Privacy Policy

At Waterton Associates L.L.C. and its respective subsidiaries and affiliates (‘Waterton’), we are committed to maintaining the confidentiality of your personal and financial information. The purpose of this Privacy Policy is to explain the types of Personally Identifiable Information or Non-Personally Identifiable Information Waterton collects, how the information is obtained, how it is used, and the choices you have regarding our use of, and your ability to review and correct, the information.

This Privacy Policy applies for all business activities of Waterton, including users accessing our Web sites (‘Sites’) or parties engaging in communications or transactions with Waterton.

What Information We Collect

The information we collect in our business and on our Sites generally falls into the following two categories: Personally Identifiable Information and Non-Personally Identifiable Information.

  • Personally Identifiable Information: This refers to information that lets us know the specifics of who you are.
  • Non-Personally Identifiable Information: This refers to information that does not by itself identify a specific individual. The non-personally identifiable data we collect in our business may include aggregated statistical data or data not attributable to specific person or entity. Non-personally Identifiable Information we collect when you visit our Sites may include the Uniform Resource Locator (“URL”) of the Web site that you came from before visiting our Sites, which pages you visit on our Sites, which URL you go to next, which browser you used to come to our Sites, your Internet Protocol (“IP”) address, and any search terms entered on our Sites. This Privacy Policy also contains more information about how we use cookies and other technology to collect this data.

We do not connect the Personally Identifiable Information and Non-Personally Identifiable Information we collect in our business or on our Sites.

Why We Collect Information About You

Our primary goals in collecting information are to provide clients with superior service and to provide all individuals a smooth, efficient, and personalized experience.

How We Collect Information

We may request Personally Identifiable Information when you request information or correspond with us. When you contact our Investor Services department for assistance, or invest in a new program with us, we may ask for Personally Identifiable Information to fulfill your requested service and to contact you in the future.

Our Web servers may automatically recognize a visitor’s domain name (such as .com, .edu, etc.), the Web page from which a visitor enters our site, which pages a visitor visits on our site, and on some sites, how much time a visitor spends on each page. This information does not reveal a visitor’s identity. We aggregate this information and use it to evaluate and improve our Sites.

Whether you choose to provide specific information requested by Waterton is completely your own choice. But if you choose not to provide the information we request, you may be unable to receive or access certain services, offers, and information.

Using Information About You

Waterton does not sell or share customer information to marketers outside of our companies, without your consent.

We may share your Personally Identifiable Information with others only in certain limited situations: (i) within our corporate group or among our affiliated entities, all of which follow this Privacy Policy or equivalent privacy policies; (ii) with our service providers or other parties who agree to keep the information confidential and use it only on behalf of the Waterton; (iii) if your investment is transferred to another custodian, we provide your general information, tax identification number and other transfer documents to the custodian taking over the investment on your behalf; and (iv) as otherwise agreed by you.

In some cases, we may be required to disclose certain information to comply with the law, an investigation or a legal process, such as a court order or subpoena. We may disclose information when we believe that such a release is reasonably necessary to enforce or protect our rights.

Cookies and Other Technology on our Sites

Our Sites use “cookies” and other technology to enhance your online experience and to learn about how you use the Sites for purposes of improving the quality of services.

Protecting Your Information

Our policy is to restrict access to your Personally Identifiable Information to only those employees, service providers, and other third parties who need to know that information to provide products or services to you. We maintain commercially reasonable physical, electronic and procedural safeguards and other applicable standards as required by law.

Links to Third Party Sites

Our Sites may contain links to Web sites operated and maintained by third parties, over which we have no control. Privacy policies on such linked sites may be different from our Privacy Policy. You access such linked sites at your own risk. You should always read the Privacy Policy of a linked site before disclosing any personal information on such site.

Policy Changes

To improve the services we can offer you, Waterton may opt to expand our capabilities for obtaining information about users in the future. Waterton will update this privacy statement continually to ensure that you are aware of developments in this area.

We will post those changes here so that you will always know what information we collect online, how we use it, and what choices you have. Please be sure to check this page before proceeding to use our Sites. Regardless of any changes we make to our Privacy Policy, we will always use your Personally Identifiable Information in accordance with the version of the Privacy Policy in place at the time you provided your information, unless you give your express consent for us to do otherwise.

Additional Privacy Terms

In conducting business with Waterton or using the Sites, you may be required to agree to additional written or electronic agreements, including additional privacy terms and conditions (‘Additional Privacy Terms’), as a condition of visiting the Sites, or receiving products, services, and other information. In the event of any conflict between the Additional Privacy Terms and this Privacy Policy, the Additional Privacy Terms shall prevail.

Business Transfers

As Waterton continues to develop the business, we may sell or buy entities, subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets. Such information remains subject to any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). In the event that Waterton is acquired in whole or in part, Personally Identifiable Information may be one of the transferred assets.

Your Feedback

To help us improve our Privacy Policy and practice, please give us your feedback utilizing the “Contact us” tab.

Legal Disclaimer: This is neither an offer to sell nor a solicitation of an offer to buy the securities herein. Offerings are made only by means of a prospectus or other offering materials. This material must be preceded or accompanied by a prospectus or other offering materials. This information may not be redistributed, copied or modified in any form without prior written consent from Waterton.

Waterton Associates
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