PRIVACY NOTICE
What You Should Know
CIP Fund Management LLC (the “Management Company”), its affiliates and CIP Capital Fund III, L.P. and any of its parallel funds, feeder funds and other related vehicles (collectively, “CIP Capital”) recognize the importance of keeping information about our investors secure and confidential.
We do not sell or share your non-public personal and financial information with non-affiliated entities, except as described here.
We carefully manage information, including among our affiliated companies, to safeguard your privacy.
We are providing this notice to you to comply with the requirements, if any, under applicable law.
Our Privacy Policy
CIP Capital is committed to protecting the non-public personal and financial information of our investors. We fulfill our commitment both by limiting, to the extent possible, the collection and use of your personal information and by establishing and implementing policies and systems to protect the security and confidentiality of the information that we do have to collect and use.
In our offices, we limit access to non-public personal and financial information about you to those CIP Capital personnel who need to know the information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect your non-public personal and financial information.
Categories of Information We Collect
We may collect the following types of non-public personal and financial information about you from the following sources:
- Your name, address and identifying numbers, and other personal and financial information, from you and from identification cards and papers you submit to us, on applications, subscription agreements or other forms or communications.
- Information about your account balances and financial transactions with us, our affiliated entities, or nonaffiliated third parties, from our internal sources, from affiliated entities and from nonaffiliated third parties.
Categories of Information We Disclose to Third Parties
Third-party professionals and others who provide services to CIP Capital may receive your name, address and account and other non-public personal, financial and other identifying information about you, as well as information about your pending or past transactions and other personal financial information, but they are contractually required to use this information only as directed by CIP Capital.
We may disclose non-public personal and financial information concerning you to law enforcement agencies, federal regulatory agencies, self-regulatory organizations or other nonaffiliated third parties, if required or requested to do so by a court order, judicial subpoena or regulatory inquiry or otherwise in connection with the investigation and assertion of legal rights.
We do not disclose your non-public personal and financial information to nonaffiliated third parties except in the limited circumstances described above, unless we believe in good faith that disclosure is required or permitted by law or in connection with the reorganization, sale, or other corporate transaction involving CIP Capital or its assets. Because we do not disclose your non-public personal and financial information to nonaffiliated third parties, our Privacy Policy does not contain any ability to opt-out of such sharing.
Categories of Information We Disclose to Our Affiliated Entities
We may disclose your name, address and account and other identifying information, account balances, information about your pending or past transactions and other non-public personal, financial and other identifying information to our affiliated entities for any purpose.
We regularly disclose your name, address and account and other identifying information, account balances and information about your pending or past transactions to our affiliates to administer and service the private fund in which you are invested or to market our products and services to you. CIP Capital’s private fund investors deliver personal financial information to our fund administrators and legal advisors to the private funds.
From time to time, we may share certain information with our affiliates for their marketing purposes. If you would prefer that we do not share information with our affiliates for their marketing purposes, please contact us at the information below to opt-out of such affiliate marketing sharing.
Information about Our Former Investors
We intend to protect non-public personal and financial information about former investors in the same manner as we do for current investors, although it may be destroyed pursuant to our records retention procedures when it is no longer legally required to be maintained.
Information Security
We have implemented reasonable measures to help protect your non-public personal and financial information from loss, misuse, or unauthorized access or disclosure. Although we cannot guarantee information security, we strive to protect your data.
Modifying and Deleting Information
If you would like to review, modify or delete from our database any non-public personal and financial information you previously submitted to us or if you would like to restrict the processing or object to the processing of your personal data and (in certain circumstances) request data portability please let us know. If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time; however, such withdrawal will not affect the lawfulness of the processing before your consent was withdrawn. If you have questions or concerns about the handling of your personal data, please let us know by contacting Melissa Vlak, Managing Director and COO of the Management Company, at 212-257-5003 or mvlak@cip-capital.com. Please note that any data that we have copied may remain in back-up storage for some period of time after your request. Also, please note that we will maintain data whenever we are required to do so by law or in connection with the investigation, assertion and defense of legal rights.