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CCPA

Important Legal Notices and Disclosures

California Consumer Privacy Act

APPENDIX F

California-Specific Privacy Policy

The California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) imposes certain obligations on the Fund, the General Partner and the Investment Manager (together, “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.”  If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA.  The rights described herein are subject to exemptions and other limitations under applicable law.

Terms used herein have the meaning ascribed to them in the CCPA.  The Fund, the General Partner and the Investment Manager are each a “business.”  “Personal information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household.  It does not include deidentified information, aggregate consumer information or publicly available information, as those terms are defined in the CCPA.

Purposes for Collecting and Using Personal Information

We may collect or use your personal information for the following business or commercial purposes: (i) performing services on behalf of a fund, including maintaining or servicing accounts, providing investor relations services, processing subscriptions and withdrawals, verifying information, processing payments or providing similar services; (ii) performing our contractual obligations to a California Resident as a subscriber to a fund, including providing updates on a fund’s performance, providing tax reporting and other operational matters; (iii) detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks; and (iv) enabling or effecting commercial transactions, including using bank account details to remit funds and process distributions.

Personal Information We Collect

In the preceding 12 months, we may have collected the following categories of personal information from or about a California Resident: (i) identifiers and similar information, such as name, address, date of birth, email address, social security number, driver’s license number, passport number, online identifiers or other similar identifiers; (ii) additional information subject to Cal. Civ. Code § 1798.80(e), including your education, credit card number, state identification card number, signature, or bank account or other financial information; (iii) characteristics of protected classifications under federal or certain state laws, including gender, national origin, or marital status; (iv) commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth; (v) internet or other electronic network activity information, including interactions with our website or use of certain online tools; (vi) professional or employment-related information, including occupation, compensation, employer, and title; and (vii) inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds.

In the preceding 12 months, we may have disclosed for a business purpose all of the above categories of personal information to all of the categories of third parties discussed below in “Sharing Personal Information with Third Parties.”

Sources of Personal Information

We may collect personal information about you directly from you and/or your intermediaries through sources such as: (i) account applications, subscription agreements, and other forms or related documentation; (ii) written, electronic, or verbal correspondence with us or our service providers; (iii) investor transactions; (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; or (v) from information captured on applicable websites.  In addition, we may collect personal information from different sources, such as: (i) our affiliates, our service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; or (iii) credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

Sharing Personal Information with Third Parties

We do not sell your personal information.  We may disclose personal information to third parties in circumstances where we believe in good faith that disclosure is required or permitted under law, to cooperate with regulators or law enforcement authorities, or to protect our rights or property.  We also may disclose personal information about you or your accounts to a third party at your request or direction or with your consent. 

For these reasons, we may disclose any of the categories of personal information discussed above in “Personal Information We Collect” to any of the following categories of third parties: (i) investors and investors’ intermediaries in connection with investments and transactions; (ii) third parties who deliver our communications, including postal services; (iii) third parties who assist with our information technology and security programs; (iv) third parties who assist with fraud prevention, detection and mitigation; (v) third parties as needed to complete a transaction, including financial institutions; (vi) third parties in connection with legal or regulatory matters, including government or regulatory agencies, courts, opposing counsel and parties to litigation; (vii) third parties in connection with the sale or transfer of all or any relevant portion of our business or assets; (viii) our lawyers, accountants, auditors, and consultants; and (ix) other third parties as permitted or required by law.

We also may disclose your personal information to our service providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.

California Residents’ Rights under the CCPA 

If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); and (v) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting the personal information; (d) the categories of third parties to which we disclosed personal information about you for a business purpose; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations.  In addition, the CCPA does not apply to certain information, like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations.  We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.

How to Submit a Request under the CCPA 

You may submit a Request to Know, as described above, through the following telephone number 412-586-3747, or through our website at the following link Privacy Form. You may submit a Request to Delete, as described above, by calling the following telephone number (412) 586-3747 or by mail to the following address:

Venator GP LP
607 Washington Road • Suite 400
Pittsburgh, PA 15228
Attention: Andrew Clark

We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your authorized agent.  Any information gathered as part of the verification process will be used for verification purposes only. 

When you submit a Request to Know or Request to Delete, we may ask that you provide clarifying or identifying information to verify your request.  Such information may include, at a minimum, depending on the information you are requesting and the type of request you are making, account login credentials or other account information, answers to security questions, name, government identification number, date of birth, contact information, or other personal information.

If an authorized agent seeks to submit a request on behalf of a California Resident, the authorized agent may do so by the aforementioned methods, however, they must provide: (i) signed authorization from the California Resident authorizing them to act on the California Resident’s behalf, unless they can provide proof that the California Resident has granted them power of attorney pursuant to California Probate Code sections 4000 to 4465; and (ii) proof of their registration with the California Secretary of State to conduct business in California.  We also require that the California Resident directly verify their own identity with us and directly confirm with us that they provided the authorized agent permission to submit the request.

Contact for More Information

If you have any questions or concerns about this California-Specific Privacy Policy, please contact Andrew Clark (telephone: (412) 586-3747) at the office of the General Partner.

This California-Specific Privacy Policy was last updated on January 6, 2021.  A copy of the Fund’s general privacy policy can be found at Appendix C to the Fund’s subscription documents, and a copy of the relevant online privacy policy can be found here at CCPA PRIVACY POLICY.