Financial institutions like Black Tower Capitals Group Advisors LP and our affiliates and subsidiaries (collectively “Black Tower Capitals Group,” “we,” or “us”) may be required to provide privacy policy notices when we hold personal information relating to individuals, as defined below (“Personal Information”).  We believe that protecting the privacy of Personal Information is of the utmost importance. It is our policy to safeguard the privacy, confidentiality and security of Personal Information and to comply with the applicable data protection laws, including SEC Regulation S-P and state regulations pertaining to Personal Information.  It is also our policy to process Personal Information in accordance with the General Data Protection Regulation 2016/679 (the “GDPR”) where applicable. We process Personal Information lawfully, fairly and in a transparent manner in relation to you and ensure that the Personal Information which we process is relevant, accurate and limited to what is necessary in relation to the purposes for which it is processed, and that Personal Information is kept confidential.  We have in place appropriate technical and organizational measures to ensure security of Personal Information, including protections against unauthorized access, use, disclosure, acquisition, destruction or alteration, misuse, damage or accidental loss.

In compliance with applicable laws, this notice is to provide you with information about Personal Information we process, the rights you can exercise with regard to Personal Information we process, the periods for which Personal Information will be stored and the persons and entities with which we may share Personal Information.

Personal Information is information about you that makes you personally identifiable.  This includes, without limitation, your name, contact information such as your address, e-mail address and phone number, date and place of birth, gender, country, as well as your social security number, assets, income, investment experience or any other identifying information you may send us in your interactions with us.  We may also collect business information such as your job function and title, department, organization name and location.

If you are an investor or prospective investor, we collect Personal Information about you from the following sources:

1. information we receive from you on fund subscription documents and related forms;
2. information we receive from you when you make an additional subscription;
3. information you provide to us in general correspondence with us;
4. information you provide to us as part of any onboarding or due diligence process;
5. information we receive when you make transactions with us or our affiliates (for example, account activity and balances);
6. publicly available information we may find;
7. information we receive from third parties (for example, from an individual who introduces you to us); and
8. to a limited extent, information we receive when you provide your contact details via our website.

If you are an investor, we will process your Personal Information for one or more of the following purposes and on the following legal grounds:

1. to perform services on behalf of Black Tower Capitals Group funds or to take steps at your request prior to entering into a contract with you, such as to provide requested information about our services, to facilitate the opening of your account with us, and for the management and administration of your holdings on an on-going basis to the extent that doing so is necessary, including, without limitation, the processing of redemptions, conversions, transfers, additional subscription requests, the payment of distributions and to keep you updated in relation to your investments;
2. to carry out anti-money laundering checks and related actions which we consider appropriate to meet any legal, regulatory or judicial obligations imposed on us or in relation to the processing of data in the public interest or in pursuit of our legitimate interests in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with our and (if applicable) Third Parties’ (as defined below) anti-money laundering procedures;
3. to report tax-related information to tax authorities in order to comply with any legal, regulatory or judicial obligations;
4. to engage in, monitor and record telephone calls and electronic communications for our legitimate interest of: (i) processing and verification of instructions; (ii) investigation and fraud prevention purposes; (iii) crime detection, prevention, investigation and prosecution; (iv) enforcing or defending us and our affiliates, ourselves or through Third Parties to whom we may delegate such responsibilities or rights in order to comply with any legal, regulatory or judicial obligation imposed on us; or (v) where the processing is in the public interest;
5. to disclose information to Third Parties (as defined below) and parties such as other service providers to us, regulatory authorities and technology providers in order to pursue our legitimate interest to comply with any legal or regulatory obligation, court order or judicial request imposed on us;
6. to engage in, monitor and record telephone calls for quality, business analysis, training and related purposes in order to pursue our legitimate interests to improve service delivery;
7. to pursue our legitimate interest of improving our services to you, providing you with investment services and information relating to investment services, making our procedures more efficient, or implementing security measures;
8. to update and maintain records and fee calculations to meet legal, regulatory or judicial obligations and to retain anti-money laundering and other records.

We do not disclose any Personal Information we collect, as described above, about our current or former investors to anyone other than to administrators, custodians, banks and service providers (including but not limited to our IT service providers, email archivists and CRM system providers) in connection with the administration, processing and servicing of customer accounts or to our accountants, attorneys and auditors (all such persons, collectively, “Third Parties”), or otherwise as required by law.  We may also disclose personal information with non-affiliated entities and regulatory authorities as permitted by applicable law.  For example, we may disclose such information to cooperate with, including but not limited to, regulatory authorities and law enforcement agencies as necessary to protect our rights and property.  

If you are not an investor, we collect Personal Information about you on the following occasions:

1. when you use our services;
2. when you register to attend an event;
3. when you apply for a job with us;
4. when you propose an investment to us;
5. when we retain you as a service provider or you solicit us to do so; or
6. when you otherwise communicate with us or contact us via our website.

In this case, we will process your Personal Information for one or more of the following purposes and on the following legal grounds:

1. to provide information you request about us and our services; as is necessary to take steps at your request prior to entering into a contract with you;
2. to evaluate investments or services you propose to provide to us and to communicate with you regarding such investments or services; as is necessary to take steps at your request prior to entering into a contract with you;
3. to provide communications (such as publications, educational materials) to you relating to products and services you are interested in;
4. to provide information about our events and conferences, as is necessary for our legitimate interest of providing a service you have requested and expect to receive from us;
5. to secure and optimize our website experience;
6. for our recruitment and employment processes; the Personal Information we process about you in this case may also include your experience, education, diplomas, job skills and other information contained in your curriculum vitae and your cover letter. Processing in this case is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract with you.

We may disclose your Personal Information to third parties, such as service providers, business sponsors and partners, when and to the extent necessary for the purposes above.  Any such third party will not be allowed to further disclose your Personal Information, save where otherwise required or authorized by law.

Irrespective of whether you are or not an investor, we restrict access to Personal Information we collect about you to our personnel who need to know that information for the purposes above and who are subject to appropriate confidentiality obligations, or who are bound to confidentiality by statutory obligations.

You have the right to receive confirmation from us of whether or not we are processing your Personal Information and, if so, to obtain a copy of that Personal Information, as provided for by applicable law.  You also have the right to obtain the rectification of inaccurate Personal Information without undue delay.

Your Personal Information will be retained for the time necessary in relation to the purpose(s) for which such information is processed.  For example, we may retain limited amounts of your Personal Information to ensure compliance with a legal obligation to which we are subject or to market specific products and services.  If you are an investor, your Personal Information will be processed for as long as you remain an investor with us, and when you are no longer an investor, we will continue to process your Personal Information which has a minimal privacy impact for the time which is necessary in relation to the purpose(s) for which such information is processed.

Depending on the legal regime applicable to you, you may also have specific additional rights regarding your Personal Information. Please contact our Privacy Team if you wish to exercise any of the following rights:

1. Right to erasure: if at any time you decide you do not want us to retain any of your Personal Information, you may request we delete it. We will comply with your request subject to applicable laws and without undue delay.
2. Right to restriction of processing: you have the right to restrict how we process your data, in accordance with applicable laws.
3. Right to object: you have the right to object to our use of your Personal Information. We will consider your objection and we will comply with it unless we have a compelling legitimate ground to refuse, as provided for by applicable law.
4. Right to rectification: you have the right to obtain without undue delay rectification of inaccurate Personal Information concerning you.
5. Right to data portability: in certain circumstances, you have the right to ask us to transmit your personal data directly to another controller under specific circumstances, as provided for by applicable law.

You also have the right to lodge a complaint with our Privacy Team or a supervisory authority if you believe our processing of Personal Information infringes applicable data protection laws.

We have mechanisms and procedures designed to ensure that, in case of a data breach (i.e., the unauthorized access, use, disclosure, acquisition, destruction or alteration, misuse, damage or accidental loss of Personal Information):

1. we follow robust breach detection, investigation and internal reporting procedures;
2. where required by law, we notify the relevant supervisory authority of a data breach in accordance with the timing and modalities envisaged in applicable law;
3. where required by law, we inform you of any data breach in accordance with the timing and modalities envisaged in applicable law; and
4. we keep records of any data breaches.

Should any changes be made to our privacy notice, for example because we begin processing data for a new purpose, a new privacy notice, specifically devoted to the change(s), will be delivered.

For any questions, requests or complaints concerning your Personal Information, including for any requests relating to your rights as discussed above, you can contact the Black Tower Capitals Group privacy team.