PRIVACY POLICY SUPPLEMENT FOR RESIDENTS OF THE EEA AND INVESTORS IN CAYMAN ISLAND ENTITIES

LAST UPDATED: APRIL 1, 2024

Notice for EEA Investors

As required under the General Data Protection Regulation 2016/679 (as amended, the “GDPR”), if you are resident in the European Economic Area (“EEA”) or if you are not a natural person and your shareholders, directors, officers, members, agents, designees and/or beneficiaries (“Underlying Data Subjects”) are resident in the EEA or have invested into an entity organized under the laws of the EEA (together or as appropriate in the circumstances, an “ERA Investor”), we are providing the notice as set out in the Appendix hereto in order to inform you of our privacy policies and practices with respect to the processing of personal data for EEA Investors. For the avoidance of doubt, the EEA includes the member states of the European Union plus Iceland, Norway, and Liechtenstein.

Notice for all Investors in Cayman Island Entities – Cayman Islands Data Protection

For each entity organized under the laws of the Cayman Islands through which you may have invested (regardless of your nationality or location of residence), the applicable entity also has obligations to you under applicable data protection laws. The Data Protection Act (as amended) of the Cayman Islands (as amended, the “DPL”) provides similar rights to investors and requires data controllers and processors to implement specific requirements similar to those applicable under the GDPR. Therefore, if you have invested through an entity organized under the laws of the Cayman Islands, please consider yourself an EEA Investor (albeit in a Cayman Islands only context) and note that you will have rights in relation to personal data as set out below. For the avoidance of doubt, considering yourself an EEA Investor (in a Cayman Islands only context) by no means seeks to imply that you have rights under the GDPR that are not otherwise applicable to you based on your nationality or location of residence. For any investor in an entity organized under the laws of the Cayman Islands, please note that you may raise complaints with the Cayman Islands Ombudsman via https://ombudsman.ky/data-protection.

Appendix to the Privacy Policy Supplement​

  1. In this Appendix to the Privacy Policy “Data Protection Law(s)” means any applicable law, statute, declaration, decree, directive, legislative enactment, order, ordinance, regulation, rule or other binding instrument in relation to the processing of personal data (including those implementing the GDPR or the DPL) as such legislation and guidance may be amended, replaced or repealed from time to time. The terms “personal data,” “data subject,” “data controller” and “process” shall have the meanings given to them in the applicable Data Protection Act.
  2. The general partner of the applicable partnership (the “General Partner”), the investment manager of the applicable partnership (the “Investment Manager”), their respective affiliates or any of their respective directors, officers, managers, employees, partners, members, shareholders, affiliates, advisers, attorneys-in-fact, delegates, representatives or agents (collectively, the “Bridge Persons”, and each, a “Bridge Person”) shall comply with all applicable Data Protection Laws when processing personal data in connection with an investment in a partnership.
  3. To the extent the investor is an individual, the investor is informed and acknowledges that the documentation and information the investor provides in relation to any subscription document to a partnership (each, a “Subscription Document”) (and in the course of its investment in a partnership) will be processed in connection with such Subscription Document and any personal data will be processed in accordance with the privacy notice set out in Exhibit A hereto (the “Privacy Notice”).
  4. To the extent that the investor is a non-natural person and shares personal data about natural persons relating to such investor with a Bridge Person (e.g. information relating to its representatives, contact persons, directors, trustees, settlors and beneficial owners), the investor shall ensure such disclosure of personal data is in compliance with all Data Protection Laws and that there is no prohibition or restriction which would:
    1. prevent or restrict it from disclosing or transferring the personal data to a Bridge Person;
    2. prevent or restrict a Bridge Person from disclosing or transferring personal data to its affiliates, subcontractors, vendors, credit reference agencies and competent authorities pursuant to its obligations under the applicable Subscription Document;
    3. prevent or restrict a Bridge Person, its delegates, affiliates, subcontractors, vendors, credit references agencies and competent authorities from processing the personal data for the purposes set out in the applicable Subscription Document; and
    4. ensure that it has provided the Privacy Notice informing the data subjects of a Bridge Person’s processing of such personal data as described in the Privacy Notice to any applicable data subject, including notifying data subjects of any updates to the Privacy Notice. Where required, the investor shall procure the necessary consents from data subjects to the processing of personal data as described in the Privacy Notice or the applicable Subscription Document.
  5. The investor agrees that it will (in addition to, and without affecting, any other rights or remedies that the applicable partnership and a Bridge Person may have whether under statute, common law or otherwise) indemnify and hold harmless a Bridge Person, on demand from and against all claims, liabilities, costs, expenses, loss or damage incurred by a Bridge Person (including consequential losses, loss of profit and loss of reputation and all interest, penalties and legal and other professional costs and expenses) arising directly or indirectly from (i) a breach of the applicable Subscription Document or applicable Data Protection Laws by such investor or (ii) enforcement by a Bridge Person of any rights under it.

​Exhibit A to the Privacy Policy Supplement
Privacy Notice

PURPOSE

This Privacy Notice details how the General Partner and/or any Investment Manager (“we,” or “us”) processes the personal data received about you (including where you are acting on behalf of an EEA Investor (i.e. as the contact person or ultimate beneficial owner, director, member or officer etc. of an institutional investor)) in relation to an investment in a partnership, how we process it and your rights and obligations in relation to your personal data during the course of your investment.

DATA CONTROLLER CONTACT DETAILS

Each General Partner is a company formed in Delaware with its principal place of business at 111 East Sego Lily Drive, Suite 400, Salt Lake City, Utah 84070 and contact email address [email protected].

Each Investment Manager is a limited liability company formed in Delaware with its registered office at The Corporation Trust Company, 1209 Orange Street, in the City of Wilmington, County of New Castle, State of Delaware 19801 and contact email address [email protected].

We are the data controllers for the purposes of the GDPR and other applicable data protection laws (the “Data Controllers”).

For all data privacy inquiries and any questions or concerns you have about this Privacy Notice, please contact Bridge Investor Relations (the “Data Privacy Contact”) at:

E-mail:         [email protected]

Phone:          877-866-4540

Post:             111 East Sego Lily Drive, Suite 400, Salt Lake City, Utah 84070.

​WHAT PERSONAL DATA IS PROCESSED?

For the purposes of this Privacy Notice, the “EEA Investor” is the person or entity that is making an investment in a partnership domiciled in the Cayman Islands.

Where the EEA Investor is an individual, you will be providing your personal data by completing the subscription forms and associated documentation and by registering for and accessing our investor portal or by communicating with us by phone, e-mail or otherwise.

 Where you are acting on behalf of an EEA Investor (i.e. you are a contact person, ultimate beneficial owner director, officer etc. of an institutional investor), the EEA Investor may provide your personal data to us by completing the subscription forms and associated documentation (including by way of satisfying applicable AML/KYC checks) and by accessing our investor portal or by the EEA Investor or the relevant Underlying Data Subject communicating with us by phone, e-mail or otherwise.

In addition, personal data may also be collected through publicly accessible sources including company and trade registers in relevant jurisdictions or other third-party data sources such as U.S., Cayman, European, national or foreign authorities (e.g. sanctions lists) or screening databases such as Thomson Reuters World-Check.

In any of the above cases, we process the following personal data about you or the individuals connected with you as an investor:

  • Contact information such as first name, last name, telephone number, email address, and physical/mailing address;
  • Personal information such as date of birth, job position/title, signature, tax identifiers, credit history, correspondence records, source of wealth, and source of funds;
  • Government issued identifiers such as passport number, national insurance number or driving licence number (and copies of supporting documents of the same);
  • Bank details, beneficial ownership in the EEA Investor (if applicable) and the source of the funds for your investment; and
  • Financial information such as credit history or credit checks.

If the personal data referable to you or an applicable Underlying Data Subject changes, please let us know by contacting [email protected] 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 investment in a partnership. Any losses created thereby shall not be our responsibility.

WHAT IS THE PURPOSE FOR PROCESSING THE PERSONAL DATA?

​As a general rule, we will not process special categories of personal data such as your racial or ethnic origin, religious beliefs, health data or information about criminal convictions. Where we do so, in exceptional circumstances, we may process this data where:

  • We have your explicit consent: for such information processing;
  • This is necessary to deal with legal claims: for example, involving court proceedings;
  • This is necessary for substantial public interest: for example, to prevent or detect unlawful acts.

HOW WILL PERSONAL DATA BE SHARED?

  1. Disclosures and transfers with third parties
    • We share your personal data with selected third parties. The categories of recipients include:​
      • Competent authorities, e.g. tax authorities, courts, regulatory bodies and any affiliated service providers, in order to comply with our legal obligations and for licensing or other regulatory compliance purposes;
      • Third party administrators and service providers located in Europe, and any other applicable jurisdiction, for the purpose of transfer agent services and fund administration;
      • Third party service providers in order to perform or fulfil our legal obligations, for example, sanctions laws and to fulfil our KYC and AML obligations;
      • Placement agents, transfer agents, brokerage firms and other similar professionals, in connection with any investment or disposition;
      • Existing investors in the partnership to facilitate communication between investors in certain circumstances;
      • Other EEA Investors, including ultimate beneficial owners, for the purpose of fulfilling our obligations; and
      • Lenders, to enable lenders to perform KYC for the purpose of providing borrowing facilities.
    • 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.
    • With respect to FATCA and/or CRS, please note that (i) your personal data may be processed and transferred to a local tax authority who may transfer such data to the competent foreign tax authorities, only for the purposes provided for in the FATCA and CRS rules as well as to service providers for the purpose of effecting the reporting on our behalf and (ii) for each information request sent to the EEA Investor, addressing such information requests as are mandatory (including where failure to respond may result in incorrect or double reporting). We also use iCapital to provide our investor portal.
    • Where we are 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.
  2. Safeguarding personal data
    • Where we transfer your personal data to group entities that are outside the European Economic Area (the “EEA”), this will be done under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC. You are informed that third-party service providers and their affiliates may notably be located in the United States and in India.
    • Where we transfer your personal data to our third-party service providers and partners outside the EEA, these recipients are required to execute the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses).
    • Please contact [email protected] should you wish to receive a copy of these standard data protection clauses.

YOUR RIGHTS

You have certain rights in relation to the personal data we hold about you, which we detail below.

Please note that we will require you (or any applicable Underlying Data Subject) to verify identity before responding to any requests to exercise your rights by providing proof of identity, such as a copy of a passport/driving licence and proof of address (such as a recent bank or building society statements (no more than three months’ old)).

We must respond to a request by you to exercise those rights without undue delay and at least within one month, (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please direct all queries, complaints and comments: [email protected].

  • 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 or access to personal information held about you. 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. You can exercise your rights by contacting us at [email protected].
  • 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 [email protected] 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.

FOR HOW LONG IS PERSONAL DATA RETAINED?

We will 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 the Subscription Document and the Privacy Notice, subject always to applicable legal minimum retention periods.

After you have terminated your investment in a partnership, we may store your information in an aggregated and anonymised format.

CHANGES TO THIS POLICY

This Privacy Notice may be amended from time to time, at our discretion. You will be notified of any changes to these terms.