At RLH Equity Partners and its affiliates (“RLH”), maintaining our investors’ trust and confidence is of paramount importance. We respect your privacy and are committed to (i) protecting and safeguarding your personal information and (ii) processing your personal information fairly and lawfully. This Privacy Notice (“Notice”) explains how RLH processes personal information collected in connection with investments in RLH funds and applications to invest with RLH.
This Notice replaces all previous statements and privacy notices and may be amended at any time. The latest version of the Notice is available upon request from our Director of Communications and Operations, Jessica Bramwell (jessica@rlhequity.com). Even in the unlikely event that you end your investor relationship with RLH, we will continue to adhere to the policies and practices described in this Notice (as amended from time to time).
Information We Collect
We collect personal information as follows:
Information provided in subscription agreements, investor questionnaires, limited partnership agreements or other forms. This information may include things such as names, addresses, social security numbers or other tax identification numbers, telephone numbers, investment objectives, bank account information, and information about assets and income;
Information about transactions with RLH and ownership interests in RLH funds. This could include information such as participation in one or more RLH funds, capital account balances, contributions and distributions and beneficiary information;
Information gathered from other interactions with us or our affiliates. This could include information obtained from discussions or other contact with our staff via telephone, written correspondence and electronic media, as well as personal contact details, such as email address and phone number; and
Sensitive Personal Data. With the limited exception of collecting your social security number for the transactional purposes described above, we do not seek to collect or otherwise process sensitive personal information as that term in defined under the California Consumer Privacy Act (the “CCPA”).
We collect the above-listed information in order to provide investment services and to comply with our legal obligations.
Information We Disclose
We may share nonpublic personal information about you to our affiliates or to non-affiliated third parties in the following situations:
In connection with the administration and operation of the RLH investment activities, such as disclosures to attorneys, accountants, auditors, administrators, placement agents, investment managers, banks, broker-dealers, credit providers, and relevant affiliates or service providers of these third parties;
In response 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 will not disclose nonpublic personal information we collect about you to nonaffiliated third parties except as necessary in connection with: (i) maintaining and servicing investment accounts and effectuating investment transactions and (ii) protecting against fraud and complying with our legal obligations, including responding to governmental requests. We do not sell your personal or financial information. Because we do not sell or disclose your nonpublic personal and financial information to nonaffiliated third parties except as noted above, our Notice does not contain opt-out provisions.
How We Protect the Confidentiality and Security of Personal Information
We maintain reasonable physical, electronic and procedural safeguards to protect your non-public personal information as part of our efforts to comply with applicable state and federal privacy laws and regulatory rules.
California Residents
If you are a California resident, please see RLH’s California Privacy Notice to learn about our practices regarding the collection, use and disclosure of personal information of individuals who are covered by the California Consumer Privacy Act, and how covered individuals can exercise their rights.
Data Retention
The length of time we hold your personal information will vary. The data retention period will be determined by various criteria, including the purposes for which we are using it and the benefit of maintaining information for potential tax, audit and regulatory exam responses. Once we have determined that we no longer need items of personal information, we may destroy or erase from our systems such personal data.
Changes to this Privacy Notice
We reserve the right to change this Notice at any time and without prior notice. We will distribute any changes to this Notice to the contact information provided in the subscription documentation, as it may be updated from time to time.
Questions
If you have any questions in relation to this Notice or our privacy practices, please contact Jessica Bramwell at (949) 428-2205 or via mail at c/o RLH Equity Partners, 10900 Wilshire Blvd, Suite 850, Los Angeles, CA 90024.