California Privacy Policy

Last revised / Effective Date: August 2023:

The disclosures in this California Privacy Policy supplement the US Privacy Policy linked at the bottom of this website (the “US Privacy Policy”) with respect to specific rights granted under California law, including the California Consumer Privacy Act (the “CCPA”), to California residents, including those we interact with in our business-to-business relationships, and provides information regarding how such California residents can exercise their privacy rights. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Please be aware that certain exceptions to your California privacy rights may apply to your personal information, such as personal information subject to the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”).

Categories of personal information we collect

We collect personal information from you, our service providers, and government entities. The categories of personal information we collect may depend on how we interact with you. We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:

Identifiers, such as 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);

Other customer records, such as 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 tax status, income, and assets);

Protected classification characteristics under California or federal law, such as date of birth, citizenship. and birthplace;

Commercial information, such as 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, and information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, and source of funds used to make the investment in the applicable fund(s);

Internet or other electronic network activity information, such as information regarding your 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; and

Sensitive personal information, such as Social Security number, passport number, driver’s license or state identification number, and account log-in. Please note that we do not use your sensitive personal information to infer characteristics about you.

Within the last twelve (12) months, we have disclosed each of the categories of personal information collected with affiliates and third-party service providers as set forth in the US Privacy Policy, and we collect personal information from the sources as set forth in the US Privacy Policy. We may also disclosure your personal information to other third parties, such as advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers.

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;
• 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 the funds 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;

• auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
• preventing, detecting, and investigating security incidents,
• resisting against malicious, deceptive, fraudulent, or illegal activity;
• presenting short-term nonpersonalized advertising;
• verifying or maintaining the quality of our services; and
• complying with U.S., state, local and non-U.S. laws, rules, and regulations.

We do not sell any of the personal information we collect about you to third parties.  We do not share any of the personal information we collect about you to third parties for cross context behavioral advertising purposes.  

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, federal and non-U.S. laws, rules and regulations.

 Correction rights

You have the right to request that we correct any of your personal information that we maintain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and federal law.

Disclosure and access rights

You have the right to request that we disclose to you certain information regarding our collection, use, disclosure, sharing, 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 share 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 and the specific business or commercial purpose for disclosing your personal information.

Opt-out rights

 You have the right to opt-you out of the sale or sharing of your personal information. However, we do not sell or share this personal information, including the personal information of those under sixteen years of age.

Limit use and disclosure of sensitive personal information rights

You have the right to request that we limit our use and disclosure of your sensitive personal information. However, we only use your sensitive personal information for the purposes permitted under applicable law, and therefore any action to exercise this right will not affect our uses and disclosures of sensitive personal information.

No discrimination or retaliation

We will not discriminate or retaliate 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 California Privacy Policy in an alternative format, please submit a request using any of the methods set forth below.

Call us using the following number: (703) 705-2017 ext 705.

Email us at the following address: dataprivacy@clarendoncap.com

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.

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 Allison Miyake, Chief Compliance Officer (amiyake@clarendoncap.com) with any questions about this notice.

Retention

We will retain your personal information until it is no longer necessary for the purposes for which it was collected. Please note that we may retain all, or a portion, of your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another business purpose.

Opt-Out Preference Signals

Many Internet browsers may make available in their settings the ability for users to send opt-out preference signals to the websites that they use, such as Do Not Track (“DNT”) and Global Privacy Control (“GPC”). The Clarendon Site currently does not respond to DNT or GPC signals.

Changes to this notice

Clarendon reserves the right in our sole discretion to modify or amend this California Privacy Policy or any other terms associated with the use of the Clarendon Site in any way at any time and without prior notice to you unless such notice of material changes is required by law. Any such changes shall become part of this California Privacy Policy and are effective upon posting on the Clarendon Site. You should review this California Privacy Policy periodically for changes applicable to you. By accessing the Clarendon Site subsequent to any such modification, you are deemed to have agreed to all terms of this California Privacy Policy as modified or amended.