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As Published: May 20, 2022
This Privacy Notice explains the manner in which we collect, utilize and maintain nonpublic personal information about our Limited Partners. This Privacy Notice applies only to Limited Partners who are individuals.
We are committed to protecting your privacy and maintaining the confidentiality and security of your personal information. We are sending you this Privacy Notice to help you understand how we handle the personal information about you that we collect and how we use that information.
Categories of Information We Collect and May Disclose
We use the personal information collected about you in order to provide you with better service or to comply with law and regulations. We may collect nonpublic personal information about you from the following sources:
- Investor Questionnaires, Limited Partnership Agreements or other forms (for example, name, address, Social Security number, assets and income);
- Ownership records of the fund in which you are a Limited Partner (such as the amount of your percentage ownership interest and any Commitment); and
- Other interactions with us or our affiliates (such as discussions or other contacts with our staff, via telephone, written correspondence, and electronic media).
We may disclose nonpublic personal information we collect about you to our affiliates (including those who are involved in the operation, administration or management of, or the sale of interests in the fund of which you are a Limited Partner) and nonaffiliated service providers, only as permitted by law and regulations. For example, we may share nonpublic personal information about you in the following situations:
- In connection with the administration and operations of the fund of which you are a Limited Partner, including disclosure to attorneys, accountants, auditors, administrators, or companies that assist us with mailing statements or processing your transactions, or other professionals;
- To broker-dealers, custodians and transfer agents to facilitate in-kind distributions of portfolio securities;
- To respond to a subpoena or court order, judicial process or regulatory inquiry; and
- At your direction or with your consent, including upon your authorization to disclose such information to persons acting in a fiduciary or representative capacity on your behalf.
We may also share your personal information with other providers of services necessary or convenient to the formation, operation or dissolution of the fund of which you are a Limited Partner. Finally, as required or permitted by the Limited Partnership Agreement, we may distribute to all partners in such fund certain personal financial information, such as capital account information and various schedules to the Limited Partnership Agreement.
The information of our former Limited Partners is treated in the same manner as the information of our current Limited Partners.
Confidentiality and Security
We have always considered the protection of sensitive information to be a sound business practice and a foundation of customer trust. We protect personal information we collect about you by maintaining physical, electronic and procedural safeguards.
Within our management entities we restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you.
However, no method of transmission or storage of data is 100% secure and we will not be responsible for any damage that results from a security breach of data or the unauthorized access to or use of information. To the extent we provide your Personal Information to any third parties, we will request that they use reasonable security measures to protect your information.
A. Children’s Personal Information
Please note that we do not knowingly collect Personal Information relating to children. If we learn we have received Personal Information from a child under 13 without verified parental consent, we will endeavor to delete that information.
B. Our Retention Policies
Personal data may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations, or where longer, such longer period as is required by applicable legal or regulatory obligations. Personal data will be retained throughout the life cycle of any investment in a Fund. Some personal data will be retained after you cease to be an investor in a Fund.
We may be allowed to retain Personal Information for a longer period if you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Information will be deleted.
We reserve the right to change this Privacy Notice at any time. The examples contained within this notice are illustrations and are not intended to be exclusive. This notice complies with United States federal law regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you.
This Privacy Notice, together with all supplemental privacy notices, complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that apply to you, including as set forth in our supplemental privacy notices. This Privacy Notice replaces any earlier version.
How to Contact Us
For any questions or concerns about this Privacy Notice or to make a request regarding your Personal Information, please contact us via email at email@example.com.
CALIFORNIA PRIVACY NOTICE SUPPLEMENT
If you are a California resident, then you also have the following rights under the California Consumer Privacy Act (“CCPA”) regarding your Personal Information. The California Consumer Privacy Act of 2018 (“CCPA”) exempts information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (“GLBA”), and its implementing regulations, or the California Financial Information Privacy Act.
Right to Know
You have the right to know and see what Personal Information we have collected about you over the past 12 months, including:
- The categories of Personal Information we have collected about you;
- The categories of sources from which the Personal Information is collected;
- The business or commercial purpose for collecting your Personal Information;
- The categories of third parties with whom we have shared your Personal Information; and
- The specific pieces of Personal Information we have collected about you.
Right to Delete
You have the right to request that we delete the Personal Information we have collected from you. There are a number of exceptions, however, that include, but are not limited, to when the information is necessary for us or a third party to do any of the following:
- Complete your transaction;
- Provide you a good or service;
- Perform a contract between us and you;
- Protect your security and prosecute those responsible for breaching it;
- Fix our system in the case of a bug;
- Protect the free speech rights of you or other users;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
- Comply with a legal obligation; or
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
Sale of Your Personal Information
We do not sell your Personal Information for money or other consideration of value.
More information about your rights as a California consumer may be found on California’s Department of Justice website.
Robust Does Not Discriminate
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 access or deletion request rights, please submit a verifiable consumer request to firstname.lastname@example.org.
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 your investor portal access credentials in order to verify your request. You may also 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.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not be able to respond to your request or provide you with specific pieces of Personal Information if we cannot verify your identity and authority to make the request.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. Please contact email@example.com with any questions about this Privacy Notice.
Our Websites may contain links to other outside websites. Please be aware that we are not responsible for the content or privacy practices of such other websites. We encourage you to be read the privacy statements of any other website that collects information of visitors.
“Robust Ventures”, “Robust”, the Robust logo, tagline and “R” logomark are registered trademarks of Robust Labs, LLC.