Privacy Policy

Respecting and protecting investor privacy is vital to our business. This Privacy Notice describes how Freeman Spogli Management Co., L.P. (“Freeman Spogli”), and the funds advised by Freeman Spogli (collectively, the “Funds” and together with Freeman Spogli, “us” or “we”), collect, use, share, transfer, store, and protect (“process”) Personal Information.

By accessing and using this website or using our services, you agree and consent to the collection, use and disclosure of your Personal Information as outlined in this Privacy Notice.

Who is Covered by the Privacy Notice?
This Privacy Notice applies to individuals who are prospective, current, and former investors in the Funds, including Freeman Spogli clients. When you are no longer our investor or client, we may continue to share your Personal Information as described in this Privacy Notice.

The Personal Information We Collect
“Personal Information,” as used in this Privacy Notice, includes nonpublic personal information and any data that, either alone or when combined with other information we hold, identifies or could reasonably be linked to an individual covered by this Privacy Notice. Personal Information may include but is not limited to your address, social security number, the amount of your assets or income, and data related to wire transfer instructions.

Some of the Personal Information we collect may be deemed sensitive under data protection laws, including identifiers such as Social Security number. We will use such sensitive information only for lawful purposes in compliance with data protection law and will not use sensitive personal information provided to infer characteristics about you other than as required to comply with law or legal process such as for AML/KYC purposes.

How We Collect Personal Information
This Privacy Notice applies to all Personal Information you provide us, including in connection with our solicitation and administration of your investment in the Funds. You may also provide us with Personal Information through your subscription documentation, as well as through ongoing communications with us by mail, e-mail, or telephone. We also collect Personal Information from third parties, such as credit bureaus, affiliates, or other companies.

How We Use and Share Personal Information
We may use or share Personal Information for any lawful purpose, including where this is necessary:

for our everyday business purposes, such as for accounting and administration purposes, providing our investment products and services, communicating with investors and prospective investors, analyzing our performance, or developing new investments and business opportunities;

for compliance with our legal or regulatory obligations, such as compliance with anti-money laundering requirements, tax reporting obligations, and/or regulatory or judicial requests;

for our legitimate interests, such as in connection with the investigation and assertion of our legal interests or the sale or reorganization of all or a portion of our business; and/or
with your consent or at your request.

We also may disclose personal information (1) when disclosure is necessary or appropriate to prevent harm or financial loss or in connection with an investigation of suspected or actual illegal activity, (2) to protect our operations, and (3) to establish and protect the rights, privacy, safety or property of Freeman Spogli, our affiliates, you, and others.

We may disclose Personal Information, including Personal Information about current or former investors, to our affiliates or to nonaffiliates in the following ways. We may disclose Personal Information of current or prospective clients or investors— including your address, social security number, the amount of your assets or income, and data related to wire transfer instructions—to nonaffiliated third-parties for our everyday business purposes, such as to process your transactions, maintain your investments in the Funds, respond to court orders and legal investigations, or as permitted by law.

We may provide such information to our affiliates, attorneys, banks, auditors, securities brokers, administrators, custodians, and service providers as may be necessary to facilitate the acceptance, management, and administration of your investment in the Funds and to enable them to perform services on our behalf.

We may share your Personal Information where it is necessary for compliance with a legal obligation to which we are subject or in connection with the investigation and assertion of legal rights.

We may share your Personal Information with third parties that acquire, or are interested in acquiring, all or a part of our business.

We do not share Personal Information with our affiliates, nonaffiliates, or other financial companies for their own direct marketing purposes.

We may also share information with your consent, to service your accounts, and in connection with legal proceedings.

We do not sell Personal Information or share it for purposes of cross-contextual behavioral advertising and have not done so within the past twelve months.

Protecting Your Information
We maintain physical, electronic, and administrative controls designed to protect Personal Information from unauthorized access or use. Nonetheless, no method of information storage or transmission is completely secure, and we do not guarantee the security of information. To help us protect Personal Information, we ask that you notify us as soon as possible if you become aware of any misuse of Personal Information.

Personal Information subject to this Privacy Notice will only be retained for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, reporting, and recordkeeping requirements.

Cookies
We and our service providers may use cookies and other online tracking mechanisms. Cookies are alphanumeric identifiers that are transferred to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our website, while others are needed for our website to function. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

We may use third-party web analytics services and other technologies on our website to collect and analyze usage information through cookies and similar tools; engage in activities such as auditing, research, or reporting; and provide certain features to you. Cookies operate in the background, and you can turn them off by adjusting you device and/or browser settings but doing so may make it difficult to use some of the features of our services or certain features may not be available to you.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals.

Sending your Personal Information Internationally
We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law. Where this is the case, we will take appropriate measures to protect information about you in accordance with this Privacy Notice.

Your Rights
Individuals in certain jurisdictions may have certain data subject rights. These rights vary, but they may include the right for individuals to:

be informed about the purposes for which your Personal Information are processed;

access your Personal Information, including requesting us to disclose to you the Personal Information we have collected, used and disclosed about you during the past 12 months;

stop direct marketing;

restrict the processing of your Personal Information;

have incomplete or inaccurate Personal Information corrected;

ask us to stop processing your Personal Information;

complain to a data protection ombudsman;

obtain a copy of your Personal Information in a portable format;

opt out of the sale or sharing of Personal Information; and

require us to delete your Personal Information in some limited circumstances. (i) request access

How to Exercise your Data Subject Rights
Individuals who submit requests for access or erasure of Personal Information will be required to verify their identity by answering certain questions. We will not disclose or delete any information until such individual’s identity is verified. If you are making a request for access, we may not be able to provide specific pieces of Personal Information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your Personal Information, your account with us, or our systems or networks. If you are making a request for erasure, we will ask that you confirm that you would like us to delete your Personal Information again before your request is submitted. In certain circumstances, we may not erase all Personal Information, as permitted by applicable law.

You may designate an authorized agent to submit a request on your behalf by providing that agent with your signed permission to do so. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us and directly confirm with us that you provided the authorized agent permission to submit the request before we can honor the request. Agents who make requests on behalf of individuals will be required to verify the request by submitting signed authorization from the individual. We will not honor any requests from agents until authorization is verified.

Additional California Disclosures
If you are a California resident, please review our California Privacy Notice. California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what Personal Information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your Personal Information to outside parties for their direct marketing to you without your consent.

Updates to this Privacy Notice
We may change this Privacy Notice at any time and will notify our investors of any material changes. It is your obligation to review this Privacy Notice from time to time. By using our services and visiting our website, you represent that you read, understand, and accept the terms of this Privacy Notice. Your continued use of our website and services following the posting of changes to terms contained in this Privacy Notice will mean you understand and accept those changes.

Getting in Touch
If you have any questions regarding this Privacy Notice or wish to discuss your data protection rights, please contact us using the following information: Christopher M. Iorillo at (310) 444-1822.