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Website Privacy and Cookie Policy

Last updated July 10, 2024

Rockpoint Group L.L.C., together with its subsidiaries and affiliates (“Rockpoint”, “we”, “us”, or “our”) are committed to protecting your personal information. This privacy and cookie policy (“Policy”) applies to your use of our public websites (collectively, the “Site”) and/or when you otherwise interact with us, such as when you visit our premises, apply for employment, and make inquiries to us, including via our Site (the “Services”). The privacy of your personal information is important to us at Rockpoint.

To provide you with Services you may request, it may be necessary for us to possess some personal information of yours. Similarly, without some of that information, we cannot inform you about the Services we have available or that you may request. This Policy explains our personal information policies and practices. It includes, but is not limited to, explanations of the types of information we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, your rights regarding your personal information, and the way to contact us to exercise those rights.

By visiting this Site or our premises, using our Services, applying for a job with us and/or otherwise providing information to us such as via email, you acknowledge that your personal information will be processed in accordance with this Policy, which may be updated by us at any time. If we update this Policy, we will post the updated version here. Any such changes will be effective upon posting. We urge you to review this Policy each time you visit our Site or our premises, use our Services, apply for a job with us and/or otherwise provide information to us such as via email. If you do not agree with any provision of this Policy, you should not use our Site or our Services, visit our premises, apply for a job with us or otherwise provide information to us such as via email. This Policy also does not apply to any other third-party website, including those that may be linked to in our website. We do not control the privacy policies or practices of others. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.

1. Your Acceptance Through Use

This Policy describes how Rockpoint collects, uses, and discloses certain personal information obtained through visiting this Site or our premises, using our Services, applying for a job with us and/or otherwise providing information to us such as via email. Please note that, to the extent permitted by applicable law, your visiting this Site or our premises, using our Services, applying for a job with us and/or otherwise providing information to us such as via email signifies your understanding and acceptance of the terms of this Policy. This Policy is incorporated into, and is part of, the Terms and Conditions, which govern your use of the Site in general.

2. Types and Use of Personal Information We Collect

We may collect and process the following personal information about you:

  • Identifiers, such as your full name, address, e-mail address, phone number and social security number;
  • Professional information (e.g., employment details, education information, occupational history or business relationships, references, any other information provided on your CV or cover letter or otherwise provided as part of your application process);
  • Usernames and passwords and account information (for investor portal);
  • Cookies and site usage information;
  • Audio, electronic, visual or similar information, including photographs and CCTV footage;
  • Physical access data relating to details of your visits to our premises;
  • Background check information;
  • Sensitive personal information, such as your social security number and health information (e.g., proof of COVID vaccination for visitors to our premises);
  • Commercial information and financial information;
  • Other information you provide, or which may be incidentally processed, when you contact us;
  • Feedback submitted to Rockpoint for support; and
  • Interests and communication preferences.

If you provide us with personal information, such as to fulfill a Service, we may collect, process, or disclose your personal information for a variety of purposes including:

  • To open an account(s) for you;
  • For our everyday business purposes such as to process your transactions, and maintain your account(s);
  • To process a transaction for your account(s), or otherwise in furtherance of our business;
  • To perform obligations under the subscription agreement (including all applicable anti-money laundering, know your customer and other related laws, rules, and regulations), including in connection with assessing suitability of potential investors;
  • For our legitimate business purposes or those of a third party, that are connected to our relationship with you such as, to operate, manage, develop and promote our business, Site and premises, to monitor access to the Site and to protect our business from fraud, money laundering and other financial or business crimes, and to screen, identify and evaluate candidates for job positions, including conducting background checks;
  • For administrative processes (and related communications) carried out in preparing for the admission of investors;
  • For ongoing communication with potential investors, their representatives, advisors, and agents, (including the negotiation, preparation and execution of documentation) during the process of admitting potential investors;
  • For ongoing administrative, accounting, reporting and other processes and communication required to operate our business in accordance with the agreements and other applicable documentation among the parties;
  • To keep investors informed about the business of the general partner of the applicable Fund and its affiliates generally, including offering opportunities to make additional investments;
  • To the extent necessary to perform a contract with you;
  • To the extent necessary to comply with any applicable legal or regulatory requirement to which we are subject;
  • To contact you and respond to your requests and inquiries; and
  • For any other purpose that has been notified or has been agreed between you and us.

3. Sources for Collected Personal Information

Rockpoint does not collect personal information about individual users that visit this Site or our premises, use our Services, apply for a job with us and/or otherwise provide information to us such as via email except:

  • when such personal information is provided to us on a voluntary basis;
  • to monitor traffic to the Site or our premises;
  • to determine the future direction of the Site including any necessary technical upgrades; and
  • to contact you regarding future services.

Additionally, we may collect information on our website from cookies, web beacons and similar technologies (together, “cookies”) when you or your devices access our online platforms or websites. For more information about the cookies we use and how to change your cookie preferences, please see section 9 below (“Our site and use of cookies”).

You may, however, provide your personal information to Rockpoint when you visit this Site or our premises, use our Services (e.g. subscription to our fund(s)), apply for a job with us and/or otherwise provide information to us such as via email. In such cases, the information we collect about you (such as your name, address, social security number, assets and income) are from:

  • our discussions with you and/or otherwise provided by you, including information provided through online forms;
  • your visits to our premises;
  • account, subscription and qualification documents that you may deliver to us; and
  • information disclosed while providing advisory services for you.

We may receive information about you from other sources and combine that information with the personal information we collect directly from you. For example, we may obtain personal information from:

  • The organization you use to pay us in order to correct our records;
  • From credit agencies, fraud prevention and detection agencies/organizations;
  • Transaction counterparties;
  • Publicly available and accessible directories and sources;
  • Bankruptcy registers and tax authorities (including those that are based outside of the territory where you are located);
  • Employment or recruitment agencies, background check providers and your referees; and
  • Governmental authorities to whom we have legal or regulatory obligations.

4. Disclosing Your Personal Information

Your personal information may be combined with information we receive from other sources, or it may be provided to other organizations we work with. We do not disclose your non-public personal information to third parties other than as described below.

Disclosing Personal Information to Third Parties and Affiliates

We do not and will not sell your personal information. If we disclose your personal information to third parties performing services for us, or acting on our behalf, we will not allow them to use your information for other purposes or to sell your personal information, and we will contractually require them to protect your information.

We may disclose your personal information to our affiliates, business partners, service providers (including, but not limited to custodians, depositaries and investment advisors), tax authorities, financing counterparties (including lenders, correspondent and agent banks), professional advisors and other third parties. We may do so for the purposes of operating our business, delivering and improving the financial services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business. We may also disclose your personal information to regulatory, prosecuting and other governmental agencies as well as litigation counterparties, in any relevant country or territory. In addition, we may also disclose your personal information to affiliates or applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding or other disposition of all or a portion of our business, assets or shares.

We also disclose personal information for a variety of additional purposes including, but not limited to:

  • For our everyday business purposes, such as to process your transactions, maintain your account(s), or respond to court orders and legal investigations; and
  • For our affiliates’ everyday business purposes, including certain information about your transactions, experiences, and creditworthiness.

Rockpoint does not disclose to nonaffiliated third parties any nonpublic personal information about its clients, except as permitted by law or as is necessary to service client accounts. To the fullest extent permitted by law, these nonaffiliated third parties are contractually required to protect the confidentiality and security of this information and to use it only for its intended purpose.

5. Restricted Use Regarding Minors

This Site is not intended or designed to be used by children under the age of 13. We do not collect or process personal information from any person we know to be under the age of 13 and instruct children under 13 not to send us any information.

6. Lawful Basis

There is a need to process personal information for the purposes set out in this Policy as a matter of contractual necessity under or in connection with the applicable agreement, and in our legitimate interests to operate our respective businesses. From time to time, we may need to process personal information on another legal basis, including, among others: to comply with a legal obligation; if it is necessary to protect the vital interests of an investor or other data subject; or if it is necessary for a task carried out in the public interest. We do not generally rely on your consent to process your personal information. For the purposes listed above, we generally expect to rely on contractual necessity and our legitimate interests or the legitimate interest of a third-party.

Unless otherwise indicated, you should assume that we require personal information for business or compliance purposes. A failure to provide the personal information requested to fulfill the purposes described in this Policy may result in us being unable to provide the services in connection with the terms of your subscription agreement.

7. Data Storage and Retention

We keep your personal information for as long as it is required to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements (e.g., in accordance with the retention period consistent with applicable securities laws), for our legitimate business purposes, or to perform our contractual obligations, unless a longer period is otherwise required or permitted by law or regulatory obligations that apply to us.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8. Protection of Personal Information

We acknowledge that no method of transmission over the Internet, or method of electronic storage, is 100% secure and, therefore, cannot guarantee the absolute security of any records or data (including personal information) submitted to us. However, we implement and maintain reasonable technical, physical, and administrative security measures that comply with applicable legal and regulatory standards and that are designed to safeguard your personal information. Access to such information is restricted to those employees who are trained in the proper handling of client information and have a legitimate business need to access that information. We follow generally accepted standards and best practices to protect the personal information you submit to us, whether that information is in transit or at rest.

9. Our Site and Use of Cookies; Do Not Track

We use various technologies to collect other types of information, including personal information, automatically. For example, to measure the usefulness and efficiency of our Sites, we automatically track certain information from all visitors to our Sites. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information.

Additionally, like most interactive web sites, we use “cookies” on certain pages of our Sites. “Cookies” are small data files that are stored on your hard drive that contain certain information, including certain personal information accessible to our Sites, such as your password and any information content preferences you may voluntarily set at our Sites. These technologies help us recognize you, customize your experience on the Sites and analyze your use of the Sites to make them more useful to you. By visiting our Sites, you agree to our use of cookies.

You can refuse the use of cookies by selecting the appropriate browser setting. If you opt-out, please note that your experience using the Sites may not be optimal, and you may not be able to use certain features on our Sites. For information on how to remove or manage cookie functions and adjust your privacy and security preferences, access the “help” menu on your internet browser, or visit https://www.aboutcookies.org/how-to-control-cookies.

We also use analytics providers, such as Google Analytics, to help us evaluate the Sites. To opt out of the aggregation and analysis of data collected about you on the Sites by Google Analytics, visit https://support.google.com/analytics/answer/181881 then download and install the Google Analytics Opt-out Browser Add-on, as noted on this web page.

Do Not Track

We do not track visitors of our Site over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

10. Automated Decision Making

We do not use automated processing, including profiling, to make decisions that will have either legal or material effects on the individuals from whom we collect and process personal information.

11. Personal Information Rights for EU and UK residents

To the extent that the European Union’s (the “EU”) General Data Protection Regulation (Regulation 2016/679) or, where applicable, such regulation as it forms part of the law of the United Kingdom (“UK”) by virtue of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419) (the “GDPR”) applies to our processing of your personal information, the GDPR may offer you increased control over your personal information.

This Privacy Notice provides details regarding your rights under the GDPR, and how to exercise those rights. It also provides you with the contact information you need to take action regarding the privacy of your personal information.

Your Data Subject Rights

To the extent the GDPR applies to our processing of your personal information, you may, subject to certain limitations, have the right to:

  • Request confirmation as to whether we are processing your PII and, if so, access to that personal information and information regarding how it is being used;
  • Request that any incomplete or inaccurate personal information is corrected;
  • Receive your personal information (in a structured, commonly used and machine-readable format) and to request that we transmit such personal information to another controller, where possible;
  • Require us to erase your personal information in certain circumstances;
  • Restrict the processing of your personal information in certain circumstances;
  • Object to the processing of your personal information in certain circumstances;
  • Not be subject to automated decisions where the decision produces a legal effect or a similarly significant effect in certain circumstances; and
  • Lodge a complaint with the relevant data protection supervisory authority.

While we do not generally rely on obtaining your consent to process your personal information, if we do, you have the right to withdraw such consent at any time. Please contact us at any time should you wish to do so.

If you want to make a complaint, a list of the EU data protection authorities is available by clicking the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en. In the UK, the relevant data protection authority is the Information Commissioner’s Office (https://ico.org.uk/).

12. Supplemental Privacy Notice for California Residents

This notice supplements the Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and all implementing regulations thereto (collectively, the “CCPA”) to natural person California residents. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection and processing of their personal information that is not set forth in this supplemental notice is otherwise set forth elsewhere in the Policy.

What Personal Information We Collect

The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we may have collected over the last twelve (12) months include the following:

  • Identifiers, such as name, contact details, address (including physical address, email address and IP address), driver’s license number, passport number or other similar identifiers;
  • Other customer records, such as telephone number and personal information provided;
  • Commercial information;
  • Financial information;
  • Biometric information;
  • Geolocation data;
  • Audio, electronic, visual or similar information, including photographs and CCTV footage;
  • Professional or employment-related information;
  • Education information;
  • Sensitive personal information, such as your social security number and health information (e.g., proof of COVID vaccination for visitors to our premises); and
  • Internet or other electronic network activity information, such as information regarding your use of our website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries;
  • Inferences drawn from any of the information identified above.

We do not knowingly collect personal information from anyone under the age of 16 without parental consent.

For additional details about the personal information we may collect, please refer to the section of the Policy titled “Types and Use Of Personal Information We Collect” above.

Sources, Uses, Disclosure and Retention of Personal Information

For information regarding how we collect your personal information, the use and disclosure of your personal information, and the time period in which we retain your personal information, please refer to the relevant sections of the Policy above.

We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA Regulations.

We do not “sell” or “share” (as such terms are defined by CCPA) any of your personal information.

Your Rights

If you are a California resident, you have the right to:

  • Request that we disclose, free of charge, the categories and specifics of the personal information we collect about you, the sources from which the personal information was collected (and, if applicable, disclosed to a third party), and the business purpose for collecting such personal information;
  • Request that we correct any inaccurate personal information about you;
  • Request that we limit use and disclosure of your sensitive personal information;
  • Opt-out of the sale or sharing of your personal information (however, currently we do not “sell” or “share” (as such terms are defined by the CCPA) any of your personal information); and
  • Request that we delete the personal information we retain about you.

Please note that the above rights may be subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Non-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 to you) a different level or quality of service.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access the Policy (including this supplemental notice) in an alternative format, please submit a request on your behalf using any of the methods set forth in the “Questions or Concerns and Exercising Your Data Subject Rights” section below.

California’s Shine the Light Law

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our website users who are California residents to request and obtain from us a list of their personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not disclose any personal information to third parties for their direct marketing purposes.

13. Transfers of Personal Information

We may transfer your personal information between different countries to our affiliates and group members, other investors in the Funds, transaction counterparties and third-party service providers. These countries may not have similarly strict standards regarding data protection and privacy (and may include, for example, transfers from the UK and the European Economic Area, to jurisdictions outside of such territories). When we transfer your personal information from one country to another, we will (where required) put in place data transfer agreements or other appropriate safeguards that are designed to ensure that your personal information is treated in a manner that is consistent with applicable data protection laws (including, where appropriate, EU-approved standard contractual clauses and/or data transfer terms issued by the UK government).

14. Questions or Concerns and Exercising Your Data Subject Rights

If you have any questions or concerns regarding the information in this Policy, or would like to exercise any of your rights set forth in this Policy, yourself or an authorized agent can contact us on our toll-free Privacy hotline at 833.581.2218 (+ 1 617.437.0166) or email us at privacy@rockpoint.com. Please include a description of what right you want to exercise and the information to which your request relates. Consumers with disabilities may request this policy in an alternative format.

15. Verifying Your Identity

If you choose to contact us with a request, you will need to provide us with identifying information that matches the personal information we currently have about you or that otherwise allows us to reasonably verify that you are the person about whom we collected personal information, such as your name, email address, and information about your interactions with us. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney, or that the agent otherwise has valid signed authority to submit requests on your behalf, and ask that you verify your identity directly with us.

PLEASE NOTE: We cannot respond to your request or provide you with non-public personal information if we cannot verify your identity or authority to make the request and confirm that the requested personal information relates to you. We will use the information provided in a request solely to verify your identity or authority to make the request.