LEGAL DISCLAIMER

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The content of RCP Advisors’ website (the "Website") is intended solely to provide general information regarding RCP Advisors' business. RCP Advisors provides investment advisory services to a limited number of clients; it does not offer or make available such investment advisory services to the general public.

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The information provided on the Website does not constitute, and is not intended as, an offer or sale of any security or investment product or investment advice. Offerings are made only pursuant to a private offering memorandum containing important information regarding risk factors, performance and other material aspects of the applicable offering; the information contained herein should not be used or relied upon in connection with the purchase or sale of any security. The information provided on the Website is not intended to be relied upon as investment advice or to be construed as legal, business or tax advice. References herein to RCP Advisors' specific investment strategies are not to be considered a recommendation or solicitation for any such investment strategy or for any fund investment. The information provided on the Website does not constitute a representation that any such investment strategy or fund investment is suitable or appropriate for any person.

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The information contained on the Website has been prepared by RCP Advisors or obtained from sources believed to be reliable and current, but accuracy cannot be guaranteed. Past performance is not a guarantee of future results. Projections or forward looking statements contained on the Website are only estimates of future results or events that are based upon assumptions made at the time such projections or statements were developed or made. There can be no assurance that the results set forth in the projections or the events predicted will be attained, and actual results may be significantly different from the projections. Also, general economic factors, which are not predictable, can have a material impact on the reliability of projections or forward looking statements. Target allocations and objectives described in the Website are targets and objectives only, and there can be no guarantee that such target allocations or objectives will ultimately be achieved.

 

RCP ADVISORS PRIVACY NOTICE - EU INVESTORS

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RCP Advisors, LLC

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RCP Advisors 2, LLC

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RCP Advisors 3, LLC

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(collectively, “RCP Advisors”)

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Background

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RCP Advisors (“RCP,” “we”, “us” or “our”) respects your privacy and is committed to protecting your personally identifiable information (“Personal Data”). We are sensitive to the privacy concerns of those individuals about whom we process Personal Data (including our individual limited partners, investors, clients, and prospective and former investors and clients). This privacy notice (this "Privacy Notice") will inform you as to how we look after your Personal Data and tell you about your privacy rights and how the law protects you.

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It is important that you read this Privacy Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing your Personal Data, so that you are aware of how and why we are using such information.

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We reserve the right to update this Privacy Notice at any time. We may also notify you in other ways from time to time about the processing of your Personal Data.

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Applicability

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This Privacy Notice applies to the processing of Personal Data of identified or identifiable natural persons (“Data Subjects”) who are residents of a member state of the European Union (“EU”) or the European Economic Area (“EEA”).

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This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the “GDPR”), as well as any law or regulation relating to the protection of Personal Data applicable to them, as any of such instruments may be modified or complemented from time to time (together, the “Data Protection Legislation”).

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We are required under the Data Protection Legislation to notify you of the information contained in this Privacy Notice. If the Data Protection Legislation applies to you, you have certain rights with respect to your Personal Data, as outlined in greater detail below. It applies to:

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• individuals with whom RCP may have had contact for business purposes, either on our own account or on behalf of third parties or organizations;

• individuals who are employed by or otherwise associated with RCP’s suppliers, vendors or professional advisors;

• individuals who are involved in transactions or potential transactions which are evaluated or conducted by RCP or any of RCP’s affiliates; and

• individuals who have opted to receive communications from RCP.

 

RCP makes available separate privacy notices which apply to individuals associated with investors in the funds managed or sponsored by RCP. This Privacy Notice does not form part of any contract for services.

 

Responsible RCP Entities

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RCP is made up of different legal entities (the “RCP Group”), as outlined in greater detail below.

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This Privacy Notice is issued on behalf of the RCP Group, so when we mention “RCP,” “RCP Advisors,” “we,” “us” or “our” in this Privacy Notice, we are referring to the relevant entity in the RCP Group responsible for processing your Personal Data.

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For the purposes of the Data Protection Legislation, the RCP entity that you have dealings with is the controller of your Personal Data. This means that we are responsible for deciding how we collect, use, share and retain your Personal Data. We are required under the Data Protection Legislation to notify you of the information contained in this Privacy Notice.

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If you have any questions regarding our use of your Personal Data or this Privacy Notice, including any requests to exercise your legal rights, please contact RCP’s Chief Compliance Officer:

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Name: Nell M. Blatherwick

Email:  dataprotection@rcpadvisors.com

Telephone: 312.266.7300

Address: 353 N. Clark Street, Suite 3500, Chicago, IL 60654

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We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority (e.g., in Luxembourg, the Commission Nationale pour la Protection des Données – www.cnpd.lu). We would, however, appreciate the chance to deal with your concerns before you approach the relevant data protection authority, so please contact us in the first instance.

 

PRIVACY STATEMENT

 

The following privacy statement is issued by RCP Advisors, LLC, RCP Advisors 2, LLC, and RCP Advisors 3, LLC (collectively, “RCP”) and each of the private equity funds (collectively, the “Funds”) managed or advised by RCP.

 

RCP considers privacy a fundamental right of the Funds’ investors and its clients, and takes seriously the obligation to safeguard investor and client information. Accordingly, we do not share any non-public personal information and/or personally identifiable information (“Personal Data”) of any current or former investor or client with any unaffiliated third parties, except as permitted by law, as authorized by our investors and clients and/or as described below.

 

Sources of Personal Data

 

Personal Data is collected directly from you when you:

 

• Enter into a subscription agreement or advisory services agreement;

• Engage in transactions related to your account;

• Visit RCP’s website;

• Enter information on RCP’s website; or

• Contact RCP

 

Categories of Personal Data

 

The Personal Data collected by RCP includes:

 

• Identifiers (name, email, address, phone number, date of birth, organization name, usernames, identity of authorized representatives)​

  • RCP uses identifiers to facilitate our relationship with you, contact you, comply with contractual obligations, make you aware of other products that may interest you, and comply with RCP’s legal and regulatory obligations.

 

• Personal information (Social Security number, tax identification number, passport number, driver’s license number)

  • RCP uses personal information to comply with contractual obligations, administer and manage your investments and account(s), verify your information, make capital calls, payments or distributions, administer the affairs of a private fund, and comply with RCP’s legal and regulatory obligations.

 

• Characteristics of protected classifications (gender, age, nationality)

  • RCP uses characteristics of protected classifications to comply with RCP’s legal and regulatory obligations.

 

• Financial information (bank account information, credit information, net worth, assets, investments, wire transfer instructions, account balances, source of wealth)

  • RCP uses financial information to comply with contractual obligations, administer and manage your investments and account(s), verify your information, make capital calls, payments or distributions, administer the affairs of a private fund, comply with RCP’s legal and regulatory obligations, perform accounting, billing, legal or tax audits, comply with RCP’s internal compliance requirements, maintain books and records, identify and prevent fraud and other unlawful activity, conduct credit and financial due diligence, and manage RCP’s legal, operational, financial, commercial, and investment risks.

 

• Internet or other electronic network activity information (platform/devices used, session analytic information, language, country, city, browser, operating and network system, service provider)

  • RCP uses internet or other electronic network activity information to monitor user behavior on RCP’s website and improve RCP’s website capabilities and service offerings.

 

• Professional or employment-related information (employment history, income)

  • RCP uses professional or employment-related information to verify your information, comply with RCPs legal and regulatory obligations, comply with internal compliance requirements, identify and prevent fraud and other unlawful activity, conduct credit and financial due diligence, and manage RCP’s legal, operational, financial, commercial, and investment risks.

 

• Education information (education history)

  • RCP uses education information to verify your information, comply with RCP’s legal and regulatory obligations, comply with internal compliance requirements, identify and prevent fraud and other unlawful activity, conduct credit and financial due diligence, and manage RCPs legal, operational, financial, commercial, and investments risks.

 

With Whom We Share Personal Data

 

RCP does not sell any of your Personal Data, including your name, mailing address or email address to any companies.

 

In the course of providing investment products and services to you, we collect non-public personal information about you from sources such as subscription agreements or advisory services agreements and related documents as well as from transactions related to your account. In the normal course of serving our investors and clients, the information we collect may be shared with companies that perform various services such as custodians, accountants, attorneys, broker-dealers and financial institutions as well as with governmental agencies. Specifically, we may disclose to these service providers all non-public information we collect, including:

 

• Information we receive on subscription agreements or other forms, such as an investor’s or client’s name, address, telephone number, social security or tax identification number, amount of investment(s), and bank account information; and

• Information about transactions with us, such as an investor’s or client’s capital account balance and other account data.

 

Finally, as required or permitted by the Funds’ respective partnership agreements, we may distribute to the investors in a Fund certain non-public personal information of the investors, such as commitment amounts and addresses, which may be recorded in schedules attached to such Fund’s partnership agreement.

 

Any service provider or organization receiving your personal information will be authorized to use such information only to perform the services required and as permitted by applicable law. Access to investors’ and clients’ non-public personal information is restricted to those employees and managers of RCP who require access to provide services to the Funds and their investors and to the firm’s clients. RCP maintains physical, electronic and procedural safeguards to protect non-public personal information. Investors’ and clients’ right to privacy extends to all forms of contact with RCP, including telephone, written correspondence and electronic media, such as the Internet.

 

Before RCP may disclose non-public personal information about any of its clients or the Fund’s investors to a non-affiliated third party other than a service provider and other than pursuant to one of the exceptions under Regulation S-P, RCP must provide each client and investor an initial privacy policy notice and an opt-out notice. The opt-out notice would describe the RCP’s planned disclosures and give clients and investors a reasonable opportunity to decline permission to make those disclosures. Because RCP does not disclose non-public personal information to non-affiliated third parties, other than service providers or pursuant to the exceptions, RCP is not required to provide opt out notices.

 

Retention of Data

 

RCP will keep your Personal Data only for as long as reasonably necessary to fulfill the purposes for which Personal Data is collected as stated herein; for as long as is necessary for the performance of the contract between you and RCP, if any; and to comply with legal and statutory obligations, such as in tax, trade and corporate laws. When RCP no longer needs your Personal Data for our purposes, RCP will destroy, delete or erase that Personal Data or convert it into an anonymous form.

 

Security of Data

 

RCP will take reasonable steps to protect your Personal Data in our possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction. For example, RCP uses security measures including safeguarding and monitoring our network and controlling access to our files, equipment, and buildings.

 

California Privacy Rights

 

If you are a resident of the state of California, the following rights are available to you under the California Consumer Privacy Act.

 

Right to access

 

You have the right to request that RCP disclose the categories of Personal Data collected, the categories of sources from which Personal Data is collected, the business or commercial purpose for collection, the categories of third parties with which RCP shares Personal Data, and the specific pieces of Personal Data that RCP has about you.  You also have the right to request that RCP provide your Personal Data to you in a readily useable format.

 

Right to request deletion

 

You have the right to request that RCP delete Personal Data that RCP collected from you.  Note, however, that certain requests to delete Personal Data may be denied if RCP is required to retain the information as a matter of law, the information is necessary for detecting security incidents, exercising free speech, protecting or defending against legal claims, or for internal uses reasonably aligned with consumer expectations.

 

Right to non-discrimination

 

You have the right not to receive discriminatory treatment by RCP for exercise of these privacy rights.  RCP does not offer financial incentives related to the provision of data.

 

Authorized agent

 

You have the right to designate an authorized agent to make these requests on your behalf.

 

Exercising your rights

 

To exercise any of these rights, please call our toll-free number at 866-758-1231 or contact us via email at dataprotection@rcp.com.  RCP may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

 

Updates to this Privacy Notice

 

RCP reserves the right to change our privacy policies and this Privacy Statement at any time. This notice is intended to comply with the privacy provisions of applicable U.S. federal law as well as the California Consumer Protection Act. You may have additional rights under other foreign or domestic laws that may apply to you.

 

For questions concerning this policy, please contact Nell Blatherwick at 312-266-7300 or via email at nblatherwick@rcpadvisors.com.

 

This Privacy Notice was last updated on January 1, 2020.