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.
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 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 number. We will use such 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 do not disclose information to third parties except as required or permitted by law. 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 marketing purposes. We will not share information we collect about you with outside companies, unless the law allows. For example, we may share information with your consent, to service your accounts, and in connection with legal proceedings. We will limit sharing among our companies to the extent required by applicable law.
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 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.
Individuals in Andorra, Argentina, Australia, California, Canada, Cayman Islands, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right for individuals to: (i) request access to and correction or erasure of their Personal Information; (ii) restrict or object to the processing of their Personal Information; and (iii) obtain a copy of their Personal Information in a portable format. Individuals may also have the right to lodge a complaint about the processing of Personal Information with a data protection authority. If you want to exercise any of these rights, please submit a request using the contact information provided below.
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 Notice
This Privacy Notice was last updated in April 2023. We may change this Privacy Notice at any time and will notify our investors of any material 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.