Collection of Information: We may collect nonpublic personal information and other personal information about you to facilitate your investments and for our business and commercial purposes. For purposes of California residents only, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), personal information includes 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. “Personal data” for the purposes of this notice includes nonpublic personal information and personal information as defined under the CCPA with regard to California residents.
We may collect the following types of personal data from or about you:
- Identifiers and similar information, including name, date of birth and birthplace, contact details, location of residence, citizenship, social security number, tax status, government identification (including passport and drivers’ license), online identifiers or other similar identifiers;
- certain information protected under federal or state laws, including signature, bank account, and other financial information, including other information contained in documents provided by investors to authorized service providers (whether directly or indirectly);
- characteristics of protected classifications under federal or certain state laws, including gender, national origin, and marital status;
- commercial information, including records of products or services purchased or other purchasing histories or tendencies, including a potential and/or actual investment in the applicable fund(s) (e.g., ownership percentage, capital investment, income and losses), accounts and transactions with other institutions, source of funds used to make the investment in the applicable fund(s), risk tolerance, transaction history, investment experience, and investment activity;
- internet or other electronic network activity information, including your use of our website, fund data room and investor reporting portal;
- professional or employment-related information, including occupation, compensation, employer, title, or professional contact information (including physical address, email address, telephone number and name of employer);
- information regarding investors’ status under various laws and regulations, including income and assets, as well as anti-money laundering and verification documentation; and
- inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, such as information on your potential interest in investing in new funds.
Sources of Information: We may collect and maintain the above categories of personal data from you and/or your intermediaries from the following sources:
- Information we receive via written, electronic, or verbal correspondence with us or our service providers, including over the telephone, in voicemails, through written correspondence, or via e-mail;
- Information we receive in subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation);
- Information about your transactions with us or others;
- Information we receive from your brokerage or other financial advisory firm, financial advisor, or consultant; and/or
- Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms and any information captured via “cookies.”
In addition, we also may collect personal data through or from different sources, such as our affiliates and our or their service providers; public websites or other publicly available sources like government records; or from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.
Purposes for Collecting and Using Information: We may collect or use your personal data for the following business or commercial purposes:
- performing services to you, including but not
- the administrative processes (and related communication) in preparing for the admission of investors to the fund(s);
- ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund;
- the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
- ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal data, processing contributions and distributions and financing, and communicating with investors;
- keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
- auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
- detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and
- complying with federal, state, local and non-U.S. laws, rules and regulations.
Disclosure of Information: We may share all of the information that we collect, as described above, with our affiliates in order to service your account or provide you with information about services that may be of interest to you. Otherwise, we do not disclose any personal data about you, except: (i) to service providers, including administrators, banks, auditors, law firms, consultants and placement agents; (ii) at your request or direction or with your consent; and/or (iii) as otherwise permitted or required by law or regulation, including, but not limited to, governmental organizations and self-regulatory organizations.
Former Investors: We maintain personal data of our former investors and apply the same policies that apply to current investors.
Information Security: We will take reasonable steps and use security measures appropriate to the nature of the information and that comply with applicable laws to protect investors’ personal data against unauthorized access and exfiltration, acquisition, theft, or disclosure. Given the nature of information security, there is no guarantee that such safeguards will always be successful.
Rights to Investors to limited sharing: We may share nonpublic personal information with affiliated funds to market to you. Federal law gives you the right to limit some but not all marketing from our affiliates. To limit sharing of nonpublic personal information to our affiliates to market to you, please send an email to IR@opeaklp.com with the subject line “Do Not Share Marketing information with Affiliates” that includes the statement “Do not share my nonpublic personal information with your affiliates to market their products or services to me.”
State law and individual companies may give you additional rights to limit sharing.
Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time. The examples contained within this Notice are illustrations only and are not intended to be exclusive. You may have additional rights under other foreign or domestic laws that may apply to you, including as set forth in our additional privacy notices.
NOTICE TO RESIDENTS OF THE STATE OF CALIFORNIA
This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the CCPA to natural person California residents and provides information regarding how such California residents can 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. 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. We are a “business.” “Personal information” for the purposes of this section has the same meaning as in the CCPA. It does not include deidentified information, aggregate consumer information, or publicly available information (as defined in the CCPA).
We do not sell your personal information. We may disclose your personal information to our service providers or other entities that have agreed to limitations on the use of your personal information or that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA. In the preceding 12 months, we may have disclosed for a business purpose all or some of the same categories of personal information listed above in the section “Collection of Information.”
Notice: You have the right to 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.
Deletion: 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 federal, state, local and non-U.S. laws, rules and regulations.
Access to Information: 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 was 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
- The categories of personal information we disclosed about you for a business purpose.
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 CCPA Rights: To exercise any of your rights under the CCPA, please submit a request using any of the methods set forth below.
Option 3: Email us at email@example.com.
We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. Any information gathered as part of the verification process will be used for verification purposes only.
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. 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.
NOTICE TO INVESTORS IN OUR CAYMAN ISLANDS FUNDS
Olympus Peak maintains policies and procedures in order to comply with Data Protection Law, 2017 of the Cayman Islands (“Cayman Islands DPL”). This section applies to investors in our Cayman Islands funds. Cayman Islands DPL – Collection and Use of Personal Information.
Olympus Peak collects and uses personal data as set forth above for all clients, prospective clients, and business located within and outside the Cayman Islands. Olympus Peak deems it to be reasonably necessary to collect such personal data in order to effectively operate its business or comply with applicable law. As such, Olympus Peak collects, uses and retains such personal data in furtherance of legitimate business purposes.
Olympus Peak may disclose personal data as set forth above. Such third parties may reside within or outside the Cayman Islands. When transferring personal data from within the Cayman Islands to outside the Cayman Islands, we adopt means reasonably expected to ensure that adequate safeguards are applied in compliance with Cayman Islands DPL standards.
If you would like to receive a copy of our DPL privacy notice, please email us at firstname.lastname@example.org.