GENERAL PRIVACY POLICY

We do not disclose non-public personal information about our clients/investors or former clients/investors to third parties other than as described below. We obtain non-public personal information about clients/investors from our discussions with you and from documents you deliver to us, including subscription documents as well as in the course of processing withdrawal/redemption requests or any other changes in your investment. This information may include your name, address, e-mail address, social security number or tax identification number, bank or brokerage account numbers, financial situation, subscription commitments, withdrawals, transaction history and other personal information.

We may use this information to provide services to you, to open an account for you, to process a transaction for you, including as is necessary in the course of making investments, processing subscriptions and withdrawals and otherwise administering our funds. In order to service your account and effect your transactions we may provide your personal information to our affiliates and to firms that assist us in servicing your account such as a clearing broker or fund administrator, and then only subject to customary undertakings of confidentiality. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements. We require third party service providers and financial institutions with whom we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. We do not otherwise provide information about you to outside firms, organizations or individuals except to our attorneys, accountants and auditors as permitted or required by law or regulations or order of any court of competent jurisdiction or pursuant to any direction, request or requirement (whether or not having the force of law) of any central bank or any regulatory, tax or other government agency or body.

We restrict access to non-public personal information about you to our employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect your personal information.

This Privacy Notice relates to Corbin Capital Partners, L.P. and the private investment funds it advises.
 

California Privacy Policy

This privacy policy for California residents (the “Policy”) supplements the general Privacy Policy and applies only to the data of California residents as required by the California Consumer Privacy Act of 2018 (the “CCPA”).  The purpose of this Policy is to provide you with a comprehensive description of our practices regarding the collection, use, disclosure, and sale of your personal information and of your rights regarding your personal information. 

“Personal Information” is information that identifies, relates to, describes, or is reasonably capable of being connected to you or your household.  Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We collect personal information by observing and tracking your interaction with our website.

• We do not sell your personal information to third parties under any circumstances.

1.       Description of Your Rights

You have the following rights under the CCPA:

• Disclosure of Personal Information We Collect About You
  • You have the right to know:
    • The categories of personal information we have collected about you;
    • The categories of sources from which the personal information is collected;
    • Our business or commercial purpose for collecting or selling personal information;
    • The categories of third parties with whom we share personal information, if any; and
    • The specific pieces of personal information we have collected about you.
  • Please note that we are not required to:
    • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
    • Provide the personal information to you more than twice in a 12-month period.

• Right to Deletion
  • Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
    • Delete your personal information from our records; and
    • Direct any service providers to delete your personal information from their records.
  • Please note that we may not delete your personal information if it is necessary to:
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
    • Debug to identify and repair errors that impair existing intended functionality;
    • Comply with the California Electronic Communications Privacy Act;
    • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
    • Comply with an existing legal obligation; or
    • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

• Protection Against Discrimination
  • You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
    • Deny goods or services to you;
    • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
    • Provide a different level or quality of goods or services to you; or
    • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
  • Please note that we may charge a different price or rate, or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to us by your personal information.

2.       Collection and Disclosure of Your Personal Information

• Information We Collect About You
  • We will collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

• How Your Personal Information is Collected
  • We collect this personal information from you:
    • via our IT systems, including:

•          automated monitoring of our websites and other technical systems, such as our computer networks and connections,

• Why We Use Your Personal Information
  • We use your personal information for the following reasons:
    • For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• Who We Share Your Personal Information With
  • We may share personal information with third parties we use to help us run our business, such as marketing agencies or website hosts.
• What Types of Personal Information Do We Disclose to Third Parties
  • In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose to the parties identified above:
    • Internet or other similar network activity.
• What Types of Personal Information Do We Sell to Third Parties
  • In the preceding 12 months, we have not sold personal information.

3.       Sale of Your Personal Information

• We do not sell your personal information to third parties under any circumstances.

4.       How to Exercise Your Rights

• How to Exercise Your Rights
  • If you would like to exercise any of your rights as described in this Privacy Policy, please:
    • Complete a data subject request form which will be made available upon request
    • Call us at 212-634-7373; or
    • Email us at clientservices@corbincapital.com.
  • Please note that you may only make a data access or data portability disclosure request twice within a 12-month period.
• Response Timing
  • We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
  • We will deliver our written response by mail or electronically, at your option.
  • Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
  • We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

• Verifying Your Identity
  • If you choose to contact us directly, you will need to provide us with:
    • Enough information to identify you (e.g., your full name, address and customer or matter reference number;
    • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
    • A description of what right you want to exercise and the information to which your request relates.
  • We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
  • Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

• Authorized Agent
  • You have the right to appoint an authorized agent to exercise your rights on your behalf.  If you want your authorized agent to exercise your rights on your behalf, we reserve the right to require that you:
    • Provide the authorized agent to act for you; and
    • Verify your own identity directly with us as described above.

5.       Additional Information

For any questions or concerns about this Policy, please contact:

John Maguire at jmaguire@corbincapital.com, 212-634-7342, Corbin Capital Partners, L.P., 575 Madison Avenue, 21^st Floor, New York, NY 10022

6.       Accessibility Information

For consumers with disabilities who need to access this Policy in an alternative format, please contact:

clientservices@corbincapital.com, Corbin Capital Partners, L.P., 575 Madison Avenue, 21^st Floor, New York, NY 10022