PRIVACY POLICY

By accessing this website, and any pages hereof, you agree to be bound by the terms and conditions below. The information contained in these pages is subject to change. Please read the following terms and conditions carefully.

COMMITMENT TO PRIVACY

Conifer Capital Holdings LLC (the “Company”) considers privacy to be fundamental to its relationship with its current and former investors and individuals who visit the Company’s website (the “Website”) or otherwise communicate or engage with the Company. The Company respects the right to privacy of its current and former investors and those individuals who visit the Website.  The Company also knows, however, that it is expected to conduct its business in an accurate and efficient manner. To do so, the Company must collect, use and otherwise process certain personal information about its current and former investors and individuals who visit the Website.

This privacy policy discusses how we collect, use and otherwise process such personal information. The Company has also developed internal policies designed to help maintain confidentiality, integrity and security and protect such information while allowing the needs of its current and former investors and individual visitors to the Website to be met. This right to privacy extends to all forms of contact with the Company, including by telephone, written correspondence and electronic media, such as the internet. 

COLLECTION OF PERSONAL INFORMATION

The types of personal information collected by or on behalf of the Company vary based on the nature of the interaction (for example, whether about an investor or an individual visiting the Website).

Personal information collected by or on behalf of the Company about individuals visiting the Website is obtained directly from the individuals or certain third parties. The personal information which the Company collects about individuals in the course of their interaction and correspondence with the Company includes, but is not limited to, the following:

  • The visitor’s IP address and other online identifiers/web beacons;

  • Details of the visitor’s browsing activities on the Website, including, but not limited to, the full Uniform Resource Locator (URL), clickstream to, through and from the Website (including, but not limited to, date and time), services viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;

  • The visitor’s browser type, relevant plug-ins, operating system and platform; and

  • The visitor’s time zone settings.

Personal information collected by or on behalf of the Company about an investor in the course of the investor’s interaction and correspondence with the Company and its representatives includes, but is not limited to, the following:

  • Basic personal details, including name and address (and proof of name and address), email address, telephone number, any other contact details, social security number, driver’s license, passport number, tax identification number, and other tax details, nationality, citizenship, tax residency, date of birth and family connections;

  • Information regarding company directors, shareholders, secretaries, authorized signatories and their comparable officers and/or beneficiaries, and identification documents;

  • Banking details and other financial account information;

  • Details of any business or financial advisors;

  • Account log-in information;

  • Personal information about transactions with the Company, its affiliates or others. 

USE OF PERSONAL INFORMATION

The Company uses the aforementioned personal information to operate its business, including as follows:

  • To provide services requested by an investor and to fulfill contractual obligations, including any contractual obligations as the general partner(s) and/or the investment advisor to a fund in which an investor has subscribed;

  • To operate the Website and the Company’s other IT systems and to safeguard their security;

  • For the Company’s internal business administration and record keeping purposes;

  • For legal and regulatory compliance purposes, including as necessary to respond to government, regulatory or law enforcement agency requests; and

  • To fulfill the Company contractual obligations to other third parties to whom an investor has provided its information