OUR COMMITMENT TO PRIVACY

Your privacy is important to Council Capital and its affiliates (together, “Council Capital,” “our,” “us,” “we” or “company”). To better protect your privacy and comply with our legal obligations, we are providing information explaining our online information practices.

This website privacy notice (this “Privacy Notice”) describes how we gather and use personal information about visitors of this website (the “Website”). For simplicity, we use the terms “personal information”, “personally identifiable information” and “personal data” in this Privacy Notice (and any additional jurisdiction-specific privacy notices) interchangeably. Please read this Privacy Notice carefully. To the extent permitted by applicable data protection and privacy laws, this Privacy Notice constitutes a legally binding agreement between Council Capital and you, the user of this Website and by entering and using this Website, you acknowledge your acceptance of, and agree to be bound by, the Privacy Notice stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Privacy Notice, please do not access or use this Website.

JURISDICTION-SPECIFIC INFORMATION

This Privacy Notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that may apply to you, including as set forth in our California Website Privacy Notice supplement.

In addition to reading this Privacy Notice, if you are a resident of California, please also read our California Website Privacy Notice.

THE INFORMATION WE COLLECT

The types of personal information we collect about you depends on the nature of your interaction with us and our reasons for collecting your personal information. The categories of personal information we collect include the following:

• Identifiers: Name, contact details and address (including physical address, email address and Internet Protocol address), date of birth, citizenship and birthplace.
• Other Identifying Information: Telephone number, signature, and verification documentation.
• Information Related to Internet 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.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we take reasonable  steps to protect your personal data – and in this regard, we maintain physical, electronic and procedural safeguards to prevent unauthorized access to your personal data and to protect the integrity of our systems –  we cannot guarantee the security of any information or data transmitted to or through our Website; any transmission of information or data by you to or through this Website is at your sole risk.

SOURCES OF INFORMATION

In connection with forming and operating our Website, we collect and maintain your personal information from the following sources:

• Information from your communications with us in connection with this Website, including any update notices provided by you.

• Information captured on our Website, including registration and account information, information provided through online forms and any information captured via cookies.

We 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.

HOW WE USE YOUR PERSONAL INFORMATION

We will use your personal information for one or more of the following business or commercial purposes:

• To present the Website and its contents to you and to allow you to interact with the Website;
• To perform services for you, including but not limited to the administrative processes (and related communication) in connection with an investment;
• To create, maintain, customize, and secure your account with us;
• To provide, support, personalize, develop and improve our Website and the products and services that we offer and notify you about changes to our Website or our products and services;
• To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website;
• To provide advertising and marketing services;
• To keep a record of and manage your relationship with us;
• To conduct ongoing operations, administrative, accounting, reporting, account maintenance and other processes;
• To keep investors informed about the business of the general partner or managing member of the applicable investment vehicle and its affiliates generally, including investor notices and reporting;
• To audit and verify the quality and effectiveness of our services and compliance;
• To maintain the safety, security and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity;
• As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations;
• 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 information held by us about our Website users is among the assets transferred; and
• For any other purpose that has been notified to you, or agreed by you, in writing.

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.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information collected in connection with this Website for a business purpose to the categories of third parties indicated below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

• Identifiers: Administrators, governmental agencies or pursuant to legal process.

• Other Identifying Information: Administrators, governmental agencies or pursuant to legal process.

• Information Related to Internet Activity: Administrators, governmental agencies or pursuant to legal process.
  
  

CAPACITY

You represent to Council Capital that you have the authority to visit this Website according to the Terms of Use. 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 information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

RETENTION OF PERSONAL INFORMATION

We retain your personal information for as long as reasonably necessary and proportionate to achieve the purposes and uses set out in this Privacy Notice, as authorized by law, and to meet legal, taxation, accounting, risk management or business requirements. We may retain personal information for longer where required by our regulatory obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others. Your personal information may be deleted when it is no longer relevant or when you withdraw consent (pursuant to the rights detailed directly in this may be exercised by using the contact information contained at the end of this Privacy Notice) within the parameters of applicable law.

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, including to help provide you with a better experience when you browse our Website. 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 wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

You may access any personally identifiable information we have about you by contacting Council Capital at cfo@councilcapital.com.

NOTIFICATION OF CHANGES

We reserve the right to amend this Privacy Notice (and any jurisdiction-specific privacy notices) from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Notice (and any jurisdiction-specific privacy notices). Accordingly, users are strongly encouraged to review our Privacy Notice (and any applicable jurisdiction-specific privacy notices) regularly. If we decide to change our Privacy Notice (and any jurisdiction-specific privacy notices), we will post those changes on the Website 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 information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Notice (and any applicable jurisdiction-specific privacy notices) under which the information was collected. Your continued access or use of this Website following the posting of changes to this Privacy Notice (and any applicable jurisdiction-specific privacy notices) means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Notice (and any applicable jurisdiction-specific privacy notices), please stop accessing this Website. Please check this page frequently and review any changes to this Privacy Notice (and any applicable jurisdiction-specific privacy notices) carefully so you are aware of any changes, as they are binding on you.

MISCELLANEOUS

The provisions in our Terms of Use are hereby incorporated by reference.

CONTACT US

If you have any questions or concerns about this Privacy Notice, or if you wish to appeal any of our decisions, exercise any of your rights hereunder or request to view this Privacy Notice in an alternate format, please contact Council Capital at cfo@councilcapital.com.