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Lighthouse Privacy Notice

 

Lighthouse Investment Partners, LLC, and its subsidiaries (collectively, “Lighthouse” or “Lighthouse Group” or “we” or “our”) respect the confidentiality and privacy of our website visitors and customers (“you”). This Privacy Notice (“Notice”) describes the information we collect on and offline through the provision of investment and related services in the conduct and operation of our business (the “Services”), how we use such information, and the choices you have with regard to your personal information. Please note that our websites may include links to third-party websites, whose own privacy policies and terms of use apply to your use of their services.

 

As used in this Notice, “personal information” means any information that relates to an identified or identifiable individual. Personal information shall have the same meaning as personal data under applicable data protection law.

TABLE OF CONTENTS

PERSONAL INFORMATION WE COLLECT AND USE

  1. Personal Information You Provide

  2. Information Collected From Your Devices

  3. Personal Information Provided by Others

  4. Other Ways We Use the Information We Collect

ANALYTICS AND TRACKING TECHNOLOGIES

  1. Categories of Cookies and Tracking Technologies

  2. Do Not Track Signals
     

DE-IDENTIFIED AND AGGREGATE DATA
HOW WE SHARE PERSONAL INFORMATION
REQUIRED NOTICES

  1. Legal Categories of Personal Information

  2. Your Rights and Choices

  3. How to make a Request and What to Expect

  4. Additional California Rights - Shine the Light Notice

INTERNATIONAL DATA TRANSFERS

CHILDREN’S PRIVACY

LEGAL BASES FOR PROCESSING

DATA RETENTION

HOW WE PROTECT YOUR PERSONAL INFORMATION

CHANGES TO THIS NOTICE

CONTACT US

PERSONAL INFORMATION PRIVACY CHART

 

PERSONAL INFORMATION WE COLLECT AND USE

  1. Personal Information You Provide

You may provide us with personal information directly through your interactions with us for the following purposes:

  • Communicate with you: To communicate with you, including to respond to your inquiries and provide updates, we may collect your contact information, such as name, email address, phone number, and other information you may provide us regarding your inquiries directly from you.

  • Providing Services: We may collect name, email address, phone number, zip code and other contact information relevant to our relationship with you directly from you to: conduct due diligence and evaluate business opportunities; develop new investment opportunities; manage, operate, and grow our business, administer the Services and manage investor accounts.

 

2. Information Collected From Your Devices

 

We also collect information about how you use our Services from your device(s) or browser, for the following purposes:

  • Providing Services: in order to provide our Services, including when we operate our website, troubleshoot bugs and provide technical support, we may collect technical information such as IP address, log details, device information, browser information and location information automatically from your device or browser.

  • Analyzing and Improving our Services: to better understand how our visitors use our websites, to improve our websites, and for research and analysis purposes, we may collect data related to your use of our websites including, IP address, zip code, device information, browser information, the actions you take on our websites and other information made available automatically from your device or browser.

 

3. Personal Information Provided by Others

We may also collect certain personal information about you from our third party service providers, such as our fund administrator and our website analytics tools, for the following business purposes:

  • Comply with Legal Obligations: we are required to collect certain types of personal information about you when you invest with us, including your name, address, date of birth, Social Security number or other tax identifier, government issued ID number, marital status, beneficiary information, bank details, assets, income, email address, phone numbers, investor status, information about your transactions with us (including our affiliates), and other financial information necessary for us to comply with our legal obligations.

  • Communicate with you: To communicate with you about our funds and in order to provide you with reporting, statements, and other information regarding our Services we may collect your name, address, email address, phone number and other contact details from our third party fund administrator.

  • Providing Services: In order to provide our Services, operate our website, troubleshoot bugs and provide technical support, we may collect technical data about your interactions with us including IP address, browser information, device information, and other technical information about your engagement with our Services from third parties.

  • Analyzing and Improving our Services: we use tracking technologies to provide us with analytics data regarding your use of the services, including IP address and information about your use of our websites from third parties. For more information about our use of analytics tools, please read the ANALYTICS AND TRACKING TECHNOLOGIES section below.

 

4. Other Ways We Use the Information We Collect

We may use the personal information collected from any of the above sources for the following business purposes:

  • Protecting our Business: to protect and secure our business, systems, the Services and our websites, to investigate, prevent, detect and respond to fraud, unauthorized access, or other potential threats to the rights and safety of any individual or third party, or other unauthorized activities or misconduct.

  • Defending Legal Rights: to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend, or protect rights or interests, including in the context of anticipated or actual litigation.

  • Auditing, Reporting, Governance and Internal Operations: to conduct our business, including fulfilling our financial, tax and accounting obligations, such as audits, assessments, privacy, security, and financial controls, accounting, record keeping and legal functions, any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business.

  • Complying with Legal Obligations: to comply with the law, our legal obligations and legal processes (such as warrants, subpoenas, court orders, and regulatory or law enforcement requests).

 

ANALYTICS AND TRACKING TECHNOLOGIES

As mentioned above, we collect information when you visit our websites to help gather statistics about usage and effectiveness, personalize your experiences and tailor our interactions with you. We do so through the use of various technologies, including the use of cookies, web beacons, and other use-tracking devices.

 

Definitions 

  • Cookies.  A “cookie” is generally a small piece of data sent from a website and stored in a user’s web browser while the user is browsing the internet. A “session cookie” is a cookie that exists in temporary memory only while the user is reading and navigating a particular website. A session cookie is typically deleted when the user closes his or her browser. A “persistent cookie” is a cookie that generally outlasts the user’s current online session and may be sent back to the server every time the user visits the same website. Persistent cookies are commonly referred to as “tracking cookies” since the user’s activity on a particular website may be tracked over time.

  • Web Beacons.  A “web beacon” is an object that is embedded in a web page or e-mail and is usually invisible to the user but allows checking that a user has viewed the page or e-mail. It is basically a technique to track who is reading a web page or e-mail. Web beacons, also called “web bugs” are often invisible to the user because they may be very small (only 1-by-1 pixel) and/or are made to blend in with the background color of the webpage, document, or e-mail message. Web bugs are identified with HTML IMG tags in the webpage.

  • Other Technologies. We may use other use-tracking devices, which may change from time-to-time as technology changes, to help diagnose problems and to administer our Services. We also may track browser types to help us understand our visitors’ needs related to our websites’ design.

 

  1. Categories of Cookies and Tracking Technologies

Cookies and Tracking Technologies can be categorized based on their function. Our websites use the following categories:

  • Necessary. These are required for the operation of our websites, such as to ensure security and fix bugs. These cookies cannot be switched off. You can set your browser to block or alert you about these, but some parts of our websites may not work if you do.

  • Analytics. These allow us to analyze website usage and understand how visitors use it. These may recognize and collect information about the number of visitors, the pages they view, how long they view pages and how they move around our websites when they are using it. This helps us to improve the way our websites work, for example, by ensuring that visitors are easily finding what they are looking for.

 

2. Do Not Track Signals

Your browser settings may allow you to automatically transmit an opt-out preference signal or “Do Not Track” signal to online services you visit.  Our websites currently are not designed to respond to Do Not Track signals received from web browsers.

 

Please note that if you set your browser to disable cookies or other tracking mechanisms, then your experience using our websites may not be the same depending on the particular service. Specifically, functionality of a service may be limited, may not function properly, or may not work at all. These functionalities include, but are not limited to, settings as to screen size and appearance, logon verification, and pre-populated information.

 

DE-IDENTIFIED AND AGGREGATE DATA

 

Lighthouse may de-identify and aggregate data for its business purposes, including but not limited to, to improve the products and features of its Services, to maintain the security and integrity of its systems, for analytics, and other legitimate business purposes.  “De-identified Data” means information that cannot reasonably be used to infer information about, or otherwise be linked to a particular data subject.  Where we process De-identified Data, we commit to maintain and use the information in de-identified form and not attempt to reidentify the information, except where permitted by law. Lighthouse may disclose De-identified Data to third who commit themselves to maintaining the De-identified Data in de-identified form and not attempt to re-identify the data for any business purpose.

 

HOW WE SHARE PERSONAL INFORMATION

We may share information about you to third parties as indicated below:

  • With other companies that provide services to us: We may engage third party vendors to assist us with our day-to-day business operations on our behalf, such as:

    • To conduct background checks for our due diligence and compliance purposes;

    • Provide statistical analysis and reporting;

    • To provide fund administration services on our behalf;

    • To assist us in creating and maintaining a secure environment to store and transfer data on our behalf.

  • Auditing services: We use third party vendors to conduct auditing services on our behalf.

  • In aggregated, de-identified form: We may provide aggregated statistical data to third parties for our own analytics and business purposes. Where we share de-identified data with third parties, we do so in compliance with this Notice.

  • Compliance with legal obligations: We may need to disclose certain information to auditors, government authorities, law enforcement, regulatory agencies, our legal counsel, third party litigants and their counsel, or other authorized individuals in order to comply with laws that apply to us, or other legal obligations such as contractual requirements.

  • Changes in business structure/ownership: We may disclose or transfer your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or ownership interest (including any bankruptcy or similar proceedings).

  • With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, including:

    • if we believe, in our sole discretion, that the disclosure of personal information is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;

    • to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;

    • to protect our property, Services and legal rights;

    • to help assess and manage risk and prevent fraud against us, our customers and fraud involving the use of our Services; and

    • to support our audit, compliance, and corporate governance functions.

 

REQUIRED NOTICES

  1. Legal Categories of Personal Information

 

Some privacy laws require that we disclose the legal categories of personal information we have collected in the past twelve (12) months, which business purposes they are collected and used for, the categories of third parties with whom the personal information is shared, and the categories of third parties to whom the information is sold. To make this easier to understand we have compiled this information in a chart in PERSONAL INFORMATION PRIVACY CHART.

 

2. Your Rights and Choices

 

For all personal information that we collect about you, you may have the following rights or choices that we will accommodate, provided, your requests meet legal and regulatory requirements and do not risk making our other data less secure or changing our other data. You may also designate an authorized agent to make a request on your behalf.

 

Access/Know:

You may have the right to know the categories of personal information collected about you, the legal basis for processing your personal information, and to know whether your personal information is disclosed / sold and to whom. You may have the right to access your personal information and to receive a copy of your information.

 

Data Portability:

You may have the right to request the transfer of your personal information to you or to a third party. We will provide to you, or to a third party you have chosen, your personal information in a structured, commonly used, machine-readable format.

 

Deletion: 

You may have the right to request that we erase your information. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

Limit Use and Disclosure of Sensitive personal information:

You may have the right to direct Lighthouse to limit our use of your sensitive personal information to that use which is necessary to perform the Services and which is reasonably expected by the average consumer requesting the Services. For the avoidance of doubt, “Sensitive personal information” as used in this Privacy Policy shall have the same meaning as “sensitive data” under the applicable data protection laws.

 

Non-Discrimination / Non-Retaliation: 

You may have the right not to receive discriminatory treatment by the Lighthouse because you exercise your privacy rights.

 

Opt out of the Sale or Sharing:

You may have the right to opt out of the Sale of your personal information, to the extent applicable. Lighthouse does not engage in the Sale of personal information. You may also have the right to request that we do not Share your personal information with third parties.

 

Opt out of Profiling and/or Targeted Advertising:

You may have the right to opt out of the processing of your personal information for the purposes of Targeted Advertising, Cross Context Behavioral Advertising, or Profiling which is used in furtherance of decisions that produce legal or similarly significant effects. “Profiling” means any automated processing of personal information to evaluate, analyze, or predict aspects concerning an individual’s economic situation, health, personal preferences, interest, reliability, behavior, location, or movements.

 

The Right to Appeal:

You may have the right to appeal a decision we make whether or not to take action on any request to exercise one of your privacy rights.

 

Request Correction: 

You may have the right to request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

3. How to make a Request and What to Expect

 

How to Make a Request. If you would like to make a request to exercise any of your privacy rights, you should submit a request by contacting us through one of the methods provided in the CONTACT US section. When making a request you will need to provide your name, email address, phone number, and the specific privacy right(s) you wish to exercise.

 

Verification. For some requests, we may be required to verify your identity, meaning that we need to make sure that you are the individual about whom the personal information we hold relates. Where we request information to verify your identity, we will not ask you to provide new information that we do not already hold about you.

 

Responding to Requests. Your request will be evaluated to determine whether the request meets the legal requirements and if we are able to honor it. For example, we may not be able to re-identify information related to an individual who visits our website but is not a customer with us. We make every effort to respond to privacy requests within thirty (30) days of when they were made to us. In the event that we need more time, we will notify you.

 

Requests by Authorized Agents.  You may designate an authorized agent to make a request on your behalf. Privacy laws require that any request you submit to us is subject to an identification and verification process, and confirmation of the agent’s authority, which may include attestation under penalty of perjury. Absent a power of attorney, we will also require the consumer to verify their own identity. We may verify identity based on matching information you provided with data we have maintained on you in our systems.

 

Lodging a complaint. You may lodge a complaint with a data protection authority such as the supervisory authority of your usual place of residence. A full list of data protection authorities located in the European Economic Area (EEA) is available here. You can also lodge a complaint with the UK Information Commissioner’s Office, which is the competent supervisory authority for Lighthouse. Alternatively, you may request the details of your competent data protection authority by using the contact details at the bottom of this Notice.

 

4. Additional California Rights - Shine the Light Notice

 

Pursuant to California Civil Code § 1798.83 (California Shine the Light Law), California residents may have the right to request:

  • A list of the categories of the “Personal Information” as defined by law disclosed to third-parties without your consent, other than with our affiliates, for direct marketing purposes during the preceding calendar year; and

  • The nature of the third-parties’ business, if any.

 

We do not share Personal Information with non-affiliate third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law and/or withdraw previously given consent to sharing with non-affiliate third parties for their direct marketing purposes by contacting using the methods in the CONTACT US section below.  Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than those provided in the CONTACT US section.

 

INTERNATIONAL DATA TRANSFERS

 

Some of the third parties with whom we share your data may be located in, or have facilities located in, countries outside of the one in which you reside or use our Services from, including the United States. Where Lighthouse transfers personal data to third parties located in countries not deemed to provide an adequate level of protection, your personal data will still be subject to the data protection laws applicable to you.

 

Lighthouse has adopted cybersecurity and data protection standards to ensure an adequate level of protection for your personal data to comply with legislative requirements. By agreeing to this Notice, you agree to this sharing with third parties outside of your country of origin, which will take place according to the purposes described in this Notice and pursuant to written agreements.

 

CHILDREN’S PRIVACY

 

Our Services are not intended for use by anyone under the age of thirteen (13).  In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly request or solicit Personal Information from anyone under the age of thirteen (13) nor will we knowingly allow anyone under the age of thirteen (13) to create a Lighthouse user account.  In the event that we receive actual knowledge that we have collected such Personal Information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical.  We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Services.

 

LEGAL BASES FOR PROCESSING

 

Some privacy laws require us to provide the legal basis(es) for processing personal information. Below are the legal bases which we rely on to process your personal information for each business process.

 

Where a legal basis no longer applies to the processing of personal information and no other legal basis exists to retain your personal data, Lighthouse will delete or make anonymous your personal data pursuant to our retention policies.

 

DATA RETENTION

 

We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.  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 requirements.

 

We cannot (fully) comply with a request to erase or delete if we have to retain your personal information for certain purposes and for a longer period due to a statutory retention period.  After the retention period has expired, we will delete your personal information.

 

HOW WE PROTECT YOUR PERSONAL INFORMATION

 

We strive to maintain technical, physical, and administrative security measures designed to provide reasonable protection for your personal information against loss, misuse, unauthorized access, disclosure, and alteration.  Security measures may include firewalls, data encryption, access controls to our data centers, and information access authorization controls.   Access to personal information is restricted to those employees who have a need to know to perform their job.  While we are dedicated to securing our systems and Services, we cannot guarantee that loss, misuse, or alteration will never occur.

 

CHANGES TO THIS NOTICE

 

We reserve the right to change this Notice prospectively effective upon the posting of the revised Notice and your use of our websites indicates your acknowledgement of the Notice posted at the time of use. However, should we update this Notice, we will post a new version online, and will notify you if the personal information processed about you will be materially different than that which was represented to you at the time it was collected. To the extent any provision of this Notice is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

 

CONTACT US

 

For questions regarding this Notice or to make a request pursuant to this Notice related to your personal information, contact us using any of the following options:

 

Email: investor.relations@lighthousepartners.com      Phone:  +1 561-741-0820

PERSONAL INFORMATION PRIVACY CHART

 

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose: 

In addition to the purposes described in this notice, we may use Personal Information listed below for business purposes.

Category A: Identifiers.

Category B: California Consumer Records Personal Information Categories.

Category C: Protected Classification Characteristics Under California or Federal Law.

Category D: Commercial Information.

Category I: Professional or Employment-Related Information.

Category J: Education information as defined by the Family Education Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).

Category L: Sensitive Personal Information.

 

No Sales of Personal Information

In the preceding twelve (12) months, we have not sold any Personal Information.

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Personal Information
Analytics & Tracking
De Identified
Personal Info Chart
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