We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business or commercial purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category	Category of Third-Party Recipients
A. Identifiers	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal law	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
D. Commercial information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
E. Biometric information	N/A
F. Internet or other similar network activity	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
G. Geolocation data	N/A
H. Sensory data	N/A
I. Professional or employment-related information	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	N/A
K. Inferences drawn from other personal information	N/A
L. Sensitive Personal Information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

How do we keep your personal information secure?

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Your rights under the CCPA

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. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons. 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;
• the 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 yes, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the 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. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

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, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact Us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following toll-free number: (844) 278-8589.
Email us at the following email address: [email protected]

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

Please contact [email protected] with any questions about this California Website Privacy Policy.

Our commitment to privacy

Your privacy is important to Rockwood Capital, LLC (together with its affiliates, “Rockwood”, “our”, “us” or “we”). To better protect your privacy, we are providing information explaining our online information practices.

This EEA-UK Website Privacy Policy (this “EEA-UK Website Privacy Policy” or “Policy”) describes how we process and use information for visitors of this website (this “Website”) in accordance with EEA and UK Privacy Laws.

For the purposes of this EEA-UK Website Privacy Policy, “EEA and UK Privacy Laws” mean all applicable laws and regulations relating to privacy, protection or processing of personal data in the European Economic Area (the “EEA”), European Union (“EU”) and United Kingdom (the “UK”), including the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union Withdrawal Act 2018 (“UK GDPR”), and including in respect of the foregoing any implementing or successor legislation and any amendments or re-enactments. The terms “controller”, “data subject”, “personal data”, “processor”, “process” and “processing” shall be interpreted in accordance with the applicable EEA and UK Privacy Laws.

For the purposes of applicable EEA and UK Privacy Laws, Rockwood and its affiliated general partners and managing members will each be a controller of any personal data collected by us when you interact with us in the ways described above (e.g., when you visit our Website, etc.). In simple terms, this means that we: (i) “control” the personal data that we collect from you or other sources, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data. If you have any questions regarding our use of your personal data, or this EEA-UK Website Privacy Policy, please contact us at [email protected].

We rely on various legal bases under applicable EEA and UK Privacy Laws in order to process your personal data, including our legitimate interests, contractual necessity and as required by law. We use the personal data we collect to operate our business and provide you with the services and products we offer and perform essential business operations.

If we require your personal data 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 data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot conduct business with you. In this case, we may have to cancel an existing business arrangement with you but we will notify you if this is the case at the time.

Further information about the legal bases under which we process your personal data is included in the section headed “Why we use your personal data.”

You do not need to take any action as a result of this EEA-UK Website Privacy Policy, but you do have certain rights as described below in the section headed “Your rights.”

PERSONAL DATA WE COLLECT ABOUT YOU

By accessing any part of this Website, you acknowledge that we may process your personal data as described in this EEA-UK Website Privacy Policy. If we ask for your consent to a particular use of your personal data on our Website and you give that consent, that use will also be covered by this Policy.

The personal data that we may collect from or about you include the following:

• Contact Information: name, address, email, telephone number;
• Identification Information: signature, date of birth, place of birth, citizenship, location of residence, social security number, taxpayer identification number, driver’s license, passport, other government identification and numbers;
• Background Information: information required to perform, or revealed in, know-your-customer (“KYC”) and anti-money laundering (“AML”) due diligence, investor accreditation and consents;
• Financial Information: assets, income, net worth, amounts and types of investments, risk tolerance, capital account balances, capital commitments, capital contributions, account data, other investment participation information, funds transfer information, beneficiaries, positions, percentages of fund, share or option numbers and values, vesting information, investment history, transaction information, tax status and information;
• Investment Information: information about your interest in the relevant investment, including ownership percentage, capital investment, income and losses; and
• Technical or account information: electronic device and usage information (for example, from cookies and similar technology), registration information and online account data.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How We Obtain Your Personal Information

Information you provide to us

We collect your personal data when you decide to interact with us and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal data via online form, email, post, telephone and this website and when you log into the investor online portal. We may also collect personal data about you through automated technology when you access and use our website, such as cookies and similar technology – please see the “Cookie Policy” section in the Privacy Policy for information about how we use such technologies.

Information provided by third parties or publicly available sources

We collect personal data from third parties, such as background information from a background check provider, personal data viewed on social media (e.g., LinkedIn) or information obtained from publicly available lists of individuals subject to sanctions or trade restrictions.

If you represent one of our vendors, business partners or portfolio investments, we may also collect your personal data from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.

We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. In this situation, your personal data will be provided to us by third parties involved in that potential transaction (including the target of any investment).

WHY WE USE YOUR PERSONAL DATA

We may use your personal data for the following purposes:

Purpose	Legal Basis
To improve our Website design, operation and usefulness.	Our legitimate interest in operating our business and providing investment services.
To conduct business with you or to provide you with the services or financial products you have requested, including responding to your enquiries and requests and providing you with support.	Contractual necessity; and/or our legitimate interest in operating our business and providing investment services.
To improve the security of the website.	Our legitimate interest in operating our business and providing investment services; and/or legal requirement.
To keep a record of and manage your relationship with us.	Our legitimate interest in operating our business and providing services; and/or legal requirement.
To verify your identity (including to conduct AML or KYC checks and to enable you to access our offices) or to evaluate a potential investor, business partner or supplier.	Our legitimate interest in operating our business and providing investment services securely; contractual necessity; legal requirement; and/or consent.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about the website users is among the assets transferred.	Our legitimate interest in operating our business.
To protect against, identify and prevent fraud, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our website, investor portals, products and services, databases, technology assets or our business, and other malicious, or unlawful activity.	Legal requirement; and/or our legitimate interest in operating our business and providing investment services securely and safely.
To conduct conflicts checks.	Legal requirement.
Litigation management and conducting internal audits and investigations.	Legal requirement; and/or our legitimate interest in operating our business.
To process and administer details associated with your investment and service your requests, and to offer and improve our services.	Our legitimate interest in operating our business; and/or consent.
To make suggestions and recommendations to you about products or services that may be of interest to you and to provide advertising and marketing services.	Our legitimate interest in operating our business.
Complying with our legal obligations and corporate governance practices, which may require recording or monitoring telephone calls or other communications with you.	Legal requirement; our legitimate interest in operating our business; and/or consent.
To obtain advice from our professional advisors, including lawyers and accountants.	Our legitimate interest in operating our business; and/or consent.
To audit and verify the quality and effectiveness of our services and compliance.	Our legitimate interest in operating our business.
For statistical analysis and market research.	Our legitimate interest in operating our business.
For any other purpose that has been notified, or has been agreed, in writing.	Consent.

Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data.

No solely automated decision-making, including profiling, is used when processing your personal data.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

MARKETING COMMUNICATIONS

We will only send you marketing newsletters, updates, alerts and similar marketing or promotional communications where we have obtained your prior consent to keep you informed of our products and services in which you might be interested, or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in to certain kinds of marketing and all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

DISCLOSURE AND TRANSFER OF PERSONAL DATA

The transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through this Website; any transmission of information or data by you to or through this Website is at your sole risk.

Your personal data will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including service providers, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. To the extent your personal data is transferred to a Non-Equivalent Country (as defined below), such transfers will only be made in accordance with applicable EEA and UK Privacy Laws. For further information about the safeguards/derogations used, please contact us at [email protected]. For the purposes of this EEA-UK Website Privacy Policy, “Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the UK (as applicable) in accordance with the applicable EEA and UK Privacy Laws to ensure an adequate level of protection for personal data.

We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal data to the new owner of the relevant business and their advisors on the basis of our legitimate interest.

SECURITY AND RETENTION OF PERSONAL DATA

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this EEA-UK Website Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact us at [email protected].

Capacity

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 data from anyone under the age of 18 without parental consent. If we learn we have collected or received personal data 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 visit www.aboutcookies.org to review comprehensive information about cookies, how they are used and how you may manage your cookie preferences.

Information regarding the cookies we use is described in the “Cookie Policy” section in the Privacy Policy.

Your rights

You have the right to access the personal data 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. To exercise these rights and controls, please contact us at [email protected].

• Access: You have the right to ask for a copy of the personal data that we hold 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.
• Correction: You may notify us of changes to your personal data if the data we hold and process about you is inaccurate or it needs to be updated.
• Deletion: If you think that we should not be holding or processing your personal data 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 data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data 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 data, override your own rights.
• Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
• Portability: If you wish to transfer your personal data that we hold and process about you on the legal ground of contractual necessity 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 (by a clear affirmative action) to allow us to process your personal data for a particular purpose not specified in this EEA-UK Website Privacy Policy, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
  
  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
  
  

Notification of changes

We reserve the right to amend this EEA-UK Website Privacy Policy from time to time by updating this EEA-UK Website Privacy Policy. If we decide to change our EEA-UK Website 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 data or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with this EEA-UK Website Privacy Policy under which the information was collected.

Contact us

If you have any questions or concerns about this EEA-UK Website Privacy Policy, please contact us at [email protected].

Complaints

Should you wish to lodge a complaint with regards to how your personal data has been processed by us:

• under the UK GDPR and/or the Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us; or
• under the EU GDPR, please contact your local supervisory authority in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.