Website Privacy Notice

February 2025

As required under the U.S. Federal Trade Commission’s “Privacy of Consumer Financial Information Rules,” we are providing this privacy notice (this “Privacy Notice”) to individual investors (i.e., investors who are natural persons or “alter egos” of individuals (e.g., revocable grantor trusts, IRAs or certain estate planning vehicles)) in order to inform you of our privacy policies and practices with respect to your personal information. For purposes of this Privacy Notice and the EEA-UK Privacy Notice and California Privacy Notice (in each case, as defined below), the terms “Maple Park,” “we,” “us,” and “our” refer to Maple Park Capital Partners and its affiliates. The California Privacy Notice supplements this Privacy Notice with respect to natural persons who are California residents and sets out additional information related to rights specific to these individuals. [If and to the extent that the EEA-UK Data Protection Legislation (as defined in the EEA-UK Privacy Notice) applies, the EEA-UK Privacy Notice takes precedence over and replaces this general Privacy Notice.

Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our individual limited partners. We have a policy of protecting the confidentiality and security of information we collect about you. We are providing you with this Privacy Notice to help you better understand why and how we collect certain personal information, the care with which we treat that information and how we use that information.

Information We Collect: In connection with forming and operating our private investment funds (or “funds”) for our investors, we collect and maintain the following categories of personal information:

  • Contact information: name, address, email address, telephone number and other contact details;
  • Identification information: signature, date of birth, place of birth, nationality, citizenship, location of residence, social security number, taxpayer identification number, driver’s license, passport, Internet Protocol address and other government identification and numbers;
  • Background information: information required to perform, or revealed in, know your-customer (KYC) and anti-money laundering (AML) due diligence, tax status, investor accreditation subscription, consents, status under various laws and regulations, PEP status, sanction status and information with respect to an investor’s ownership composition and structure;
  • Financial information: assets, income, net worth, amounts and types of investments, risk tolerance, capital account balances, capital commitments, capital contributions, account data, other investment participation information, funds transfer information, beneficiaries, positions, percentages of fund, share or option 2 numbers and values, vesting information, investment history, transaction information, tax status and information and sources of assets and funds used for capital commitments and contributions;
  • Investment information: information about your interest in the relevant funds, including ownership percentage, capital commitment and investment, income and losses; and
  • Technical or account information: electronic device and usage information (for example, from cookies and similar technologies in relation to the use of websites, fund data rooms and investor reporting portals), registration information, and account (including online account) data.

Sources of Information: We collect and maintain personal information from the following sources:

  • Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail and other electronic communications or in subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation);
  • Information about your transactions with us or others; and
  • Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms and any information captured via “cookies.”

Purposes for Collecting Personal Information: We may process or disclose the personal information we collect about you for the following business or commercial purposes:

  1. performing services to you, including but not limited to:
    1. the administrative processes (and related communication) in preparing for the admission of investors to the fund(s), including administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase interests in the fund(s);
    2. ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund and the execution of all relevant agreements;
    3. the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund and during the process of admitting potential investors to the fund and the execution of all relevant agreements;
    4. ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
    5. keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
    6. administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase its holding (of shares);
    7. facilitating the execution, continuation or termination of the contractual relationship between an investor and the general partner, the fund(s) and/or other applicable party; and
    8. facilitating the transfer of fund interests, and administering and facilitating any other transaction, between an investor, the general partner, the fund(s) and/or any other applicable party;
  2. auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
  3. maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
  4. enabling any actual or proposed assignee or transferee of the fund(s), to evaluate proposed transactions;
  5. facilitating business asset transactions involving the funds;
  6. complying with U.S., state, local and non-U.S. laws, rules and regulations; and
  7. any other purpose that has been notified, or has been agreed, in writing.

Disclosure of Information: We may disclose any of the categories of personal information set out in the “Information We Collect” section above as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, tax advisors, governmental agencies or pursuant to legal process, self regulatory organizations, consultants, information technology providers and placement agents, or as otherwise authorized by you in writing.

Former Investors: We may maintain personal information of our former investors and apply the same policies that apply to current investors.

Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards, which seek to protect your personal information in our possession or under our control.

Further Information: We reserve the right to change our privacy notices and this Privacy Notice at any time. In the event that we do so, we will make an updated version of this Privacy Notice available to you via the investor portal. The examples contained within this notice are illustrations only and are not intended to be exhaustive. This notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. To the extent there is any conflict between this Privacy Notice and the privacy requirements under the Gramm-Leach-Bliley Act or Regulation S-P (collectively, the “GLB Rights”), the GLB Rights shall apply to you, including as set forth in our additional privacy notices You may have additional rights under other foreign or domestic laws that apply to you, including as set forth in our additional privacy notices, including the California Privacy Notice and the EEA-UK Privacy Notice (each as applicable).

Contact Us: If you have any questions or concerns about this Privacy Notice, wish to view this Privacy Notice in an alternative format, or wish to exercise any rights, submit requests or appeal any of our decisions in connection with this Privacy Notice (each, a “Communication”), please contact us at info@mapleparkcap.com.

We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information or your investor portal access credentials, if applicable, in order to verify your Communication.

California Privacy Notice

This notice (this “California Privacy Notice”) supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended, and any implementing or successor legislation to the foregoing (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. 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 of their personal information that is not set forth in this CCPA supplement is otherwise set forth above in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

Categories of Personal Information We Collect: We collect or have collected within the last twelve (12) months some or all of the following categories of personal information from individuals:

CategoryExamplesCollected
A. IdentifiersName, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets).YES
C. Protected classification characteristics under California or federal lawDate of birth, citizenship and birthplace. YES
D. Commercial informationAccount data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).YES
E. Biometric informationImagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.NO
F. Internet or other similar network activityUse of our website, fund data room and investor reporting portal (e.g., cookies, browsing history or search history), as well as information you provide to us when you correspond with us in relation to inquiriesYES
G. Geolocation dataPhysical location or movements. NO
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related informationCurrent or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NO
K. Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NO
L. Sensitive Personal Information (see further information on use of sensitive personal information below)Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.YES, as to the following types of information: social security, driver’s license, state identification care, or passport numbers, account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only.

We do not collect or use sensitive personal information other than:

  • To perform services, or provide goods, as would reasonably be expected by an average
  • consumer who requests those goods or services;
  • As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
  • As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
  • For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
  • To perform services on behalf of our business;
  • To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
  • To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Purposes for Collecting Personal Information: We collect personal information for any of the business or commercial purposes set forth in the “Purposes for Collecting Personal Information” section in the Privacy Notice above.

We collect personal information from the sources set forth in “Sources of Information” in the Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this California Privacy Notice for only as long as it is reasonably necessary for those purposes set forth in “Purposes for Collecting Personal Information” in the Privacy Notice above, except as may be required under applicable law, court order or government regulations:

Disclosure of Information: We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

We disclose or within the last twelve (12) months, we have disclosed personal information collected from you for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category Category of Third-Party Recipients
A. IdentifiersAdministrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal lawAdministrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
D. Commercial informationAdministrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
E. Biometric information N/A
F. Internet or other similar network activityAdministrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
G. Geolocation data N/A
H. Sensory data N/A
I. Professional or employment-related informationN/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))N/A
K. Inferences drawn from other personal informationN/A
L. Sensitive Personal InformationAdministrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

Rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain 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.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you over the last twelve (12) months. Such information includes:

  • The categories of personal information we collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting such personal information;
  • Categories of third parties to whom we disclose the personal information;
  • The specific pieces of personal information we have collected about you; and
  • Whether we disclosed your personal information to a third party, and if so, the
  • categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, 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.

No 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, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this California Privacy Notice in an alternative format, please submit a request using any of the methods set forth below.

Call us using the following number: (214) 302-5550

Email us at the following email address: info@mapleparkcap.com

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request your investor portal access credentials to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

EEA-UK PRIVACY NOTICE

This EEA-UK Privacy Notice (the “EEA/UK Privacy Notice”) applies to the extent that UK-EEA Data Protection Legislation (as defined below) applies to the processing of personal data by an Authorized Entity (as defined below). If this EEA-UK Privacy Notice applies, the relevant data subjects have certain rights with respect to such processing of their personal data, as outlined below.

For the purposes of EEA-UK Privacy Notice, “UK-EEA Data Protection Legislation” means all applicable legislation and regulations relating to the processing and/or protection of personal data in force from time to time in the European Union (the “EU”), the European Economic Area (the “EEA”), and/or the United Kingdom (the “UK”), including (without limitation): (i) Regulation (EU) 2016/679 (the “EU GDPR”); (ii) the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018) (the “UK GDPR”); (iii) and any other legislation which implements or supplements any other current or future legal act of the EU, EEA or the UK concerning the protection and/or processing of personal data and any national implementing or successor legislation, and including any amendment or re-enactment of any of the foregoing. The terms “controller”, “processor”, “data subject”, “personal data” and “processing” in this EEA-UK Privacy Notice shall be interpreted in accordance with the applicable UK-EEA Data Protection Legislation. Unless the context otherwise requires, as used herein the words “include”, “includes” and “including” shall be deemed to be followed by the phrase “without limitation”. All references to “investor(s)” in this EEA-UK Privacy Notice shall be to the applicable actual or potential investor(s) and, as applicable, any of other persons relating to such investor(s), including partners, officers, directors, employees, shareholders, members, managers, ultimate beneficial owners and affiliates.

Please contact info@mapleparkcap.com with any queries arising out of this EEA-UK Privacy Notice.

Categories of personal data collected and lawful bases for processing

In connection with the formation, offering, and operation of private investment funds for investors, Maple Park, the applicable fund, the partnership, the general partner, or their respective affiliates and, in each case, their respective administrators, legal and other advisors, service providers, and agents (the “Authorized Entities”) may collect, record, store, adapt, and otherwise process and use personal data either relating to investors or to their partners, officers, directors, employees, shareholders, ultimate beneficial owners or affiliates or to any other data subjects from the following sources (and all references to “investor(s)” in this EEA-UK Privacy Notice shall be to such investor(s) and, as applicable, any of these other persons as relate to such investor(s)):

a) information received in telephone meetings, conversations, in voicemails, through written correspondence, via e-mail or other forms of communications, or in subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation);

b) information about transactions with any Authorized Entity or other persons;

c) information captured on any Authorized Entity’s website, fund data room and/or investor reporting portal (as applicable) including registration information, information provided through online forms or any information captured via “cookies” and/or similar technologies; and

d) information containing photographic images or specimen handwriting; and

e) information from available public sources, including from:

  • publicly available and accessible directories and sources;
  • bankruptcy registers;
  • tax authorities, including those that are based outside the UK and the EEA if the applicable data subject is subject to tax in another jurisdiction;
  • governmental and competent regulatory authorities to whom any Authorized Entity has regulatory obligations;
  • credit agencies; and
  • fraud prevention and detection agencies and organizations.

Any Authorized Entity may process the following categories of personal data:

a) names, dates of birth and birth place;

b) contact details and professional addresses (including physical addresses, email addresses and telephone numbers);

c) account data and other information contained in any document provided by investors to the Authorized Entities (whether directly or indirectly);

d) information regarding the investor’s use of any Authorized Entity’s website, fund data room, and/or investor reporting portal (as applicable);

e) risk tolerance, transaction history, investment experience and investment activity;

f) accounts and transactions with other institutions;

g) information and documents regarding an investor’s status under various laws and regulations, including their identification/social security number, tax status, income and assets, PEP status, sanctions status and related parties’ power of attorney;

h) accounts and transactions with other institutions;

i) information and documents regarding an investor’s interest in the applicable fund, including ownership percentage, capital commitment and contributions, income and losses;

j) information regarding an investor’s nationality, citizenship and location of residence;

k) source of funds used to make the investment in the applicable fund; and

l) anti-money laundering, identification (including passport, drivers’ license and any other acceptable photo identity card or document), and verification documentation.

As part of its compliance with legal obligations such as anti-money laundering requirements, the Authorized Entities may be required to process special categories of personal data (as defined in the UK-EEA Data Protection Legislation), including personal data relating to political opinions as well as criminal convictions and offences data.

Any Authorized Entity may, in certain circumstances, combine personal data it receives from an investor with information that it collects from or about such investor. This may include information collected in an online or offline context. In addition, personal data of investors could be processed and controlled by an Authorized Entity irrespective of whether such investor is admitted to the relevant partnership as a limited partner.

The Authorized Entities are each “controllers” of personal data collected in connection with the applicable fund. In simple terms, this means such Authorized Entities: (i) “control” the personal data that they or other Authorized Entities collect from investors or other sources; and (ii) make certain decisions on how to use and protect such personal data.

There is a need to process personal data for the purposes set out in this EEA-UK Privacy Notice as a matter of contractual necessity under or in connection with investor agreements and associated documentation, pursuant to applicable legal obligations and in the legitimate interests of the Authorized Entities (or those of a third party) to operate their respective businesses. From time to time, an Authorized Entity may need to process the personal data on other legal bases, including: with consent; if it is necessary to protect the vital interests of an investor or other data subjects; or if it is necessary for a task carried out in the public interest. To the extent that an Authorized Entity processes personal data relating to political opinions of data subjects having a public political exposure, such personal data is processed on the basis that it is personal data which has manifestly been made public by the data subject and/or is necessary for reasons of substantial public interest.

A failure to provide the personal data requested to fulfil the purposes described in this EEA-UK Privacy Notice may result in the applicable Authorized Entities being unable to provide the services in connection with investor agreements.

Purpose of processing

The applicable Authorized Entities process the personal data for the following purposes (and in respect of paragraphs (c), (d) (f), (h), (i) and (k) in the legitimate interests of the Authorized Entities (or those of a third party)):

a) The performance of its contractual and legal obligations, including applicable anti-money laundering, “know-your-client” and other related laws and regulations including in assessing suitability of investors in the applicable fund.

b) The administrative processes (and related communication) carried out between the Authorized Entities in preparing for the admission of investors to the applicable fund.

c) Ongoing communication with investors, their representatives, advisors and agents, (including the negotiation, preparation and signature of documentation) during the process of admitting investors to the applicable fund and the execution of investor agreements.

d) The ongoing administrative, accounting, reporting and other processes and communication required to operate the business of the applicable fund (including any websites, fund data rooms, and/or investor reporting portals) of the Authorized Entities (as applicable) in accordance with investor agreements and/or any other applicable documentation between the parties.

e) To administer, manage and set up your investor account(s) to allow investors to purchase holdings (of shares or interests) in the partnership (and any other funds operated by the general partner or its affiliates).

f) To facilitate the execution, continuation or termination of the contractual relationship between an investor and the general partner, the partnership and/or any other Authorized Entity (as applicable).

g) To facilitate the transfer of funds, and administering and facilitating any other transaction, between an investor and the applicable fund and/or any other Authorized Entity (as applicable).

h) To enable any actual or proposed assignee or transferee, participant or sub-participant of the partnership’s or the applicable fund’s rights or obligations to evaluate proposed transactions.

i) To facilitate business asset transactions involving the applicable fund’s partnership or the applicable fund related vehicles, and/or including due diligence carried out by any third party that acquires, or is interested in acquiring or securitizing, all or part of the applicable fund’s assets or shares, or that succeeds to it in carrying on all or a part of its businesses, or services provided to it, whether by merger, acquisition, financing, reorganization or otherwise.

j) Any legal or regulatory requirement.

k) Keeping investors informed about the business of the general partner and its respective affiliates generally, including offering opportunities to make investments other than in the applicable fund.

l) Any other purpose that has been notified, or has been agreed, in writing.

The Authorized Entities may monitor communications where the law requires them to do so. The Authorized Entities may also monitor communications where permitted to do so, to protect their respective businesses and the security of their respective systems.

Sharing and transfers of personal data

In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where permitted by UK-EEA Data Protection Legislation, to other service providers, investors, portfolio companies, regulators or other governmental entities, custodians, administrators, transfer agents, employees, agents, contractors, consultants, professional advisers, lenders, processors and persons employed and/or retained by them and/or any other third parties in order to fulfil the purposes described in this EEA-UK Privacy Notice and any third party that acquires, or is interested in acquiring or securitizing, all or part of the applicable fund’s assets or interests, or that succeeds to it in carrying on all or a part of its businesses, or services provided to it, whether by merger, acquisition, reorganization or otherwise. In addition, any Authorized Entity may share personal data with regulatory bodies having competent jurisdiction over them, as well as with the tax authorities, auditors and tax advisers (where necessary, required or advisable to comply with law).

Any Authorized Entity may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfil the purposes described in this EEA-UK Privacy Notice and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer investor agreements, and to implement requested pre-contractual measures. Transfers of personal data may be made further to applicable adequacy decisions, appropriate or suitable safeguards permitted under the UK-EEA Data Protection Legislation (such as the standard contractual clauses issued by the European Commission and/or the UK equivalent) or any other valid means permitted by applicable law. For information on the safeguards applied to such transfers, please contact the general partner. For the purposes of this EEA-UK Privacy Notice, “Non-Equivalent Country” shall mean a country or territory other than: (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by applicable authority, including the European Commission or the government of the UK and/or the UK Information Commissioner’s Office (as applicable) in accordance with UK-EEA Data Protection Legislation to ensure an adequate level of protection for personal data.

Retention and security of personal data

The general partner and its affiliates consider the protection of personal data to be a sound business practice, and to that end, employ appropriate technical and organizational measures, including robust physical, electronic and procedural safeguards which seek to protect personal data in their possession or under their control.

Personal data will not be retained for longer than necessary, with regards to the purposes described in this EEA-UK Privacy Notice, or as long as is required to comply with applicable legal or regulatory obligations. Personal data will be retained throughout the life cycle of any investment in the applicable fund. The applicable fund maintains personal data of former investors and apply the same policies that apply to current investors.

Data Subject Rights

It is acknowledged that, subject to applicable UK-EEA Data Protection Legislation, investors or the data subjects to which personal data relates, have certain rights under UK-EEA Data Protection Legislation including: to obtain information about, or (where applicable) withdraw any consent given in relation to, the processing of their personal data; to access and receive a copy of their personal data; to request rectification of their personal data; to request erasure of their personal data; the right to data portability; and the right not to be subject to automated decision-making. Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, erasure of the personal data requested to fulfil the purposes described in this EEA-UK Privacy Notice may result in the inability to provide the services required in connection with investor agreements.

In case a data subject to whom personal data relate disagrees with the way in which their personal data is being processed in relation to investor agreements, the data subject has the right to object to this processing of personal data and request restriction of the processing. The data subject may also lodge a complaint with the competent data protection supervisory authority in the relevant jurisdiction.

A data subject may raise any request relating to the processing of their personal data via email at: info@mapleparkcap.com.