Investor Privacy Policy

INVESTOR PRIVACY POLICY

Last updated May 16, 2024

1. INTRODUCTION

This is the investor data protection policy and privacy notice (“Policy”) for Centre Partners (as defined below). This Policy applies to Investors (as defined below).

Centre Partners respects your privacy and this Policy governs how we collect, process (as defined below) and use your Personal Information (as defined below). For the purposes of applicable laws and regulations relating to data protection and privacy. The terms set forth on Annex A applies to the Personal Information of Investors that constitute “nonpublic personal information” under the Gramm-Leach-Bliley Act.

This Policy may change from time to time. The most up to date version of this Policy can be found at www.centrepartners.com. We encourage you to check it periodically to review any changes that we might make to this Policy.

2. DEFINITIONS

The following definitions shall apply to this Policy:

• “Centre Partners”, “we”, “us”, “our” means Centre Partners Management, LLC (along with each investment vehicle, fund or account managed or advised by Centre Partners (together, the “Affiliates”)).
• “Investor” means an investor in a Centre Partners managed investment vehicle, who may be an individual investor or an institutional investor (direct or intermediary).
• “Personal Information” means any information that identifies, could be used to identify or is otherwise associated with an individual person, which is in the possession of, or is likely to come into our possession (or the possession of our representatives or service providers), and includes the definition of “personal Information,” “personal data,” and similar terms under applicable laws and regulations relating to data protection and privacy.
• “Process” or “processing” means any operation that is carried out in respect of Personal Information, including but not limited to collecting, storing, using, disclosing, transferring or deleting Personal Information.
• “You” or “Your” means a living individual, who may be: (a) an Investor or prospective Investor; or (b) an employee, director, officer, trustee, beneficiary, or representative or intermediary of an Investor or prospective Investor.

3. THE TYPES OF PERSONAL INFORMATION WE COLLECT

Many of the services offered by Centre Partners require us to obtain Personal Information about you in order to perform the services we have been engaged to provide, and to comply with applicable law or policies (for example, Know Your Client and Anti-Money Laundering). In connection with the provision of those services, Centre Partners may collect the following categories of Personal Information about you:

• Identifiers, including of your name, age, date of birth, e-mail address, address, telephone number, identification number, online identifier, location, gender, nationality, citizenship and other contact information;
• financial information or other information obtained as a result of your investment in any of our funds (such as advisor details, investment details, banking details, and financial details);
• information relating to the services we provide to our Investors or prospective Investors; and
• information required as a result of legal, tax and regulatory requirements or internal policies; and
• any other categories of information listed in Annex A to this Policy.

Please note that if you do not provide certain Personal Information to Centre Partners when requested (and where relevant, provide your consent), we may not be able to provide you with some or all of our services and products (including those set out in this Policy or in other agreements we enter into with you).

4. HOW WE USE YOUR PERSONAL INFORMATION

Your Personal Information may be collected, stored, disclosed and processed by Centre Partners for the following purposes:

• to provide you with marketing communications and inform you about news and information relating to our business and services;
• to assess your application for Centre Partners products and services, where applicable;
• to understand your needs and interests and to respond to your enquiries;
• to analyze and improve our services;
• for the management and administration of our business;
• to provide you with the products and services for which you subscribe;
• to comply with and in order to assess compliance with applicable laws, rules and regulations (including tax reporting purposes pursuant to tax legislation), industry codes, voluntary codes we decide to adopt, or good practice, anywhere in the world and internal policies and procedures;
• to confirm and verify your identity and to conduct due diligence, background and related checks (this may involve the use of a credit reference agencies and/or other third parties acting as our agents to conduct these verifications and related reviews including screens against publicly available government and/or law enforcement agency sanctions lists);
• to detect, investigate and prevent fraud and other crimes or malpractice, and to improve fraud detection and information security;
• for the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings);
• to obtain legal advice or to establish, exercise or defend legal rights;
• for the administration and maintenance of databases storing Personal Information;
• to comply with our contractual obligations; and
• for purposes otherwise set out in this Policy, including Annex A, or as notified to you at the specific time of collection.

5. DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES

Centre Partners does not sell Personal Information to third parties or target advertising to individuals based on their Personal Information obtained from their online activity on non-affiliated websites or applications (“cross-context behavioral advertising”). Centre Partners may share or provide access to your Personal Information among its affiliates and business units and third-party agents, service providers and contractors outside of Centre Partners for the purposes set forth in Annex A. In addition to the purposes set forth in Annex A, Centre Partners may share your personal information with third parties such as service providers in order to facilitate our business operations.

6. YOUR RIGHTS

To the extent provided by the law of your jurisdiction, you may have certain legal rights in relation to your Personal Information, including under the California Consumer Privacy Act, (“CCPA”). A description of your CCPA rights is available in our Investor California Privacy Policy attached hereto as Annex B. The Investor California Privacy Policy applies to the Personal Information of California Investors that do not constitute “nonpublic personal information” under the Gramm-Leach-Bliley Act.

7. QUESTIONS AND CONCERNS

If you have any questions or concerns about our handling of your Personal Information, or about this Policy, please contact us using the contact information set out below.

8. CONTACT INFORMATION

Please contact us with any questions, comments or concerns about this Privacy Notice or our use of your personal information by e-mail at info@CentrePartners.com or by mail at:

Centre Partners Management, LLC
601 Lexington Avenue, 55th floor
New York, NY 10022-4611

 

Annex A

 

FACTS	WHAT DOES CENTRE PARTNERS DO WITH YOUR PERSONAL INFORMATION?
WHY?	Financial companies choose how they share your personal information. U.S. federal law gives consumers the right to limit some but not all sharing. U.S. federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
WHAT?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number Wire transfer instructions Account transactions and assets
HOW?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Centre Partners chooses to share; and whether you can limit this sharing. When you are no longer our customer, we continue to share your information as described in this notice.

Reasons we can share your personal information	Does Centre Partners	Can you limit this
For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes- to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	We don’t share
For our affiliates’ everyday business purposes- information about your transactions and experiences	No	We don’t share
For our affiliates’ everyday business purposes- information about your creditworthiness	No	We don’t share
For our affiliates to market to you	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

QUESTIONS

Call 212-332-5800 or email info@CentrePartners.com.

Who we are
Who is providing this notice?	Centre Partners Management, LLC and its affiliates set forth below.

What we do
How does Centre Partners protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Centre Partners collect my personal information?	We collect your personal information, for example, when you open an account or provide account information give us your contact information or enter into an investment advisory contract make a wire transfer
Why can’t I limit all sharing?	U.S. federal law gives you the right to limit only sharing for affiliates’ everyday business purposes—information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing.
What happens when I limit sharing for an account I hold jointly with someone else?	Your choices will apply to everyone on your account—unless you tell us otherwise.

Definitions
Affiliates	Our affiliates include each investment vehicle, fund or account managed or advised by Centre Partners.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates we share with can include fund administrators, custodians, brokers, dealers, counterparties, auditors, and legal advisors.
Joint marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Centre Partners does not jointly market.

 

Annex B

 

INVESTOR CALIFORNIA PRIVACY POLICY

1. Introduction

This supplemental privacy policy (“Investor California Privacy Policy”), which is provided in addition to the Investor Privacy Policy, governs how Centre Partners and its Affiliates collect, process, and use Personal Information (as defined below) relating to investors who are residents of the State of California (collectively, “you”) covered by the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act, collectively, the “CCPA”) and provides information regarding how such California residents can exercise their rights under the CCPA.

This Investor California Privacy Policy is only relevant to you if you are a resident of California as determined in accordance with the CCPA. This Investor California Privacy Policy is available in alternative formats upon request. Please contact info@CentrePartners.com to request this Investor California Privacy Policy in an alternative format. Centre Partners is currently in the process of obtaining a toll free number.

2. Definitions

1. “Personal Information” means any information that identifies, could be used to identify or is otherwise associated with an individual person, which is in the possession of, or is likely to come into our possession (or the possession of our representatives or service providers), and includes the definition of “personal Information,” “personal data,” and similar terms under applicable laws and regulations relating to data protection and privacy.
2. Capitalized terms used herein but not otherwise defined shall have the meaning assigned to it in the Investor Privacy Policy.

3. Our Collection, Use, Retention and Disclosure of Personal Information

1. Sales and Sharing of Personal Information. We do not and have not sold any categories of Personal Information to third parties or shared any categories of Personal Information for the purpose of cross-context behavioral advertising.
2. Collection, Sources and Use of Personal Information. We have collected and used the following categories of Personal Information from the following sources and for the following business purposes during the 12-month period prior to the “last updated” date of this Investor California Privacy Policy:

Categories of Personal Information	Sources	Business Purposes
Identifiers, including name and contact details (including address,	Directly from you, including, for example, through your use of the website, when you send us an email, visit our premises or otherwise contact or communicate with us; From within Centre Partners, including, for example, from our affiliates; From vendors, including, for example, service providers, advisors, and other business partners.	Providing services that you reasonably expect from us; Marketing purposes, including sending correspondence, analyzing trends, administering the Site, tracking users’ movements around the Site, to improve the Site and to make it more useful to visitors; Auditing and verifications, including but not limited to verifying the quality and effectiveness of services and compliance activities; Short-term, transient uses, including in relation to cookies and similar technology; Protecting our systems, including detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity and prosecuting those responsible; debugging to identify and repair errors that impair intended functionality; Complying with legal obligations, such as in connection with a valid court order, judicial subpoena or regulatory inquiry, and as required by law enforcement agencies, federal or state regulatory agencies or self-regulatory organizations; and In connection with business transactions, such as (i) a sale, merger, or other change in corporate control or a restructuring event, or (ii) an investment, acquisition or other business transactions involving Centre Partners’ portfolio companies.
Other records, including signature, physical characteristics or description; bank account number and other financial information (including accounts and transactions with other institutions); driver’s license or other state ID card number or passport number; medical information and health insurance information; and verification documentation (including	Directly from you; From within Centre Partners; and From vendors.	Providing services; Auditing and verifications; Protecting our systems; Complying with legal obligations; and In connection with business transactions.
Protected classifications under California or federal law, including race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, citizenship status and military and veteran status.	Directly from you; From within Centre Partners; and From vendors.	Providing services; Marketing purposes; Complying with legal obligations; and In connection with business transactions.
Inferences, including those drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	From within Centre Partners; and From vendors.	Providing services; Marketing purposes; Auditing and verifications; Protecting our systems; and In connection with business transactions.
Other information you create or provide to us, including the content of your communications with us.	Directly from you; From within Centre Partners; and From vendors.	Providing services; Marketing purposes; Auditing and verifications; Short-term, transient uses; Protecting our systems; Complying with legal obligations; and In connection with business transactions.

1. Protecting Minors. Our Services are intended for use by individuals over the age of 18. We do not knowingly collect Personal Information from individuals under the age of 18. If you are under 18 years of age, then please do not use or access the Services at any time or in any manner.
2. Anonymized or De-Identified Data. Centre Partners may share anonymous or aggregated data in order to facilitate our business operations. To the extent such data constitutes anonymized or de-identified data under the CCPA and other applicable privacy and data protection laws, we will maintain and use such data without attempting to re-identify the data.
3. No Automatic Decision-making. We may process some of your Personal Information automatically, but we do not use computer algorithms to make automated decisions based on your Personal Information.
4. Sensitive Personal Information. Sensitive Personal Information may include social security numbers, driver’s license numbers, passport numbers and account credentials. To the extent we collect your Sensitive Personal Information, we will not use or disclose such information for purposes other than (i) to perform services/goods that you reasonably expect from us; (ii) to prevent, detect and investigate security incidents; (iii) to resist illegal actions directed at the business and prosecute defend our rights; (iv) to ensure the physical safety of others; (v) for short-term, transient use; (vi) to perform services necessary for the business; (vii) to verify and maintain the quality and safety of our product or services; and (viii) generally for purposes that do not infer characteristics about you.
5. Retention of Personal Information. We retain Personal Information for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected. For additional information on how we store your Personal Information, please refer to Section 6(B) of the Privacy Policy.
6. Disclosures of Personal Information for Business Purposes. We have disclosed the following categories of Personal Information to the following categories of recipients for the following business purposes during the 12-month period prior to the “last updated” date of this Investor California Privacy Policy:

Categories of Personal Information	Categories of Recipients	Business Purposes
Identifiers; Other records; Protected classifications; Inferences; and Other information.	Affiliates, as defined above; Service providers and contractors, including, for example, service providers, contractors, advisors and others who provide services to us or on our behalf; Professional advisors, including, for example, auditors, tax advisors, investment advisors, compliance consultants and law firms; Investors and creditors, including, for example, prospective or current investors or creditors of Centre Partners.	Providing services.
Identifiers; Protected classifications; Inferences; and Other information.	Affiliates; Service providers and contractors; and Professional advisors.	Marketing purposes.
Identifiers; Other records; Inferences; and Other information.	Affiliates; Service providers and contractors; Professional advisors; Investors and creditors; and  Governmental entities, including, for example, regulatory agencies and law enforcement.	Auditing and verifications.
Identifiers; and Other information.	Affiliates; Service providers and contractors; and Professional advisors.	Short-term, transient uses.
Identifiers; Other records; Inferences; an Other information.	Affiliates; Service providers and contractors; Professional advisors; and Governmental entities.	Protecting our systems.
Identifiers; Other records; Protected classifications; and Other information.	Affiliates; Service providers and contractors; Professional advisors; Investors and creditors; and Governmental entities.	To comply with legal obligations.
Identifiers; Other records; Protected classifications; Inferences; and Other information.	Affiliates; Service providers and contractors; Professional advisors; Investors and creditors; and Governmental entities.	In connection with business transactions.

4. Your California Privacy Rights

1. Your CCPA Privacy Rights. You have certain choices regarding our use and disclosure of your Personal Information, as described below.
   1. Know. You have the right to request, twice in a 12-month period, that we provide (a) certain information about the (1) the categories of Personal Information we have collected about you, (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting your Personal Information; and (4) the categories of third parties with whom we have shared your Personal Information; and/or (b) the specific pieces of Personal Information we have collected, used and disclosed about you during the past 12 months.
   2. Deletion. You have the right to request that we delete certain Personal Information we have collected from you and to tell our service providers to do the same
   3. Correction. You have the right to request that we correct or amend certain Personal Information we maintain about you if it is inaccurate.
   4. Limit. You have the right to request that we limit the use and disclosure of Sensitive Personal Information we have collected. If Centre Partners collects any sensitive personal information, it will use it only for purposes listed above in Section 3(F). As such, any sensitive personal information that we collect does not come within this right to limit use.
   5. Opt-out. You have the right to opt out of the sale of your Personal Information to third parties and/or the sharing of your Personal Information for certain purposes. As noted above, we do not sell or share Personal Information to or with third parties.
   6. Non-Discrimination. You have the right to not experience discriminatory treatment, and we will not discriminate against you, because you have exercised any California consumer privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.

2. How To Submit a Request. You may submit a request by using one of the following methods.

   1. Email. Email us at info@CentrePartners.com
   2. Call. Call us at (212) 332-5800

3. Verifying Your Request. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we are unable to verify your identity, we will need to deny your request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

   1. Consumer Verification. If you request to know, access, delete and/or correct your Personal Information, we may require you to provide any of the following information: address, date of birth, state or country of residence, telephone number, email address or details of a transaction. In addition, if you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. We will use the information you submit and the information we have in our systems to try to verify your identity and to match the Personal Information we have collected about you, if any, to your identity.
   2. Authorized Agent. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (a) provide the authorized agent written permission (e.g., via a notarized letter) to do so, and (b) verify your own identity directly with us (as described above), and confirm with us that you provided the authorized agent permission to submit the request.
4. Additional California Privacy Disclosures.
   1. Shine the Light Notice. California residents may request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in Section 4(B), above.