PRIVACY POLICY
Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our clients. We have a policy of protecting the confidentiality and security of information we collect about you. We are providing you this notice (the “Privacy Notice”) to help you better understand why and how we collect certain personal information, the care with which we treat that information, and how we use that information.
Information We Collect: In connection with forming and operating our private investment funds (or “funds”) and/or performing asset management services for our investors and clients, we collect and maintain the following categories of non-public information:
• Contact information: name, address, email, telephone number;
• Identification information: signature, date of birth, place of birth, citizenship, location of residence, social security number, taxpayer identification number, driver’s license, passport, other government identification and numbers;
• Background information: information required to perform, or revealed in, know-your-customer (KYC) and anti- money laundering (AML) due diligence, investor accreditation and consents;
• Financial information: assets, income, net worth, amounts and types of investments, risk tolerance, capital account balances, capital commitments, capital contributions, account data, other investment participation information, funds transfer information, beneficiaries, positions, percentages of fund, share or option numbers and values, vesting information, investment history, transaction information, tax status and information;
• Investment information: information about your interest in the relevant Investment, including ownership percentage, capital investment, income and losses; and
• Technical or account information: electronic device and usage information (for example, from cookies and similar technology), registration information and online account data.
Sources of Non-Public Information: We collect and maintain non-public personal information from the following sources:
• Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via email and other electronic communications, or on subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification and verification documentation),
• Information about your transactions with us or others,
• Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms and any information captured via “cookies.”
Purposes for Collecting Personal Information: We may process or disclose the personal information we collect about you for the following commercial or business purposes:
• The performance of our contractual and legal obligations (including applicable anti-money laundering, KYC and other related laws and regulations) in assessing your suitability for investing in a fund.
• 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 relevant fund(s) and execution of relate documentation (e.g., the subscription agreement).
• The ongoing administrative, accounting, reporting and other processes and communication required to operate our business and/or the relevant fund.
• To administer, manage and set up your investor account(s) to allow you to purchase your holding (of shares) in the relevant fund(s).
• To facilitate the execution, continuation or termination of the contractual relationship between you and the Partnership and/or the relevant fund (as applicable).
• To facilitate the transfer of funds, and administering and facilitating any other transaction, between you and the relevant fund.
• To audit and perform verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance.
• To maintain the safety, security and integrity of our products and services, databases, technology assets and business, including to detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity.
• To enable any actual or proposed assignee or transferee of the fund(s), to evaluate proposed transactions.
• To facilitate business asset transactions involving the relevant fund.
• To fulfil any legal or regulatory requirement.
• Keeping investors informed about our business generally, including offering opportunities to make investments other than in the relevant fund.
• Any other purpose that has been notified, or has been agreed, in writing.
Disclosure of Information: We may disclose any of the categories of personal information in the “Information We Collect” section above, in connection with fund and/or advised account transactions, partner financial or other reports, or for other purposes relating to raising and managing our funds and overseeing their investments to third parties and our financial service or non-financial service affiliates, including:
• Financial service providers, such as broker-dealers, custodians, banks, lenders, and others used to facilitate transactions for investors and clients or our private funds,
• Other service providers to the general partner, the manager, their affiliates and/or our private funds, such as legal, consulting, administration, accounting, auditing or tax preparation services and placement agents,
• Portfolio companies, co-investors in portfolio companies and their respective advisors, if requested in connection with an investment, and
• Other private fund partners, parallel fund partners or investors in alternative investment vehicles in connection with closing documentation, investor reports, financial statements or other investor communications.
We may also disclose any of the categories of personal information in the “Information We Collect” section above as permitted by law or regulation and to affiliates and service providers, including, but not limited to, administrators, lenders, banks, auditors, accountants, law firms, tax advisors, and governmental agencies or pursuant to legal process and self-regulatory organizations, consultants and placement agents.
Mobile information shared with the use of the Global Relay application in connection with any business performed for you by PeakAlts will not be shared with third parties/affiliates for marketing/promotional purposes. PeakAlts will not send you text messages without your prior consent, and will include clear out-out procedures so that you can stop receiving such communications at any time. Notwithstanding anything else in these Terms of Use, to the extent text messaging originator opt-in / opt-out data and consents are collected, such information will be solely used by PeakAlts’ third-party providers to manage the text message opt-in / opt-out procedures.
Former Investors and Clients: We maintain non-public personal information of our former investors and clients and apply the same policies that apply to current investors and clients.
Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards, which seek to protect your non-public personal information in our possession or under our control.
Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time. In the event that we update this Privacy Notice, we will make an updated draft available to you on this site. The examples contained within this notice are illustrations only and are not intended to be exhaustive. This notice is intended to comply with the privacy provisions of Regulation S-P of the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that apply to you, including as set forth in our additional privacy notices.
Contact Us: If you have any questions or concerns about this Privacy Notice, wish to access this Privacy Notice in an alternative format, or wish to exercise any rights, submit requests, or appeal any of our decisions in connection with this Privacy Notice (each, a “Communication”), please contact us at IR@peakalts.com.
We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information or your investor portal access credentials, if applicable in order to verify your Communication.
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