WE ARE PROVIDING THIS NOTICE IN ORDER TO INFORM YOU OF OUR PRIVACY POLICIES AND PRACTICES WITH RESPECT TO THE COLLECTION, USE AND SHARING OF YOUR NONPUBLIC PERSONAL INFORMATION.
Post: 111 East Sego Lily Drive, Suite 400, Sandy, Utah 84070.
TYPES OF INFORMATION
In connection with the operation of our business, including the formation, operation and ongoing activities of our private investment funds, when you visit our website or our premises, or when you are one of our business partners, we may collect, use, process and maintain the following nonpublic information about you:
Contact information such as first name, last name, telephone number, email address, residency and physical or mailing address;
Personal information such as date of birth, job position and title;
Government issued identifiers such as social security number, tax ID number, passport number, national insurance number or driving license number (and copies of supporting documents of the same);
Bank details, financial account information, credit or debit card numbers (including security codes to access such information), beneficial ownership (if applicable) and the source of the funds for your investment;
Financial information such as credit history or credit checks; and
Any other information deemed reasonably necessary to accomplish our investment objectives or to comply with applicable reporting or regulatory requirements.
Nonpublic information shall not include information that is lawfully obtained from publicly available information, or from federal, state or local government records lawfully made available to the general public. If your personal data changes, please let us know by contacting firstname.lastname@example.org at the earliest opportunity so that our records can be updated. Any delay in notification is likely to delay our ability to communicate with you and administer your investments. We expressly disclaim any liability for losses created by your failure to update such information.
SOURCES OF INFORMATION
We may obtain personal information about you from the following sources:
Subscription agreements, investor questionnaires or other forms submitted to us;
Contracts you negotiate or enter into with us;
Responses to diligence requests, such as for “know your customer” processes;
Transactions with us, our affiliates or others;
Meetings, electronic communications or telephone conversations with you; and
Any other communications from you or your representatives.
RETENTION OF INFORMATION
Regardless of whether your investments with us have terminated (but not in contravention of any applicable laws), we may retain your personal data that you provide to us until the liquidation of the applicable partnership, and a subsequent period of up to ten (10) years thereafter where necessary to comply with applicable laws and regulations or to establish, exercise or defend actual or potential legal claims, subject to the applicable statutes of limitation, unless a longer period is required by applicable laws and regulations. In any case, your personal data will not be held for longer than necessary with regard to the purposes described in any subscription document and any privacy notice, subject always to applicable legal minimum retention periods.
Even after this time period, we may store your information in an aggregated and anonymized format for an unlimited amount of time.
We generally process personal data in reliance upon the legal bases and for the purposes set out in the chart below, but may do so for any additional purposes which we deem reasonably necessary (and based upon sufficient legal bases) in order to achieve Bridge’s objectives.
Documents or files containing sensitive client or investor information may only be accessed by:
Persons who are required to access such information in order to complete their job,
Persons who are required to provide such information to a judicial or regulatory body,
Persons in the management, legal, compliance, and human resources departments who need such information to analyze or resolve a dispute, and
Other persons specifically permitted by the Chief Compliance Officer.
We maintain physical, electronic and procedural safeguards that we believe are reasonably designed to guard your nonpublic personal information while it is within our control. Where such information is shared with nonaffiliated third parties (discussed below), we contractually require such persons to maintain appropriate confidentiality and privacy measures with respect to nonpublic information.
DISCLOSURE OF NONPUBLIC INFORMATION TO THIRD PARTIES
We may disclose nonpublic personal information about you to nonaffiliated third parties as permitted by law and in accordance with the agreements governing your investments, including but not limited to the following recipients:
Fund administrators and service portal providers in the United States, the Cayman Islands, Europe, and any other applicable jurisdiction;
Other investors (including ultimate beneficial owners) in order to facilitate communications between investors in certain circumstances or to otherwise comply with legal or contractual obligations;
Prospective lenders to the extent required by such lender’s onboarding, “know your customer”, sanctions or AML policies;
Competent authorities, e.g. tax authorities, courts, regulatory bodies and any affiliated service providers, in order to comply with legal obligations and for licensing or other regulatory compliance purposes;
Placement agents, transfer agents, brokerage firms and other similar professionals, in connection with any investment or disposition; and
Other recipients, on a need-to-know basis, in order to perform their obligations towards Bridge and its funds, so long as such third parties are under a contractual obligation to treat such information confidentially.
Our service providers process personal data on our behalf, thus acting as data processors (the “Processors”).
Further entities (also data processors) may process your personal data on our behalf and such service providers, in particular their affiliates and own service providers such as auditors, legal, financial or technical advisors.
The Processors act as data processor on our behalf and, in certain circumstances, as data controller, in particular for managing, testing, securing and optimising their systems and compliance with their own legal obligations in accordance with applicable laws and regulations (such as anti-money laundering identification) and/or order of competent jurisdiction. Where they act as a data controller, they shall remain solely liable with respect to such processing and further details about their processing of your personal data may be found within their respective privacy policies.
In order to comply with FATCA and CRS, your personal data may also be processed and transferred to a local tax authority who may transfer such data to the competent foreign tax authorities, as well as to service providers for the purpose of effecting such reporting on our behalf.
Where under an obligation to do so by law, we will disclose your 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 notify you in advance about the details of such disclosures.
You have certain rights in relation to the personal data we hold about you. To exercise any of your rights, please direct all inquiries, complaints or comments to: email@example.com. Please note that we will require you to verify you identity before responding to any requests to exercise your rights by providing proof of identity, such as a copy of a passport and/or driving licence and proof of address (such as a recent bank or building society statements (no more than three months old). We will respond without undue delay and at least within one month (although this may be extended in certain circumstances).
Data access rights. In certain circumstances, you have the right to access and receive a copy of information we hold about you, to rectify any personal information held about you that is inaccurate and to request the deletion, portability or suspension of access to such information. Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you.
Complaints. In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at firstname.lastname@example.org and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with any supervisory authority.
LAST UPDATE: APRIL 1, 2022