Transpose Platform Management, LLC
This Privacy Notice explains the manner in which Transpose Platform Management, LLC (“we” or the “Firm”) collects, utilizes and maintains nonpublic personal information about investors in our funds.
We are committed to protecting your privacy and maintaining the confidentiality and security of your personal information. We are sending you this Privacy Notice to help you understand how we handle the personal information about you that we collect and how we use that information.
We reserve the right to change this Privacy Notice at any time. The examples contained within this notice are illustrations and are not intended to be exclusive. If you have any questions about this notice, please email us at: firstname.lastname@example.org or write to us at: c/o City Spaces City Centre One, 800 Town and Country, Suite 400, Houston, TX 77024.
Categories of Information We Collect and May Disclose
We use the personal information collected about you to provide you with better service or to comply with law and regulations. We may collect nonpublic personal information about you from the following sources:
· Subscription Booklets, Limited Partnership Agreements or other forms (for example, name, address, Social Security number, assets and income);
· Ownership records of the fund in which you are an investor, (such as the amount of your percentage ownership interest and any capital commitment); and
· Other interactions with us or our affiliates (such as discussions or other contacts with our staff, via telephone, written correspondence, and electronic media).
We may disclose nonpublic personal information we collect about you to our affiliates (including those who are involved in the operation, administration or management of, or the sale of interests in the fund in which you are an investor) and nonaffiliated service providers, only as permitted by law and regulations. For example, we may share nonpublic personal information about you in the following situations:
· In connection with the administration and operations of the fund in which you are an investor, including disclosure to attorneys, accountants, auditors, administrators, or companies that assist us with mailing statements or processing your transactions, or other professionals;
· To broker-dealers, custodians and transfer agents to facilitate in-kind distributions of portfolio securities;
· To respond to a subpoena or court order, judicial process or regulatory inquiry; and
· At your direction or with your consent, including upon your authorization to disclose such information to persons acting in a fiduciary or representative capacity on your behalf.
We may also share your personal information with other providers of services necessary or convenient to the formation, operation or dissolution of the fund in which you are an investor. Finally, as required or permitted by the fund’s governing documents, we may distribute to all investors in such fund certain personal financial information, such as capital account information and various schedules to the partnership agreement.
The information of our former investors is treated in the same manner as the information of our current investors.
Confidentiality and Security
We have always considered the protection of sensitive information to be a sound business practice and a foundation of customer trust. We protect personal information we collect about you by maintaining physical, electronic and procedural safeguards.
Within our management entities, we restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you.
Information Collected from You Automatically
The Firm uses various Internet technologies to manage and track use of our services. Non-personal information that we collect using these technologies may be combined with the personal information that you may voluntarily provide us when using certain specific services.
· Device Information: We may collect non-personal information about the computer, mobile device, or other device you use to access our services, such as your computer’s unique IP address, geolocation information, unique device identifiers, browser type, browser language and other transactional information;
· Cookies, Beacons, Local Storage and Other Similar Technologies: The Firm uses “cookies,” Web beacons, HTML5 local storage, and other similar technologies. These technologies allow us to manage access to and use of our services, recognize users and provide personalization, and help us to understand how users engaged with our services. You will not be able to access certain areas of our websites if your computer does not accept cookies from us. We do not respond to browser- based “do not track” signals;
· Location Information: Some of our mobile applications can deliver content based on your current location if you choose to enable that feature of the app. If you enable the location-based feature, your current location will be stored locally on your device, which will then be used by the app. If you elect to have a location-based search saved to your history, we will store that information on our servers. If you do not enable the location-based service, or if an app does not have that feature, the app will not transmit to us, and we will not collect or store location information;
· Email Tracking Pixels: We may use a function in HTML emails to track which users open emails and which links they click;
Investors in the European Union
If you are a resident of the European Union, your personal information is protected by the European Union’s General Data Protection Regulation (Regulation 2016/679) (the “GDPR”) Under GDPR, the Firm is characterized as a “data controller” and third-parties that the Firm engages may act as “data processors” under the GDPR.
By virtue of being an investor in one of our funds, you will provide us with certain personal information which constitutes personal data within the meaning of the GDPR. In general, this includes, but is not limited to:
· Identification data, such as name, sex, age/date of birth, place of birth, contact details including address (private and professional), telephone number (private and professional), email (private and professional);
· Profession, job title and position;
· Nationality or civil status;
· Passport information or other national identification number;
· Tax identification such as National Insurance Number;
· Personal bank account and financial information such as account identification and number, income and (for professional investors) financial license;
· Information about the account holders’ or clients’ transactions;
· Account history with us;
· Financial details such as fees paid and bank account details;
· IP addresses;
· Utility bills;
· Information collected using cookies.
In certain circumstances, we and/or our third-party service providers may be legally obliged to share your data and other financial information with the U.S. Securities and Exchange Commission (“SEC”) and they, in turn, may exchange this information with foreign tax authorities (such as the Internal Revenue Service) that are located outside the European Economic Area (the “EEA”).
Any transmission of your personal data by the Firm and/or third-party service providers outside the EEA shall be in accordance with the conditions in the GDPR.
The Firm and/or third-party service providers utilize appropriate information security measures designed to protect data in our/their possession from unauthorized access or computer corruption. We have also implemented reasonable technical and organizational measures designed to secure personal information from accidental loss and unauthorized access, use, alteration or disclosure. Additionally, our employees are required to follow specific procedures with respect to maintaining the confidentiality of investors’ personal information. Lastly, we maintain physical, electronic, and procedural safeguards to protect the personal information that we process. This includes performing ongoing evaluations of our systems containing investor information and making changes when appropriate.
We will notify you of any personal data breach affecting you that is likely to result in a high risk to your interests, fundamental rights or freedoms.
You have certain rights regarding the Firm’s use of your personal data, such as (but not limited to):
· Access to your personal data (in an easily readable form);
· Examining and correct your personal data;
· Restricting the use of your personal data;
· Requesting that your personal data be erased;
· Objecting to processing of your personal data;
· Portability (in certain specific circumstances);
· Withdrawing any consent given to the processing of your personal data (where applicable);
· Receiving information regarding any entities the Firm discloses your personal data to;
· Lodging a complaint with the relevant authority.
Please note that the right to have your personal data erased (also known as the “right to be forgotten”) applies in some contexts under the GDPR but is not likely to be applicable to most, if not all, of the personal data you provide to us, given the limited purposes for which we use the data. Further, the Firm is registered as an investment adviser with the SEC. To comply with applicable recordkeeping requirements, we may retain your personal data for a period of up to five years following the termination of your relationship with the Firm.
As the Firm does not process personal data on a large scale, we are not required to designate a data protection officer. However, should you have any queries or wish to discuss or exercise your rights, please contact us at the above telephone number or email address.