WEBSITE PRIVACY AND COOKIE POLICY

Last updated October 22, 2020

Rockhill Management L.L.C., together with its subsidiaries and affiliates (“Rockhill”, “we”, “us”, or “our”) are committed to protecting your personal information. This website privacy and cookie policy (“Policy”) applies to your use of our public websites (collectively, the “Site”) and inquiries about or use of services associated with our business available through our Site (the “Services”). The privacy of your personal information is important to us at Rockhill.

To provide you with Services you may request, it may be necessary for us to possess some personal information of yours. Similarly, without some of that information, we cannot inform you about the Services we have available or that you may request. This Policy explains our personal information policies and practices. It includes, but is not limited to, explanations of the types of information we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, your rights regarding your personal information, and the way to contact us to exercise those rights.

Amendments to this Policy will be posted to the Site and/or Services and will be effective when posted.

  1. Your Acceptance Through Use
  2. Types and Use of Information We Collect
  3. Sources for Collected Personal Information
  4. Sharing Your Personal Information
  5. Restricted Use Regarding Minors
  6. Lawful Basis
  7. Data Storage and Retention
  8. Protection of Personal Information
  9. Our Site and Use of Cookies
  10. Automated Decision Making
  11. Personal Information Rights for EU residents
  12. Personal Information Rights for California Residents
  13. Transfers of Personal Information
  14. Questions or Concerns and Exercising Your Data Subject Rights
  15. Verifying Your Identity

 


 
 
 
 

1.YOUR ACCEPTANCE THROUGH USE

This Policy describes how Rockhill collects, uses, and discloses certain personal information obtained through this Site. Please note that, to the extent permitted by applicable law, your use of this Site signifies your understanding and acceptance of the terms of this Policy. This Policy is incorporated into, and is part of, the Terms and Conditions, which govern your use of the Site in general.

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2. TYPES AND USE OF INFORMATION WE COLLECT

This section explains the personal information that may be collected when using our Site, and the other information we may receive from other sources.

Examples of information we may collect on our Site include:

  • Contact details, such as your full name, e-mail address, and other information you provide in connection with a general inquiry
  • Usernames and passwords (for investor portal)
  • Cookies and site usage information
  • Feedback submitted to Rockhill for support
  • Interests and communication preferences

If you provide us with personal information to fulfill a Service, we may collect, process, or disclose your personal information for a variety of purposes including:

  • To open an account(s) for you
  • For our everyday business purposes such as to process your transactions, and maintain your account(s)
  • To process a transaction for your account, or otherwise in furtherance of our business
  • To perform obligations under the subscription agreement (including all applicable anti-money laundering, know your customer and other related laws, rules, and regulations), including in connection with assessing suitability of potential investors
  • For our legitimate interest or those of a third party (including certain information about your transactions, experiences, and creditworthiness);
  • For administrative processes (and related communications) carried out in preparing for the admission of investors
  • For ongoing communication with potential investors, their representatives, advisors, and agents, (including the negotiation, preparation and execution of documentation) during the process of admitting potential investors
  • For ongoing administrative, accounting, reporting and other processes and communication required to operate our business in accordance with the agreements and other applicable documentation among the parties
  • To keep investors informed about the business of the general partner of the applicable Fund and its affiliates generally, including offering opportunities to make additional investments
  • To the extent necessary to perform a contract with you
  • To the extent necessary to comply with any applicable legal or regulatory requirement to which we are subject
  • For any other purpose that has been notified or has been agreed between you and us

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3. SOURCES FOR COLLECTED PERSONAL INFORMATION

Rockhill does not collect personal information about individual users that visit the Site except:

  • when such personal information is provided to us on a voluntary basis.
  • to monitor traffic to the Site
  • to determine the future direction of the Site including any necessary technical upgrades
  • to contact you regarding future services.

Additionally, we may collect information on our website from cookies, web beacons and similar interactions when you or your devices access our online platforms or websites.

You may, however, provide your personal information to Rockhill to fulfill a Service (e.g. subscription to our fund(s)). In such cases, the information we collect about you (such as your name, address, social security number, assets and income) are from:

  • our discussions with you
  • account, subscription and qualification documents that you may deliver to us
  • While providing advisory services for you.

We may receive information about you from other sources and combine that information with the personal information we collect directly from you. For example, we may obtain personal information from:

  • The organization you use to pay us in order to correct our records
  • From credit agencies, fraud prevention and detection agencies/organizations
  • Transaction counterparties
  • Publicly available and accessible directories and sources
  • Bankruptcy registers and tax authorities (including those that are based outside of the territory where you are located)
  • Governmental authorities to whom we have legal or regulatory obligations.

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4. SHARING YOUR PERSONAL INFORMATION

Your personal information may be combined with information we receive from other sources, or it may be provided to other organizations we work with. This section details that sharing of your personal information. We do not disclose your non-public personal information to third parties other than as described below.

Sharing Personal Information with Third Parties

We do not and will not sell your personal information. If we share your personal information with third parties performing services for us, or acting on our behalf, we will not allow them to use your information for other purposes, and we will contractually require them to protect your information.

We may share your personal information with our affiliates, business partners, and other third parties. We may do so for the purposes of operating our business, delivering and improving the financial services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business.

We also share personal information for a variety of additional purposes including, but not limited to:

  • For our everyday business purposes, such as to process your transactions, maintain your accounts(s), or respond to court orders and legal investigations; or
  • For our affiliates’ everyday business purposes, including certain information about your transactions, experiences, and creditworthiness.

Rockhill does not sell or disclose to nonaffiliated third parties any nonpublic personal information about its clients, except as permitted by law or as is necessary to service client accounts. To the fullest extent permitted by law, these nonaffiliated third parties are required to protect the confidentiality and security of this information and to use it only for its intended purpose.

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5. RESTRICTED USE REGARDING MINORS

This Site is not intended or designed to be used by children under the age of 13. We do not collect personal information from any person we know to be under the age of 13 and instruct children under 13 not to send us any information.

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6. LAWFUL BASIS

There is a need to process personal information for the purposes set out in this Policy as a matter of contractual necessity under or in connection with the applicable agreement, and in our legitimate interests to operate our respective businesses. From time to time, we may need to process personal information on another legal basis, including, among others: to comply with a legal obligation; if it is necessary to protect the vital interests of an investor or other data subject; or if it is necessary for a task carried out in the public interest. We do not generally rely on your consent to process your personal information. For the purposes listed above, we generally expect to rely on contractual necessity and our legitimate interests or the legitimate interest of a third-party.

Unless otherwise indicated, you should assume that we require personal information for business or compliance purposes. A failure to provide the personal information requested to fulfill the purposes described in this Policy may result in us being unable to provide the services in connection with the terms of your subscription agreement.

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7. DATA STORAGE AND RETENTION

We keep your personal information for as long as it is required for our legitimate business purposes, to perform our contractual obligations or, where longer, such longer period as is required or permitted by law or regulatory obligations that apply to us. As a general matter, we do not retain your personal information for longer than we need it. Under regular operations, we will delete your personal information after you cease to be an investor in our Funds and there is no longer any legal/regulatory requirement or business purpose for retaining your personal information.

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8. PROTECTION OF PERSONALLY INFORMATION

We maintain physical, electronic, and procedural security measures that comply with applicable legal and regulatory standards to safeguard your personal information. Access to such information is restricted to those employees who are trained in the proper handling of client information and have a legitimate business need to access that information. We follow generally accepted standards to protect the personal information you submit to us, whether that information is in transit or at rest. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

 
 
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9. OUR SITE AND USE OF COOKIES

We use various technologies to collect other types of information, including personal information, automatically. For example, to measure the usefulness and efficiency of our Sites, we automatically track certain information from all visitors to our Sites. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information.

Additionally, like most interactive web sites, we use “cookies” on certain pages of our Sites. “Cookies” are small data files that are stored on your hard drive that store certain information, including certain personal information accessible to our Sites, such as your password and any information content preferences you may voluntarily set at our Sites. These technologies help us recognize you, customize your experience on the Sites and analyze your use of the Sites to make them more useful to you. By visiting our Sites, you agree to our use of cookies. For more details, please refer to our Cookie Policy.

You can refuse the use of cookies by selecting the appropriate browser setting. If you opt-out, please note that your experience using the Sites may not be optimal, and you may not be able to use certain features on our Sites. For information on how to remove or manage cookie functions and adjust your privacy and security preferences, access the “help” menu on your internet browser, or visit http://www.aboutcookies.org/how-to-control-cookies.

We also use analytics providers, such as Google Analytics to help us evaluate the Sites. To opt out of the aggregation and analysis of data collected about you on the Sites by Google Analytics, visit https://tools.google.com/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.

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10. AUTOMATED DECISION MAKING

We do not use automated processing, including profiling, to make decisions that will have either legal or material effects on the individuals from whom we collect and process personal information.

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11. PERSONAL INFORMATION RIGHTS FOR EU RESIDENTS

To the extent that the European Union’s (the “EU”) General Data Protection Regulation (Regulation 2016/679) (the “GDPR”) applies to our processing of your personal information, the GDPR may offer you increased control over your personal information.

This Privacy Notice provides details regarding your rights under the GDPR, and how to exercise those rights. It also provides you with the contact information you need to act regarding the privacy of your personal information.

Your Data Subject Rights

  • To the extent the GDPR applies to our processing of your personal information, you may, subject to certain limitations, have the right to: Request access to your personal information and some related information, including purpose for processing such personal information, the categories of recipients of such personal information to the extent that is transferred internationally and, where such personal information has not be collected directly from you, the source
  • Rectify incomplete or inaccurate personal information
  • Take your data (in a readable, “portable” format) to another service provider, where possible
  • Require us to erase your personal information in some limited circumstances; and
  • Restrict or object to the processing of your personal information in certain circumstances.

While we do not generally rely on obtaining your consent to process your personal information, if we do, you have the right to withdraw such consent at any time. Please contact us at any time should you wish to do so.

If you want to make a complaint, a list of the EU data protection authorities is available by clicking the following link: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

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12. PERSONAL INFORMATION RIGHTS FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act (“CCPA”) requires us to make certain additional disclosures and provides California residents with certain rights regarding their personal information. If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what we will do in response.

Please note that the rights under the CCPA do not apply to certain personal information collected, processed, sold, or disclosed pursuant to Gramm-Leach-Bliley Act (Public Law 106-102) and Fair Credit Reporting Act (12 CFR 1022).

If you are an individual who resides in California and whose personal information is collected and processed by us, you have the right to:

  • Request that we disclose, free of charge, the categories and specifics of the personal information we collect about you, the sources from which the personal information was collected (and/or, if applicable disclose to a third party), and the business purpose for collecting personal information
  • Choose to opt-out of the sale of personal information. Currently, however, we do not sell personal information
  • Request that we delete the personal information we have collected unless a legal exception applies. For example, we may deny your deletion request if retaining the information is necessary f or us or our providers to complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. Following our verification of the request, we will comply with the request and delete any or all the personal information in our possession that we collected from the California resident and/or any or all such personal information in the possession of our service providers, unless otherwise restricted by law or regulation or if a legal exception applies

We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this Privacy Notice. We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this Privacy Notice.

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13.TRANSFERS OF PERSONAL INFORMATION

We may transfer your personal information between different countries to our affiliates and group members, other investors in the Funds, transaction counterparties and third-party service providers. These countries may not have similarly strict standards regarding data protection and privacy (and may include, for example, transfers from the United Kingdom and the European Economic Area, to jurisdictions outside of such territories). When we transfer your personal information from one country to another, we will put in place data transfer agreements or other appropriate safeguards that are designed to ensure that your personal information is treated in a manner that is consistent with applicable data protection laws (including, where appropriate, EU-approved standard contractual clauses).

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14. QUESTIONS OR CONCERNS AND EXERCISING YOUR DATA SUBJECT RIGHTS

If you have any questions or concerns regarding the information in this Policy, or would like to exercise any of your rights set forth in this Policy, yourself or an authorized agent can contact us on our Privacy hotline at (617) 437-0166 or email us at privacy@rockpoint.com. Please include a description of what right you want to exercise and the information to which your request relates. Consumers with disabilities may request this policy in an alternative format.

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15. VERIFYING YOUR IDENTITY

If you choose to contact us with a request, you will need to provide us with identifying information that matches the personal information we currently have about you or that otherwise allows us to reasonably verify that you are the person about whom we collected personal information. For example, we may require identifying documents such as a copy of passport, driver licenses or other government issued photo identification card, proof of address, date of birth, and/or an executed Form W-9 or applicable Form W-8 (as appropriate).

PLEASE NOTE: We cannot respond to your request or provide you with non-public personal information if we cannot verify your identity or authority to make the request and confirm that the requested personal information relates to you. We will use the information provided in a request solely to verify your identity or authority to make the request.

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