Privacy Policy

Terms of Use

Thank you for visiting SIP Global Partners’ website (the “Website”). By entering and using the Website, you acknowledge and agree to all of the terms and conditions stated herein (“Terms and Conditions”). SIP Global Partners (“SIP”) reserves the right to revise these Terms and Conditions at any time and for any reason, without notice or obligation. Changes will be effective when posted. Your continued use of this Website following any revisions to these Terms and Conditions will mean that you accept and agree to abide by the Terms and Conditions as modified. If you do not agree with any of the terms and conditions contained herein, please do not access or otherwise use the Website. SIP recommends that you periodically revisit this page to review these Terms and Conditions.

Our website address is: https://sipgp.com.

Use of Website

This Website is intended to be solely for the purpose of evaluating a potential or existing business relationship with SIP, employment recruiting, and general informational purposes. You agree not to construe any of the content, information, or other materials (including any data, text, images, video or audio) (collectively, the “Content”) contained on or made available through this Website to be, investment, accounting, financial, tax, legal or any other advice. SIP does not solicit or make its services available to the general public. Under no circumstances should any Content on this Website be used or considered as an offer to sell or buy or a solicitation of an offer to sell or buy any security or services of SIP or any other issuer. Offers can only be made where lawful under, and in compliance with, applicable law. Although this Website may include investment-related information, nothing on this Website is a recommendation that you purchase, sell or hold any security or other investment, or that you pursue any investment style or strategy. Furthermore, any transactions listed on this Website are included as representative transactions and are not necessarily reflective of overall performance. SIP makes no representations that transactions, products or services discussed on the Website are available or appropriate for sale or use in all jurisdictions or by all investors. In the United States, SIP operates as an SEC-registered investment adviser.

Loss of Use

In addition to all rights and remedies available to SIP under applicable law, SIP reserves the right, in its sole discretion, to immediately, at any time without notice, suspend or terminate your ability to access or use the Website. SIP reserves the right to withdraw or amend the Website and any Content, in its sole discretion, without notice. SIP shall not be liable if, for any reason, all or any part of the Website or any Content is unavailable at any time or for any period.

Restricted Use of Website Materials

SIP grants you a limited right to access and make personal use of the Website in accordance with these Terms and Conditions. You shall not download or modify the Website, or any portion of it except with the prior express written consent of SIP. If you wish to seek permission for such use of the Website, please contact SIP at the email address below. The right to access and use this Website granted herein does not include: any resale or commercial use of the Website or its contents; any derivative use of the Website or its contents; or any use of data mining, robots or similar data gathering or extraction tools or methods. Any unauthorized use terminates the permission granted by SIP hereunder. SIP reserves all other rights.

Although SIP provides the Content accessible on the Website for your personal, non-commercial use, SIP retains ownership of, and all right, title, and interest in and to all property rights, including under U.S. and international copyright law, to, the Website and all Content, including but not limited to non-textual information components, such as graphic images, that are part of or incidental to such Content. This means that without the prior express written permission of SIP, you MAY NOT: distribute information from this Website to others; include information from this Website on another website, on a server or computer, or in documents, including but not limited to “mirroring” the information or displaying the information by means of HTML frames or similar means (see the ‘Linking, Posting and Framing’ Section below); or modify or re-use the Content from this Website. SIP reserves all other rights.

Copyrights and Trademark

You acknowledge and agree that SIP is the copyright owner of all Content on the Website or has the permission to use such Content, or in the case of news articles, if any, the news articles are from publicly available sources. No portion of the Content may be copied or distributed in any manner, or for any purpose, without SIP’s prior express written permission. The compilation of all Content on this Website is the exclusive property of SIP and is protected by U.S. and international copyright laws. All trademarks and logos displayed on this website are the property of their respective owners who may or may not be affiliated with our organization.

You acknowledge and agree that any name, logo, trademark, or service mark contained on the Website is owned or licensed by SIP and may not be used without the prior express written permission of SIP. You acknowledge and agree that SIP may enforce its intellectual property rights to the full extent of the law. Graphics, charts, information or images of places or people are either property of SIP or used on the Website with permission. Your use of any of these materials is prohibited unless specifically permitted. Any unauthorized use of these materials may subject you to penalties or damages, including but not limited to those related to violation of trademarks, service marks, copyrights, cybersecurity, privacy, and publicity rights under statute or common law.

Linking, Posting and Framing

Please note that these Terms and Conditions apply only to the Website and not to websites operated by other entities that may be accessible from the Website via hyperlink as a convenience to you (“Third-Party Websites”). SIP is responsible only for the Content on this Website. You acknowledge and agree that SIP is not, directly or indirectly, making or implying any approval, association, sponsorship, endorsement, or affiliation with any Third-Party Website. Your visiting any Third-Party Website is at your own risk. SIP does not make, and hereby disclaims, all representations or warranties of any kind with respect to any Third-Party Websites or any such content, information, or materials. SIP encourages you to review the privacy policies and user agreements of all Third-Party Websites that you visit.

You agree that you will not link to, post on, or transmit to the Website, any pornographic, obscene, profane, defamatory, libelous, threatening, unlawful, or other material which could constitute or encourage unlawful conduct, be considered a criminal offense, give rise to civil liability, or otherwise violate any law or regulation. Notwithstanding the fact that SIP, or other parties involved in creating, producing, or delivering the Website, may monitor or review any transmissions to or use of theWebsite, SIP and all such parties assume no responsibility or liability from such monitoring or review, including for claims for defamation, libel, slander, obscenity, pornography, profanity, or misrepresentation.

No Warranty

While SIP makes reasonable efforts to ensure that all Content on the Website is correct, accuracy cannot be guaranteed, and SIP makes no representations or warranties as to its accuracy, reliability or completeness.

THIS WEBSITE, AND ALL CONTENT CONTAINED THEREIN AND THEREON, IS PROVIDED “AS IS ”WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, ANY IMPLIED WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE OR NON-INFRINGEMENT AND ANY SUCH WARRANTY IS HEREBY DISCLAIMED TO THE FULLEST EXTENT PERMITTED BY LAW. TO THE FULLEST EXTENT PERMITTED BY LAW, SIP ALSO DISCLAIMS ANY WARRANTIES FOR THE SECURITY, RELIABILITY, TIMELINESS, AND PERFORMANCE OF THE WEBSITE.

International Use

This Website is operated and controlled by SIP in the United States. Due to the global nature of the Internet, the Website may be accessed by users in countries other than the United States. SIP makes no warranties that Content on this Website is appropriate or available for use in any jurisdiction. If it is illegal or prohibited in your country of origin to access or use this Website, then you should not do so. Those who choose to access the Website do so on their own initiative and are responsible for compliance with all local laws and regulations.

Limitations of Liability

You acknowledge and agree that your use of this Website is solely at your own risk and that none of SIP, its affiliates, nor any of the parties involved in creating, producing, or delivering the Website is liable for any direct, indirect, incidental, consequential or punitive damages, or any other losses, liabilities, obligations, damages, claims, demands, actions, costs and/or expenses of any kind (including legal fees, expert fees, or other disbursements) which may arise, directly or indirectly, through authorized or unauthorized access to, use of, or browsing of this Website or downloading of any materials, data, text, images, video, audio, or other Content from this Website, including but not limited to anything caused by any omission, interruption, defect, viruses, bugs, human action or inaction or any computer system, phone line, hardware, software, or program malfunctions, or any other errors, failures or delays in computer transmissions or network connections.

Notwithstanding anything to the contrary herein, your sole and exclusive remedy from SIP, its affiliates, or any of the parties involves in creating, producing, or delivering the Website, for any reason relating to the Website or Content is to stop using the Website. In jurisdictions not allowing the exclusion or limitation of incidental or consequential damages, SIP’s and its affiliates’ liability will be limited to the extent permitted by law.

Indemnity

You agree that you will be solely responsible for, and that you will indemnify, and hold SIP, its affiliates, and its and their respective officers, directors, agents, employees, representatives and licensors harmless from and against any and all claims, demands, suits, proceedings, liabilities, judgments, losses, damages, costs or expenses, including reasonable attorney’s fees assessed or incurred by SIP or such affiliates, directly or indirectly, with respect to or arising out of your use or misuse of the Website or the Content or resulting from your violation of these Terms and Conditions. SIP reserves the right, at its own expense, to assume the exclusive defense and control of any matter for which it is entitled to indemnification, but you must still indemnify SIP for all liability, losses, or damages. You agree to provide SIP with whatever cooperation it reasonably requests in connection with any such defense.

User Submissions

You acknowledge and agree that any communication or material you transmit to this Website or to SIP, in any manner or for any reason, will not be treated as confidential or proprietary. Furthermore, you acknowledge and agree that any materials you transmit to SIP may be used by SIP, anywhere, anytime, and for any reason whatsoever, without payment to you. From time to time, SIP receives business plans, and SIP reserves the right to review only those plans that SIP believes fit our criteria for investment. SIP also reserves the right to reject plans in our sole discretion, and SIP is under no obligation to return any information or materials to the sender. SIP expects to receive many similar plans and ideas. Therefore, you understand that your idea may already have been submitted to us or be under consideration by us. SIP is not limited or restricted in any way from pursuing opportunities with others as a result of you providing any information or materials to us.

You agree not to send SIP anything that constitutes a trade secret or confidential or proprietary information. SIP is not in a position to accept such information, nor can SIP agree to obligations of nondisclosure or confidentiality with regard to submitted plans or ideas. You agree that any information or materials that you, or individuals acting on your behalf, provide to SIP will not be considered confidential or proprietary.

Electronic Communications

When you use the Website or send e-mails or other communications from your desktop or mobile device to SIP, you are communicating with SIP electronically. You consent to receive communications from us electronically. SIP will communicate with you in a variety of ways, such as by e-mail or by posting notices and messages on or through the Website.

You agree that all agreements, notices, disclosures, and other communications that SIP provides to you electronically satisfy any legal requirement that such communications be in writing.

Privacy Policy

Please review the Website’s Privacy Policy which governs your visit to this Website in order to understand SIP’s privacy practices.

Severability

If any of these Terms and Conditions are deemed invalid, void, or unenforceable, such term or condition shall be deemed severable and shall not affect the validity or enforceability of the remaining Terms and Conditions, and such invalid, void, or unenforceable term or condition shall be deemed to be replaced by a term or condition that is valid and enforceable and corresponds as close as possible with the intent of the invalid, void, or unenforceable term or condition.

Miscellaneous

You may not assign or otherwise transfer these Terms and Conditions, or any of your rights or obligations hereunder, without SIP’s prior written consent, and any attempted assignment or other transfer in violation of this provision shall be null and void.

Nothing in these Terms and Conditions may be used to construe you and SIP as joint venturers, co-employers, partners, or agents of each other, and neither you nor SIP has the power to obligate or bind the other in any way whatsoever.

The failure of SIP at any time or times to require performance of any provision hereof shall in no manner affect its right at a later time to enforce the same unless the same is waived in writing. No waiver in connection with these Terms and Conditions shall be effective unless it is in writing and signed by the party granting such waiver.

The terms and conditions set forth in these Terms and Conditions, and each agreement included or referred to in these Terms and Conditions, constitutes the final, complete, and exclusive agreement with respect to the subject matter hereof and may not be contradicted, explained, or supplemented by evidence of any prior any contemporaneous oral agreement, or any inconsistent additional terms.

Governing Law

These Terms and Conditions shall be interpreted and construed in accordance with the laws of the State of New York. You agree that your use of this Website and any and all claims, controversies, and causes of action arising out of or relating to these Terms and Conditions or this Website, whether sounding in contract, tort, or statute, shall be governed in all respects by the internal laws of the State of New York, including its statutes of limitations, without giving effect to any laws or other rules that would result in the application of the laws or statutes of limitations of a different jurisdictions. Any dispute relating to the above shall be resolved exclusively in the state or federal courts located in theState of New York. SIP may seek injunctive or other appropriate relief in any state or federal court in the State of New York, and you consent to exclusive jurisdiction and venue in such courts.

Contact Us

Thank you for visiting our Website. Please contact us at info@sipgp.com if you have any questions about our Website or these Terms and Conditions.

Advisory Services Disclaimer

SIP Global Partners (“SIP”) and certain of its affiliates are regulated by the Securities and Exchange Commission as investment advisers or exempt reporting advisers under the Investment Advisers Act of 1940, as amended. The information provided on this website, including any information regardingSIP’s current and historical portfolio investments, is not intended to recommend any investment described herein and is not an offer or solicitation of any security or investment product and should not be construed as investment advice. Past performance is not a guarantee of future results, and it should not be assumed that results for current and historical portfolio investments will be achieved for other investments. Representative investments are not to be considered a complete list of all investments made in the past, or currently held, by SIP funds.

SIP has not compensated any party for any endorsement, testimonial, or ranking shared or referenced on this website, and SIP is not aware of any material conflicts of interest arising from any endorsement, testimonial, or ranking.

Certain portions or pages of this website may be subject to additional disclosures and disclaimers. In the event of a conflict between these disclosures and disclaimers and these terms and conditions, the additional disclosures and disclaimers will govern such portions and pages.

Website Privacy Policy

Thank you for visiting the SIP Global Partners (“SIP”) website. Your privacy is important to SIP and our affiliates (together, ‘our’, ‘us’, or ‘we’). To better protect your privacy, we are providing you information explaining our online information practices.

SIP may change this Privacy Policy from time to time, based upon any changes to the personal information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, and if we make any substantial changes to this PrivacyPolicy, we will post a prominent announcement on our home page of this website. We will use your personal information only in accordance with this Privacy Policy under which the personal information was collected.

SIP respects the privacy of visitors to our website. This Privacy Policy describes how and when we gather information from visitors to our website. Please read this Privacy Policy carefully. For the purposes of applicable EU laws, SIP will be a data controller of any personal information collected by us.

We rely on various legal bases under applicable data protection legislation in order to process your personal information, including our legitimate interests, contractual necessity and as required by law. We use the personal information we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal information about you, nor any information about criminal convictions and offenses.

If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal information, and the possible consequences of you failing to provide such personal information (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations and failure to provide this information means that we cannot provide our services or products to you). In this case, we may have to cancel an investment or service you have with us, but we will notify you if this is the case at the time.

Further information about the legal bases under which we process your personal information is included in the section headed “Why We Use Your Personal Information”.

You do not need to take any action as a result of this Privacy Policy, but you do have certain rights as described below in the section headed “Your Rights”.

Aggregate Data

We generally record certain usage information, such as the number and frequency of visitors to this website. This information may include the websites that you access immediately before and after your visit to our website. If we use such data at all, it will be on an aggregated and anonymized basis, and we will not disclose to third parties any information that could be used to identify you personally.

How We Collect Your Personal Information

We use Google’s reCAPTCHA application on our website in order to protect against spam and other automated abuse. The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements. The use of their CAPTCHA tool and any information collected through the tool are subject to Google’s privacy policy, available here, and Google’s terms of service, available here.

SIP, through our website, also utilizes Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going here and exercise the opt-out options provided by Google by downloading the Google Analytics opt-out browser add-on, available here.

If you voluntarily submit information to our website, for example, in a request to receive a SIP newsletter, we may record and use any such personal information. We may collect personal information from you via the “Contact Us” details on our website (including by email, post, and telephone), when you submit a message using our website contact form, or when you provide us your details when signing up for our newsletter. The personal information we may collect about you includes your name, name of your employer, address, title, job title, position, telephone number and email address. Information regarding how we process personal information is set out in the privacy notice provided to you when you invest in one of our funds.

We will only use your personal information for reasonable business purposes as set out below (including, but not limited to, fulfilling your requests). We will not use your personal information for any other purposes without your permission.

Information Provided by Third Parties or Publicly Available Sources

We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. This personal information is obtained via third parties (i.e., the company in question). We may also process information provided to us from recruiters or our portfolio companies in connection with evaluating potential employment or resourcing opportunities.

Why We Use Your Personal Information

To the extent that you provide us with, or we otherwise collect, any personal information, through or in connection with this website (i.e., via telephone, email, or post), we may use such information for the following purposes and may process your personal data on more than one legal basis depending on the specific purpose:

  • To provide you with the services or financial products you have requested.
  • To keep a record of your relationship with us.
  • To verify your identity.
  • To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to.
  • Fraud and abuse prevention.
  • Litigation management and conducting internal audits and investigations.
  • To administer and protect our business and this website.
  • To send you marketing communications.
  • To respond to your contact requests via email, post, or telephone.

No automated decision making, including profiling, is used when processing your personal information.

Marketing

We will only send you direct marketing communications, such as SIP newsletters, where we have obtained your prior consent to do so or based on our legitimate business interests where we have an existing relationship with you, and we wish to contact you about similar services in which you may be interested. You may opt-in to certain kinds of marketing and amend your marketing preferences at any time (including by unsubscribing), by emailing info@sipgp.com. You can also click on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

Disclosures and Transfers of Personal Information

We may use internet service providers to operate this website and employ other persons to perform work on our behalf. Your personal information will be shared with and processed by our affiliates and certain service providers as necessary to fulfill the purposes set out in this Privacy Policy, including professional advisors, consultants and data hosting providers, and in some instances, placement agents and other fund administrators. These third parties may have access to the personal information you submit through this website, but only for the purpose of performing their duties. These persons may not use your personal information for any other purpose.

We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. For further information about the safeguards used, please contact info@sipgp.com.

We will not provide any personal information to any other persons, except if we are required to make disclosures to the government, to comply with a request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us or private parties in connection with a lawsuit, subpoena, investigation, examination or similar proceeding. We reserve the right to disclose any such information in those circumstances. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal information to the new owner of the relevant business and their advisors.

Protection of Personal Information

We endeavor to protect your personal information. We use both robust technical and procedural methods to maintain the integrity and security of our databases so the information we have about you is protected to the extent possible from unauthorized access and improper use, including firewalls. Please be aware, though, that no security measures are perfect or impenetrable. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact info@sipgp.com.

Capacity

This website is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to this site who are under the age of 13 or knowingly collect personal information from anyone under the age of 13 without parental consent. If we learn we have collected or received personal information from an individual under the age of 13, we will delete that information.

Your Rights

You have the right to access and control (in certain ways) the personal data we process about you. To exercise these rights and controls, please contact info@sipgp.com.

Access – You have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.

Correction – You may notify us of changes to your personal data if it is inaccurate or it needs to be updated.

Deletion – If you think that we shouldn’t be holding or processing your personal data anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.

Restrictions on use – If you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.

Objection – You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.

Portability – If you wish to transfer your personal data to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.

Withdrawal of consent – If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise the above rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact Us

Thank you for visiting this website. Please contact us at info@sipgp.com if you have any questions about this website or this Privacy Policy.

Complaints

If you have any concerns, questions, or complaints with respect to our processing of your personal information, please contact us at info@sipgp.com. You may also lodge a complaint directly with your local data protection authority.

CALIFORNIA WEBSITE PRIVACY POLICY

This California Website Privacy Policy supplements the above Website Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California resident scan exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the above Website Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/orRegulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this Website Privacy Policy apply to?

This Website Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you?

We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we may have collected from individuals on this Website over the last twelve (12) months include the following:

  • Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address);
  • Other customer records, such as telephone number and personal information provided in connection with obtaining account access;
  • Commercial information, such as account data;
  • Professional or employment-related information;
  • Education information;
  • Internet or other electronic network activity information, such as information regarding your use of our Website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries. The browsing and/or search history information may include the websites that you access immediately before and after your visit to our website. If we use such data at all, it will be on an aggregated and anonymized basis.

We do not knowingly collect or solicit personal information from anyone under the age of 18.

How do we obtain your personal information?

In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:

  • Information from your communications with us in connection with this Website, including any update notices provided by you.
  • Information captured on our Website, including registration information, information provided through online forms and any information captured via cookies.

We use Google’s reCAPTCHA application on our website in order to protect against spam and other automated abuse. The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements. The use of their reCAPTCHA tool and any information collected through the tool are subject to Google’s privacy policy, available here, and Google’s terms of service, available here.

SIP, through our Website, also utilizes Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going here and exercise the opt-out options provided by Google by downloading the Google Analytics opt-out browser add-on, available here.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

How do we use your personal information?

We will use your personal information for one or more of the following business purposes:

  • To perform services for you.
  • To improve our Website and the products and services that we offer and notify you about changes to our products and services.
  • To communicate with you, including responding to requests for information submitted by you through our Website.
  • To keep a record of your relationship with us.
  • Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
  • To audit and verify the quality and effectiveness of our services and compliance.
  • To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
  • To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.

Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

Who do we share your personal information with?

We do not sell any of the personal information we collect about you to third parties.

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, advisors, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We may also disclose your information to other parties as may be required by law or regulation, in response to regulatory inquiries, or upon your request.

Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth above in “What information do we collect about you?”

We may also share your personal information with applicable third parties in the event of are organization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.

How do we keep your personal information secure?

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Your rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S.,state, local and non-U.S. laws, rules, and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:

  • the categories of personal information we collected about you;
  • the categories of sources from which the personal information is collected;
  • our business or commercial purpose for collecting such personal information;
  • the categories of third parties with whom we share the personal information;
  • the specific pieces of personal information we have collected about you; and
  • whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding ourprocessing of your personal information, please submit or have your authorized representative submita request using the method set forth below.

Email us at the following email address: info@sipgp.com

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required. Please contact the Chief Compliance Officer of SIP Global Partners LLC at the email address above with any questions about this California Website Privacy Policy.