Terms & Conditions
Terms
By accessing or using this website (the “Site”) of Sentinel Global LP and its affiliates (collectively, “Sentinel Global”), you hereby accept and agree to comply with these Terms and Conditions of Use. You acknowledge your understanding that these Terms and Conditions of Use constitute a binding agreement between you and Sentinel Global (sometimes referred to as “we” or “us”) that governs your access and use of the Site, which includes any images, text, illustrations, designs, icons, photographs, programs, music clips, downloads, systems and methods of trading, video clips, graphics, user interfaces, visual interfaces, information, data, tools, products, written materials, services and other content (together, “Content”), including but not limited to the design, structure, selection, coordination, expression and arrangement of the Content available on or through the Site.
PLEASE READ THESE TERMS AND CONDITIONS OF USE CAREFULLY BEFORE USING THE SITE. EACH TIME YOU USE THE SITE, YOUR USE INDICATES YOUR FULL ACCEPTANCE OF AND AGREEMENT TO ABIDE BY THESE TERMS AND CONDITIONS IN CURRENT FORM. IF YOU DO NOT ACCEPT THE TERMS AND CONDITIONS STATED HEREIN, DO NOT USE THE SITE. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS OF USE, YOU AGREE THAT YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE SITE.
YOUR COMPLIANCE WITH THESE TERMS AND CONDITIONS OF USE AND ALL OTHER RULES, PROCEDURES, POLICIES, TERMS AND CONDITIONS THAT GOVERN ALL OR ANY PORTION OF THE SITE IS A CONDITION TO YOUR RIGHT TO ACCESS THE SITE. YOUR BREACH OF ANY PROVISION OF THESE TERMS AND CONDITIONS OF USE OR OTHER RULES, PROCEDURES, POLICIES, TERMS AND CONDITIONS THAT GOVERN ALL OR ANY PORTION OF THE SITE WILL AUTOMATICALLY, WITHOUT THE REQUIREMENT OF NOTICE OR OTHER ACTION, REVOKE AND TERMINATE YOUR RIGHT TO ACCESS THE SITE AND YOU WILL BE FULLY LIABLE FOR CONVERSION, MISAPPROPRIATION, TRESPASS TO CHATTELS AND ALL OTHER CLAIMS AND CAUSES, REGARDLESS OF THE IDENTITY OF CLAIMANT OR INJURED PARTY, ARISING FROM OR RELATING TO YOUR CONTINUED USE OF THE SITE AFTER SUCH BREACH.
Limited Right to Use:
Sentinel Global grants you a limited right to use the Site. Your right to use the Site is subject to your agreement to abide by these Terms and Conditions of Use in their entirety, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of the Site and is limited solely for the purpose of evaluating a potential business relationship with Sentinel Global or for internal business purposes in furtherance of an existing business relationship with Sentinel Global. At any time and for any reason Sentinel Global may revoke your right to use all or any portion of the Site. Without limiting the foregoing, as a condition of your right to access the Site under the Terms of Use, you acknowledge and agree that you shall not directly or indirectly:
Use the Site for any commercial purpose or for the benefit of any third party;
Frame or hyperlink the Site or any portion thereof without the prior written consent of Sentinel Global;
Remove any proprietary notices from the Site or any copy thereof;
Attempt to decompile, reverse engineer or hack the Site or to defeat or overcome any security measures, encryption and/or digital rights management technology implemented by Sentinel Global with respect to the Site and/or data transmitted, processed or stored by Sentinel Global; or
Use the Site for any illegal or fraudulent purpose.
Updates to the Site:
Sentinel Global reserves the right to make changes to the Site and these Terms and Conditions of Use at any time without prior notice to you. For this reason, each time you use the Site, you should visit and review the then-current Terms and Conditions of Use that apply to your use of the Site. Your continued use of the Site after any such changes constitutes your acceptance of the new terms and policies.
While we make reasonable efforts to provide accurate information, we may not promptly update or correct the Site even if we are aware that it is inaccurate, outdated or otherwise inappropriate. You agree that we are not responsible for any action that you take or decision you make in reliance on any information contained in the Site.
Site Security:
You may not violate or attempt to violate the security of the Site. Tampering with any portion of the Site, providing untruthful or inaccurate information, misrepresenting your identity, or conducting fraudulent activities on the Site, whether or not through the use of agents, are prohibited and constitute a breach of these Terms and Conditions of Use.
You are prohibited from violating or attempting to violate the security of the Site, including, without limitation, (a) accessing data not intended for you or logging onto a server or an account which you are not authorized to access; (b) disabling, removing, defeating, or avoiding any security device or system, including, without limitation, any password and login functionality used to authenticate users; (c) attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization; (d) attempting to interfere with service to any user, host or network, including, without limitation, via means of submitting a virus to the Site, overloading, “flooding,” “spamming,” “mailbombing” or “crashing;” (e) sending unsolicited email, including promotions and/or advertising of products or services; (f) forging any TCP/IP packet header or any part of the header information in any email or posting; (g) using or attempting to use any engine, software, tool, agent or other device or mechanism (including, without limitation, browsers, spiders, robots, avatars or intelligent agents) to navigate or search the Site other than the search engine and search agents available on the Site and other than generally available third party web browsers; (h) reverse engineering, decompiling or disassembling the underlying software; (i) removing any notices, warnings, labels, annotations or instructions from any portion of the Site or any related material, including, without limitation, any patent, trademark, copyright, or other proprietary notices or license provisions; or (j) otherwise invading the privacy of, obtaining the identity of, or obtaining any personal information about any user of the Site.
Any violations of system or network security, including attempts to intentionally access a computer without authorization or exceed your authorized access level, may result in civil and criminal charges, including but not limited to charges under the Computer Fraud and Abuse Act (18 U.S.C. §1030). Sentinel Global may investigate occurrences that might involve such violations and may involve, and cooperate with, law enforcement authorities in prosecuting users who are involved in such violations. We may, without prior notice or warning of any kind, restrict or terminate the access of any and all users to the Site if we reasonably conclude that such restriction or termination is necessary to prevent, or prevent the further spread, of a virus, security breach or system malfunction.
Ownership of Materials on Site:
The information provided on this Site may not be reproduced, distributed or communicated, in whole or in part, to any third party without the express written consent of Sentinel Global. You may not reproduce (except as noted above), publish, transmit, distribute, display, modify, create derivative works from, sell or participate in any sale of or exploit in any way, in whole or in part, any of the Content, the Site or any related software.
The trade names, trademarks, service marks, trade dress, logos and other indicia of source (collectively, “Marks”) found on the Site and any and all information and Content available through the Site are proprietary to Sentinel Global or its licensors and are protected by intellectual property rights and unfair competition and other laws. The Marks may be registered or unregistered trademarks of Sentinel Global or others. Nothing on the Site shall be interpreted as granting any license or right to use any Marks on the Site. Anything transmitted to the Site by you becomes Sentinel Global’s property and may be used by us for any lawful purpose. Sentinel Global reserves all rights with respect to copyright and trademark ownership of all material on the Site, and will enforce such rights to the full extent of the law.
Unless otherwise noted, all Contents are copyrights, trademarks, trade dress and/or other intellectual property owned, controlled or licensed by Sentinel Global or by third parties who have licensed their materials to Sentinel Global and are protected by U.S. and international copyright laws. The compilation of all Contents on the Site is the exclusive property of Sentinel Global and is also protected by U.S. and international copyright laws.
Cookies:
We may collect certain aggregate and non-personal information when you visit the Site. We may collect this information through “cookie” technology. Cookies are bits of text that can be placed on your computer’s hard drive when you visit certain web sites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all of the Site features.
Regulatory Disclosures:
The content of this Site is for general, informational purposes. Sentinel Global does not make any representation or warranty of any kind, express or implied, as to the accuracy or completeness of the information contained herein. Under no circumstances should the information presented be considered an offer to sell, or a solicitation to buy, any security. Such offer or solicitation may only be made pursuant to the current offering documents for the relevant Sentinel Global Fund (the “Fund”) which may only be provided to accredited investors and qualified purchasers as defined under the Securities Act of 1933 and the Investment Company Act of 1940. While the information provided herein is believed to be accurate and reliable, Sentinel Global, its advisors and employees make no express warranty as to its completeness or accuracy.
Although the Site may include investment-related information, nothing on the Site is a recommendation that you purchase, sell or hold any security or other investment, or that you should pursue any investment strategy, and no information or Content on the Site is to be relied upon for the purpose of making or communicating investment or other decisions. Nothing on the Site is intended to be, and you should not consider anything on the Site to be investment, accounting, tax, legal or other professional advice.
This Site may include information regarding Sentinel Global’s past and present portfolio companies. It should not be assumed that investments made in the future will be comparable in quality or performance to the investments described herein. Further, references to Sentinel Global’s past and present portfolio companies should not be construed as a recommendation of any particular investment or security. The portfolio companies listed should not be assumed to have been profitable. Any transactions listed on the Site are included as representative transactions and are not necessarily reflective of overall performance.
The Site may contain forward-looking statements (including those relating to current and future market conditions and trends in respect thereof) that are not historical facts and are based on current expectations, estimates, projections, opinions and/or beliefs of Sentinel Global. Such statements involve known and unknown risks, uncertainties and other factors, and undue reliance should not be placed thereon. In addition, no representation or warranty is made with respect to the reasonableness of any estimates, forecasts, illustrations, prospects or returns, which should be regarded as illustrative only, or that any profits will be realized. Actual events or results or actual performance of the relevant Fund (or any other entity referred to on the Site) may differ materially from those reflected or contemplated in such forward-looking statements. As a result, investors should not rely on such forward-looking statements in making their investment decisions. No representation or warranty is made as to future performance or such forward-looking statements. Sentinel Global undertakes no obligation to update publicly or revise any information on the Site, whether as a result of new information, future developments or otherwise. Opinions and any other Contents at the Site are subject to change without notice.
Past performance is not indicative of future results; no representation is being made that any investment will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided.
No Warranty; Limitation on Liability:
BY USING THE SITE, YOU EXPRESSLY AGREE THAT SUCH USE IS AT YOUR SOLE RISK. THE SITE AND RELATED SERVICES ARE PROVIDED ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS. NEITHER SENTINEL GLOBAL NOR ANY OF ITS RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, THIRD-PARTY CONTENT PROVIDERS, DESIGNERS, CONTRACTORS, DISTRIBUTORS, MERCHANTS, SPONSORS, LICENSORS OR THE LIKE (COLLECTIVELY, “ASSOCIATES”) WARRANT THAT USE OF THE SITE OR RELATED SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE. NEITHER SENTINEL GLOBAL NOR ITS ASSOCIATES WARRANT THE ACCURACY, INTEGRITY, COMPLETENESS, AVAILABILITY OR TIMELINESS OF THE CONTENT PROVIDED IN THE SITE OR THE MATERIALS OR SERVICES OFFERED IN THE SITE NOW OR IN THE FUTURE. SENTINEL GLOBAL AND ITS ASSOCIATES SPECIFICALLY DISCLAIM ALL WARRANTIES, WHETHER EXPRESSED OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT OF THE SITE, INFORMATION ON THE SITE OR THE RESULTS OBTAINED FROM USE OF THE SITE OR RELATED SERVICES.
UNDER NO CIRCUMSTANCES WILL SENTINEL GLOBAL OR ITS ASSOCIATES BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE OR OTHER INDIRECT DAMAGES, INCLUDING BUT NOT LIMITED TO LOST PROFITS, TRADING LOSSES, UNAUTHORIZED ACCESS, SYSTEMS FAILURE, COMMUNICATIONS LINE FAILURE, INTERNET FAILURE OR DAMAGES THAT RESULT FROM USE OR LOSS OF USE OF THE SITE, CONTENT, INCONVENIENCE OR DELAY. THIS IS TRUE EVEN IF SENTINEL GLOBAL HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES.
Any Content downloaded or otherwise obtained through the Site is done at your own discretion and risk and you are solely responsible for any damage to your computer or other electronic system or loss of data that results from the download of any such Content. The foregoing limitation of liability will apply in any action, whether in contract, tort or any other claim, even if an authorized representative of Sentinel Global has been advised of or should have knowledge of the possibility of such damages.
Third Party Content and Linked Sites:
References on this Site to any names, marks, products or services of third parties who may or may not be affiliated with Sentinel Global, or hypertext links to third party sites or information or Content provided by third parties, are provided solely as a convenience to you and do not in any way constitute or imply our endorsement, sponsorship or recommendation of the third party, its information, materials or services. We are not responsible for the practices or policies of such third parties, nor the Content of any third party sites, and do not make any representations regarding third party materials or services, or the Content or accuracy of any material on such third party sites. Nor have we independently verified the content of any such third party sites. If you decide to link to any such third party sites, you do so entirely at your own risk. You are advised to review the terms of use and privacy policies of any website that you visit.
Termination of Use:
These Terms and Conditions of Use are effective unless and until terminated by either you or Sentinel Global. You may terminate these Terms and Conditions of Use at any time, provided that you discontinue any further use of the Site. We also may terminate these Terms and Conditions of Use, in our sole discretion, at any time and may do so immediately without notice, and accordingly deny you access to the Site. Upon any termination of these Terms and Conditions of Use by either you or us, you must promptly destroy all materials downloaded or otherwise obtained from the Site, as well as all copies of such materials, whether made under these Terms and Conditions of Use or otherwise.
Indemnification:
As a condition of your use of the Site, you agree that you will be solely responsible for, and that you will defend, indemnify and hold Sentinel Global, its parents, subsidiaries and other affiliates and each of their respective officers, directors, agents, employees and representatives harmless from and against any and all claims, demands, liabilities, costs or expenses, including reasonable attorneys’ fees, resulting from your use of the Site or your violation of the Terms of Use. Sentinel Global reserves the right, at its own expense, to assume the exclusive defense and control of any matter for which it is entitled to indemnification, but you must still indemnify Sentinel Global for all liabilities, losses or damages. You agree to provide Sentinel Global with whatever cooperation it reasonably requests.
Representations and Warranties:
You represent and warrant that: (i) you have full authority and all rights necessary to enter into and fully perform all of your obligations pursuant to these Terms and Conditions of Use; (ii) you have not and you will not enter into any agreement or perform any act which might contravene the purposes and/or effects of these Terms and Conditions of Use; and (iii) you will not delete any Content.
Effect on Other Agreements:
Nothing contained in these Terms and Conditions of Use is intended to modify or amend any other written agreement you may have with Sentinel Global (including without limitation any customer agreement, participation agreement or account agreement) (collectively, “Other Agreements”), if any, that may currently be in effect. In the event of any inconsistency between these Terms and Conditions of Use and any Other Agreement, the Other Agreement will govern. Some pages within the Site contain supplemental terms and conditions and additional disclosure and disclaimers, which are in addition to these Terms and Conditions of Use. In the event of a conflict, such supplemental terms and conditions and additional disclosures and disclaimers will govern for those sections or pages.
Privacy:
Your privacy is very important to us. To better protect your rights, please refer to our Privacy Statement, which explains our privacy practices in detail.
Governing Law:
Headings used in these Terms and Conditions of Use are for reference purposes only and in no way define or limit the scope of the section. These Terms and Conditions of Use are governed by the laws of California (except for conflict of law provisions). Any claim related to any dispute arising as a result of the Site or under these Terms and Conditions of Use will be made before a court of competent jurisdiction located in California. If any provision of these Terms and Conditions of Use is held to be unenforceable, such provision will be reformed only to the extent necessary to make it enforceable. The failure of Sentinel Global to act with respect to a breach of these Terms and Conditions of Use by you or others does not constitute a waiver and will not limit Sentinel Global’s rights with respect to such breach or any subsequent breaches.
Arbitration:
By using the Site, you agree that Sentinel Global, at its sole discretion, may require you to submit any disputes arising from the use of the Site, related services or these Terms and Conditions of Use concerning or, including disputes arising from or concerning their interpretation, violation, nullity, invalidity, non-performance or termination, as well as disputes about filling gaps in this contract or its adaptation to newly arisen circumstances, to final and binding arbitration under the International Rules of Arbitration of the American Arbitration Association, by one or more arbitrators appointed in accordance with the said rules. Notwithstanding these rules, however, such proceeding shall be governed by the laws of the state as set forth in the previous section.
EU PRIVACY NOTICE
This EU Privacy Notice4 applies to the extent that EU Data Protection Legislation (as defined below) applies to the processing of personal data by an Authorised Entity (as defined below) or to the extent that a data subject is a resident of the United Kingdom (the “UK”), the European Union (“EU”), or the European Economic Area (“EEA”). If this EU Privacy Notice applies, the data subject has certain rights with respect to such personal data, as outlined below.
For this EU Privacy Notice, “EU Data Protection Legislation” means all applicable legislation and regulations relating to the protection of personal data in force from time to time in the EU, the EEA, the UK, or Luxembourg, including, without limitation: Regulation (EU) 2016/679 (the General Data Protection Regulation) and any national implementing or successor legislation (including any data protection law applicable in Luxembourg such as the law of 1st August 2018 on the organization of the National Commission for Data Protection and the general regime on data protection, as may be amended or replaced), or any other legislation which implements or supplements any other current or future legal act of the European Union concerning the protection and processing of personal data and any national implementing or successor legislation, and including any amendment or re-enactment of the foregoing. The terms “data controller”, “data processor”, “data subject”, “personal data”, and “processing” in this EU Privacy Notice shall be interpreted in accordance with the applicable EU Data Protection Legislation.
Please contact the CCO with any queries arising out of this EU Privacy Notice.
Categories of personal data collected and lawful bases for processing
In connection with offering, forming and operating private investment funds for existing and potential investors, the General Partner acting as data controller on behalf of the Partnership (the “Data Controller”) their affiliates and, in each case, their administrators, legal and other advisors and agents (the “Authorized Entities”) collect, record, store, adapt, and otherwise process and use personal data either relating to existing and potential investors or to their partners, officers, directors, employees, shareholders, ultimate beneficial owners or affiliates or to any other data subjects from the following sources (and all references to “existing investor(s)” or “potential investor(s)” in this EU Privacy Notice shall be to such existing investor(s) or potential investor(s), respectively, and, as applicable, any of these other persons as relate to such existing investor(s) or potential investor(s), respectively):
(a) information received in telephone conversations, in voicemails, through written correspondence, via e-mail, or on subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, “know-your-client”, identification, and verification documentation);
(b) information about transactions with any Authorized Entity or others;
(c) information captured on any Authorized Entity’s website, including registration information and any information captured via “cookies”; and
(d) information from available public sources, including from:
publicly available and accessible directories and sources;
bankruptcy registers;
tax authorities, including those that are based outside the UK and the EEA if an existing or potential investor is subject to tax in another jurisdiction;
4 To be conformed to subscription booklet privacy policies, when finalized.
governmental and competent regulatory authorities to whom any Authorized Entity has regulatory obligations;
credit agencies; and
fraud prevention and detection agencies and organizations.
Any Authorized Entity may process the following categories of personal data:
names, dates of birth and birth place;
contact details and professional addresses (including physical addresses, email addresses and telephone numbers); account data and other information contained in any document provided by investors to the Authorized Entities (whether directly or indirectly);
information regarding your use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history);
risk tolerance, transaction history, investment experience and investment activity;
information regarding an investor’s status under various laws and regulations, including social security number, tax status, income and assets;
accounts and transactions with other institutions;
information regarding an investor’s interest in the Partnership, including ownership percentage, capital commitment, income and losses and any other Confidential Information relating to an investor;
information regarding an investor’s citizenship and location of residence; (i) source of funds used to make the investment in the Partnership; and
anti-money laundering, identification (including passport and drivers’ license) and verification documentation.
Any Authorized Entity may, in certain circumstances, combine personal data it receives from an existing or potential investor with information that it collects from, or about such potential investor. This will include information collected in an online or offline context.
The Authorized Entities may, as the case may be, process the personal data as data processors (when processing the personal data on behalf and upon instructions of the Data Controller), or as distinct data controllers (when processing the personal data for their own purposes, namely fulfilling their own legal obligations).
There is a need to process personal data for the purposes set out in this EU Privacy Notice as a matter of contractual necessity under or in connection with the Partnership Agreement and associated Partnership documentation, and in the legitimate interests of the Authorized Entities (orthose of a third party) to operate their respective businesses. From time to time, an Authorized Entity may need to process the personal data on other legal bases, including: with consent; to comply with a legal obligation; if it is necessary to protect the vital interests of an existing investor, a potential investor or other data subjects; or if it is necessary for a task carried out in the public interest.
The legitimate interests referred to above are the processing purposes described in point (f) and (g) of the below section, the provision of the proof, in the event of a dispute, of a transaction or any commercial communication as well as in connection with any proposed purchase, merger or acquisition of any part of the Partnership’s business; and exercising the business of the Partnership in accordance with reasonable market standards.
A failure to provide the personal data requested to fulfil the purposes described in this EU Privacy Notice may result in the applicable Authorized Entities being unable to provide the services in connection with the Partnership Agreement and/or the Subscription Agreement.
Purpose of processing
The applicable Authorized Entities process the personal data for the following purposes (and in respect of paragraphs (c), (d) and (f), below in the legitimate interests of the Authorized Entities):
(a) The performance of obligations under the Partnership Agreement and/or the Subscription Agreement (and all applicable anti-money laundering, “know-your-client” and other related laws and regulations), including in assessing suitability of potential investors in the Partnership.
(b) The administrative processes (and related communication) carried out between the Authorized Entities in preparing for the admission of investors to the Partnership.
(c) Ongoing communication with existing investors and potential investors and their respective representatives, advisors and agents, (including the negotiation, preparation and signature of documentation), including during the process of admitting potential investors to the Partnership.
(d) The ongoing administrative, accounting, reporting and other processes and communication required to operate the business of the Partnership in accordance with the Partnership Agreement and other applicable documentation between the parties.
(e) Any legal or regulatory requirement.
(f) Keeping existing and potential investors informed about the business of the General Partner and its affiliates generally, including offering opportunities to make investments other than to the Partnership.
(g) Any other purpose that has been notified, or has been agreed, in writing.
The Authorized Entities monitor communications where the law requires them to do so to comply with regulatory rules and practices and, where permitted to do so, to protect their respective businesses and the security of their respective systems.
Sharing and transfers of personal data
In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where permitted by EU Data Protection Legislation, to other service providers, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfil the purposes described in this EU Privacy Notice. In addition, any Authorized Entity may share personal data with regulatory bodies having competent jurisdiction over them, as well as with the tax authorities, auditors and tax advisers (where necessary or required by law).
Any Authorized Entity may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfil the purposes described in this EU Privacy Notice and in accordance with applicable law, including where such transfer is a matter of contractual necessity to enter into, perform and administer the Subscription Agreement and Partnership Agreement, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers and in order to get copies of such safeguards as the case may be, please contact the General Partner. For the purposes of this EU Privacy Notice, “Non
Equivalent Country” shall mean a country or territory other than (i) a member state of the EEA; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU Data Protection Legislation to ensure an adequate level of protection for personal data.
Retention and security of personal data
The General Partner and its affiliates consider the protection of personal data to be a sound business practice, and to that end, employ appropriate technical and organizational measures, including robust physical, electronic and procedural safeguards to protect personal data in their possession or under their control.
Personal data may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations, or where longer, such longer period as is required by applicable legal or regulatory obligations. Personal data will be retained throughout the life cycle of any investment in the Partnership. However, some personal data will be retained after a data subject ceases to be an investor in the Partnership, subject to statutory limitation periods.
Data Subject Rights
It is acknowledged that, subject to applicable EU Data Protection Legislation, the data subjects to which personal data relates, have certain rights under EU Data Protection Legislation: to obtain information about, or (where applicable) withdraw any consent given in relation to, the processing of their personal data; to access and receive a copy of their personal data; to request rectification of their personal data; to request erasure of their personal data; to exercise their right to data portability; to object to the processing of personal data for marketing purposes and the right not to be subject to automated decision-making. Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, erasure of the personal data requested to fulfil the purposes described in this EU Privacy Notice, may result in the inability to provide the services required pursuant to this Subscription Agreement and the Partnership Agreement.
In case the data subject to whom personal data relate disagrees with the way in which their personal data is being processed in relation to this Subscription Agreement or the Partnership Agreement, the data subject has the right to object to this processing of personal data and request restriction of the processing. The data subject may also lodge a complaint with the competent data protection supervisory authority in the relevant jurisdiction.
The data subject may raise any request relating to the processing of his or her personal data with the General Partner.
The data subjects are also informed of the existence of their right to lodge a complaint with any competent data protection supervisory authority in their EU Member State of residence.