ANNUAL PRIVACY NOTICE
Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our individual partners and clients. We have a long-standing policy of protecting the confidentiality and security of information we collect about you. Accordingly, we are providing you with this Privacy 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. The information contained in this Privacy Notice is subject to any further information contained in any relevant supplementary privacy notice, including the Privacy Notice Supplement for California Residents and the EU Privacy Notice for individuals located in the EU and UK (each as applicable).
Sources of Non-Public Information: In connection with forming and operating our private investment funds for our limited partners and clients, we collect and maintain non-public personal information from the following sources:
- Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail, or in subscription agreements, investor questionnaires, applications or other forms;
- Information about your transactions with us or others; and
- Information captured on our website, including registration information and any information captured via “cookies.”
Disclosure of Information: We do not disclose any non-public personal information about you to anyone, except as permitted or required by law or regulation and to service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
Former Limited Partners and Clients: We will maintain non-public personal information of any former limited partners or clients and apply the same policies that apply to current limited partners and clients.
Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your non-public personal information in our possession or under our control.
Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time. Any examples contained within this notice are illustrations only and not intended to be exclusive. This notice complies with the privacy provisions of Regulation S-P under the Gramm Leach Bliley Act. You may have additional rights under other foreign or domestic laws that may apply to you.
EU Privacy Notice
Altaris, LLC (“Altaris,” the “Company,” “we,” “us” or “our”) is a global investment firm that provides management services to private investment vehicles (the “Altaris Funds”) through its direct and indirect subsidiaries. This notice generally describes data, including personal data that Altaris may receive about natural persons, how we process it and the rights and obligations of natural persons in relation to personal data we may collect in connection with an investment in the Altaris Funds.
For the purposes of applicable EU and UK data protection laws, including the General Data Protection Regulation (EU) 2016/679 (the “EU GDPR”), and the UK equivalent of the EU GDPR (the “UK GDPR”) (collectively, “the EU and UK Privacy Laws”), Altaris will be a controller of any personal data collected by us when you interact with us in the ways described in the Sources of Non-Public Information section of the Privacy Notice.
WHAT INFORMATION DOES THE COMPANY COLLECT?
The Company may hold personal data about natural persons in connection with investments made in the Altaris Funds. If this information changes, please let us know at the earliest opportunity so that our records can be updated. In connection with an investment in the Altaris Funds, the Company may collect the following personal data about natural persons:
- identity information such as title, full name, gender, citizenship, nationality, race, date of birth, photograph, passport or other unique ID number;
- contact details such as home and work address, phone number(s) and email address(es);
- personal and family details such as place of birth and marital status;
- financial data, including bank account details, tax/social security number, sources of wealth, information about net worth and current investments and assets; and
- other information required under applicable law, rule or regulation or as otherwise required in connection with an investment in the Altaris Funds, including data collected in relation to compliance with applicable anti-money laundering/know your customer regulations, applicable tax reporting and anti-tax evasion regulations, or otherwise.
HOW DOES THE COMPANY USE DATA?
The Company may use data, including any personal data, for various purposes, including to operate our business, conduct business with you and perform essential or legitimate business operations in connection with investments made in the Altaris Funds.
We rely on various legal bases under the EU and UK Privacy Laws in order to process your personal data, including for our legitimate interests in managing each Altaris Fund, as necessary for the performance of obligations by Altaris under the organizational documents applicable to each Altaris Fund and subscription agreements, and as necessary in order to comply with legal obligations arising under the applicable and relevant securities laws governing the operation of each Altaris Fund.
We will retain your personal data only for as long as is reasonably necessary for the purposes set out in this EU Privacy Notice, unless a longer retention period is required by law.
DISCLOSURE OF PERSONAL DATA AND TRANSFERS OVERSEAS
Disclosures and Transfers within Altaris
Altaris takes security and legal precautions to ensure the safety and integrity of personal data that is transferred within its organization. Where a transfer of personal data within Altaris involves a transfer of personal data outside the European Economic Area (“EEA”) or UK, such transfers will be made in accordance with the EU and UK Privacy Laws.
Disclosures and Transfers to Third Parties
Personal data will, in certain circumstances, be disclosed to third parties, including third-party fund administrators, custodians of the assets of the Altaris Funds, advisors to Altaris on tax and other related matters, and others as necessary and appropriate.
Where Altaris is under an obligation to do so by law, it may disclose personal data to regulators, courts, the police or tax authorities, or in the course of litigation. In some cases, in accordance with applicable law, it may not be possible to provide notification in advance about the details of such disclosures. The Company will use reasonable efforts to disclose the minimum personal data necessary in such cases.
Where Altaris engages the services of a third-party, Altaris will seek to ensure that such suppliers protect personal data with appropriate security measures and prohibit them from using data other than as instructed by the Company.
RIGHTS IN RELATION TO PERSONAL DATA HELD BY THE COMPANY
Natural persons have certain rights under EU and UK Privacy Laws in relation to the personal data we hold about them. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we require natural persons to verify their identity before responding to any requests to exercise applicable rights. Natural persons have the following rights in relation to their personal data:
- Access: the right to access the personal data held by Altaris and certain information about how we use it and who we share it with. Those wishing to exercise this right should email email@example.com;
- Portability: in certain circumstances, natural persons have the right to receive or ask us to provide their personal data to a third-party in a structured, commonly used and machine-readable format, although we will not provide certain personal data if it would interfere with another’s individual’s rights or where another exemption applies; we are not responsible for the security of the personal data or its processing once received by the third-party;
- Correction: natural persons may insist that we correct any personal data held about them that is inaccurate and have incomplete data completed (including by the provision of a supplementary statement).
- 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 personal data for the purposes for which it was collected, but you still need your personal 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;
- Erasure: natural persons may request that we erase the personal data we hold about them where they believe that it is no longer necessary for us to hold the personal data we hold; or where the natural person believes the personal data we hold about them is being unlawfully processed by us
- Objection: in certain circumstances, in particular where personal data has been provided voluntarily, or consent to use personal data has been otherwise granted, natural persons have the right to restrict or object to our processing of personal data or withdraw consent.
For more detail on when these rights apply, or in order to exercise the rights set out at items (a) through (e) above, please send a message to firstname.lastname@example.org. We must respond to a request to exercise those rights without undue delay and at least within one (1) month (although this may be extended by a further two (2) months in certain circumstances).
In the event that any person wishes to register a complaint about how we process personal data, please email email@example.com and we will endeavor to deal with your request as soon as possible.
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 Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us; or
- the EU GDPR, please contact your local supervisory authority in particular in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.
For all data privacy inquiries and any questions or concerns you have about this EU Privacy Notice, please contact Charles Mullens (firstname.lastname@example.org).
CHANGES TO THIS POLICY
The Company’s EU Privacy Notice may be amended from time to time at the Company’s discretion.
Privacy Notice Supplement for California Residents
This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018 (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement 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 CCPA supplement is otherwise set forth above in the Privacy Notice. 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.
Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:
|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 drivers’ license or state identification card number).||YES|
|B. Additional data subject to Cal. Civ. Code § 1798.80||Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering 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 contain 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||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.||NO|
We do not collect or use sensitive personal information other than:
- To perform services as would reasonably be expected by an average consumer who requests such services;
- 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;
- As reasonably necessary and proportionate to ensure the physical safety of natural persons;
- 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); and
- To perform services on behalf of the our business.
Purposes for Collecting Personal Information: We may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes:
- performing services to you, including, but not limited to:
- the administrative processes (and related communication) in preparing for the admission of investors to the fund(s);
- ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund and the execution of all relevant agreements;
- the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
- ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of (each) fund in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
- keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
- administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase its holding (of shares) in the fund(s);
- facilitating the execution, continuation or termination of the contractual relationship between a investor and the general partner and/or the fund(s);
- facilitating the transfer of funds, and administering and facilitating any other transaction, between a potential investor and the fund(s);
- auditing and verifications related to investor interactions, including, but not limited to, verifying the quality and effectiveness of services and compliance;
- maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity;
- enabling any actual or proposed assignee or transferee, participant or sub-participant of the partnership’s or the investment fund/limited partnership’s rights or obligations to evaluate proposed transactions;
- facilitating business asset transactions involving the investment fund/limited partnership or investment fund/limited partnership-related vehicles; and
- complying with U.S., state, local and non-U.S. laws, rules and regulations.
We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.
Disclosure of Information: We do not share (as such term is defined in the CCPA, i.e., disclose 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. In the preceding twelve (12) months, we have not sold or shared any of the personal information we collect about you to third parties. We do not disclose any non-public personal information about you to anyone, except as permitted or required by law or regulation and to service providers.
Within the last twelve (12) months, we have disclosed personal information collected from you for a business 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, and consultants.|
|B. Additional data subject to Cal. Civ. Code § 1798.80||Administrators and consultants.|
|C. Protected classification characteristics under California or federal law||Administrators and consultants.|
|D. Commercial information||Administrators, lenders, banks, auditors, law firms, and consultants.|
|E. Biometric information||None.|
|F. Internet or other similar network activity||Administrators and consultants.|
|G. Geolocation data||None.|
|H. Sensory data||None.|
|I. Professional or employment-related information||None.|
|J. Non-public education information||None.|
|K. Inferences drawn from other personal information||None.|
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 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, use, disclosure and sale 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;
- Categories of third parties with whom we disclose 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 so, 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 using any of the methods set forth below.
You can contact us by emailing Charles Mullens at email@example.com.
If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email to Charles Mullens at firstname.lastname@example.org, and we will call you between 9 a.m. and 6 p.m. Pacific Time.
You can also write to:
Attn: Charles Mullens
10 East 53rd Street, 31st Floor
New York, NY 10022
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 your investor portal access credentials 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. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. Please contact Charles T. Mullens at 212-931-0242 or email@example.com with any questions or concerns about this Privacy Notice.