Categories of Personal Information We Collect
We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:
- Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and drivers’ license or state identification card number);
- Other customer records, such as 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 clients’ status under various laws and regulations (including social security number, tax status, income and assets);
- Protected classification characteristics under state or federal law, such as date of birth, citizenship and birthplace;
- Commercial information, such as account data and other information contained in any document provided by clients to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity; and
- Internet or other electronic network activity information, such as information regarding your use of our website and client portal (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.
Within the last twelve (12) months, we have shared each of the categories of personal information collected with affiliates and third-party service providers, and we collect personal information from the sources set forth above.
Purposes for Collecting Personal Information
We may collect or share the personal information we collect about you for one or more of the following business or commercial purposes:
- performing services to you, including but not limited to:
- the administrative processes (and related communication) in preparing for the admission of investors to the fund(s);
- 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;
- 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;
- 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;
- 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;
- auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
- detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and
- complying with U.S., state, local and non-U.S. laws, rules and regulations.
WE DO NOT SELL ANY OF THE PERSONAL INFORMATION WE COLLECT ABOUT YOU TO THIRD PARTIES.
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.
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 with whom we share 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.
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 notice in an alternative format, please submit a request using any of the methods set forth below.
Via email: to eseger@icapitalmgt.com
Telephone: please submit your request and telephone number by email to eseger@icapitalmgt.com and we will call you between 9 a.m. and 6 p.m. Eastern Time.
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 in order 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.
*Some state laws give residents additional rights to limit sharing. Under these laws, we may not be able to share information of minors who are of a certain age. In some states, this age is 13 years old. In order to share this information, we must first written permission (“opting-in”). If we do not receive permission to share personal information, then we are prohibited from sharing it or processing it for targeted advertising.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. Please contact Eric Seger, the Chief Compliance Officer of Integrated Capital Management at eseger@icapitalmgt.com with any questions about this Privacy Notice.
PRIVACY NOTICE SUPPLEMENT: CALIFORNIA RESIDENTS
California law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the California Attorney General at P.O. Box 944255, Sacramento, CA 94244; phone (916) 210-6276.
PRIVACY NOTICE SUPPLEMENT: COLORADO RESIDENTS
Colorado law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, Colorado Department of Law at 1300 Broadway, 10th Floor, Denver, CO 80203; phone (720) 508-6000.
PRIVACY NOTICE SUPPLEMENT: DELAWARE RESIDENTS
Delaware law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, 820 N. French St., Wilmington, DE 19801; phone (302) 577-8400; email attorney.general@delaware.gov.
PRIVACY NOTICE SUPPLEMENT: FLORIDA RESIDENTS
Florida law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, PL-01 The Capitol, Tallahassee, FL 32399-1050; phone (866) 966-7226.
PRIVACY NOTICE SUPPLEMENT: IOWA RESIDENTS
Iowa law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, 1305 E. Walnut Street, Des Moines IA 50319; phone 888-777-4590; email consumer@ag.iowa.gov.
PRIVACY NOTICE SUPPLEMENT: KENTUCKY RESIDENTS
Kentucky law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, 1024 Capital Center Drive Frankfort, KY 40601.
PRIVACY NOTICE SUPPLEMENT: MARYLAND RESIDENTS
Maryland law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, 200 St. Paul Place, Baltimore, MD 21202; phone 888-743-0023; email consumer@oag.state.md.us.
PRIVACY NOTICE SUPPLEMENT: MINNESOTA RESIDENTS
Minnesota law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, 445 Minnesota Street, Suite 600, St. Paul, MN 55101; phone (800) 657-3787.
PRIVACY NOTICE SUPPLEMENT: NORTH CAROLINA RESIDENTS
North Carolina law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, 9001 Mail Service Center, Raleigh, NC 27699-9001; phone (919) 716-6400.
PRIVACY NOTICE SUPPLEMENT: NEW HAMPSHIRE RESIDENTS
New Hampshire law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, 1 Granite Place South Concord, NH 03301; phone (603) 271-3658.
PRIVACY NOTICE SUPPLEMENT: OREGON RESIDENTS
Oregon law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, 1162 Court St. NE, Salem, OR 97301-4096; phone (503) 378-4400; email AttorneyGeneral@doj.oregon.gov.
PRIVACY NOTICE SUPPLEMENT: TENNESSEE RESIDENTS
Tennessee law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, P.O. Box 20207, Nashville, TN 37202; phone (615) 741-3491.
PRIVACY NOTICE SUPPLEMENT: TEXAS RESIDENTS
Texas law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, P.O. Box 12548, Austin, TX 78711-2548; phone (512) 463-2100.
PRIVACY NOTICE SUPPLEMENT: VIRGINIA RESIDENTS
Virginia law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling us at 248-593-8900. To obtain further information, contact The Office of the Attorney General, 202 North Ninth Street, Richmond, VA 23219; phone (804) 786-2071.