Greenbelt Capital Management L.P., Advisory Affiliates and Related Persons Notice of Privacy Policy & Practices
Commitment to Privacy
Greenbelt Capital Management L.P., a Delaware limited partnership (Delaware State file number: 6115903), and its advisory affiliates and related persons (collectively the “Firm,” “we,” “us” or “our”) are committed to responsibly handling personal information(1) that we collect or otherwise process regarding our investors and individuals who visit our website at https://www.greenbeltcapital.com (the “Website”), or our Investor Portal at https://citcoone.citco.com/ui/login (the “Portal”), or otherwise communicate or engage with us (“you” or “your”).
You have the right to be provided with clear, transparent and easily understandable information about how the Firm uses your personal information and certain rights you may have relating to such use.
Collection of Personal Information
The types of personal information collected by or on behalf of the Firm about you varies based on the Firm’s interactions with you (for example, whether you are an investor or an individual visiting the Website). Personal information collected by or on behalf of the Firm about individuals visiting the Website or the Portal is obtained directly from you or certain third parties. The personal information we collect about you in the course of your interaction and correspondence with the Website, or the Portal includes, but is not limited to, the following:
IP address and other online identifiers/web beacons;
details of your online browsing activities on the Website or the Portal, including the full Uniform Resource Locators (URL), clickstream to, through and from the site (including date and time), services you 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;
your browser type and version, relevant plug-ins, operating system and platform;
your time zone settings;
In relation to the Portal:
user names, passwords and other log-in information;
your account settings including any default preferences; and
a log of your browsing activities during your visit the Portal; and
any preferences we have observed, such as the types of products that interest you, or the areas of the Website that you visit.
If you are an investor (including, for the purposes of this privacy policy, a potential investor or a former investor), additional personal information collected by or on behalf of the Firm about you is obtained directly from you, your professional advisors or other third parties, and generally comes from subscription agreements, investor questionnaires, other required forms and agreements or other correspondence (including written, telephone or electronic contacts) with you regarding your accounts or transactions with non-affiliated third parties. The personal information we collect about you as an investor in the course of your interaction and correspondence with the Firm and its representatives includes, but is not limited to, the following:
basic personal details, including your name and address (and proof of name and address), email address, telephone number, any other contact details you may supply, social security number, tax details, nationality, citizenship, tax residency, date of birth and family connections;
details of your company’s directors, shareholders, secretaries, authorized signatories and other comparable officers and/or beneficiaries, and identification documents;
financial information, including, for example, banking details;
information regarding your assets and/or income and/or financial dealings, including investment history;
personal characteristics, histories, and associations data, including, for example, signature, physical characteristics or description, and lifestyle and social preferences;
details of business advisers you may employ, including wealth managers and independent financial advisers; and/or
records of all communications, including recordings of your attendance (or your representative’s attendance) at certain meetings/phone calls, and electronic communications with Firm staff and meeting notes (see below for more details).
If you are an investor, the Firm may also collect or receive personal information about you from third parties such as service providers to the Firm’s sponsored funds, investor advisors (including independent financial advisors), Firm vendors and publicly available sources such as company websites. We may collect or receive any of the personal information noted above from such third parties, and in addition, we may collect or receive the following:
details of any complaints made by you with respect to your dealings with the relevant service provider to the fund;
data received from due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks); and/or
fraud inquiries (for example, information from police reports).
In addition, if you are an investor, the Firm obtains personal information about your interests in funds (such as capital account balances and percentage interests) from the funds themselves and their other non-affiliated service providers. Please see the section entitled “Cookies” below for a discussion of our use of cookies on the Website and the Portal.
Use of Information Collected
The Firm uses your personal information to operate its business, including as follows:
to provide you with services that you have requested and to fulfill the Firm’s contractual obligations, including any contractual obligations as the general partner(s) and/or the investment advisor to a fund in which you have subscribed;
to operate the Website and the Portal;
to fulfill our contractual obligations to other third parties to whom you have provided your information;
for the Firm’s internal business administration and record keeping purposes;
for legal and regulatory compliance purposes, including as necessary to respond to governmental, regulatory or law enforcement agency requests; and/or
where required or considered appropriate, including prior to admitting you to a fund, prior to accepting capital contributions or making a capital distribution, carrying out “know-your-client” (KYC) checks and other procedures that the Firm undertakes in the course of the Firm’s ongoing business relationship with you.
The Firm generally does not send marketing messages; however, from time to time, the Firm will provide you with information on Greenbelt Capital Management sponsored funds that we may be raising. You have the right to ask us not to send you marketing messages by post, telephone or e-mail or any combination of these at any time; however you acknowledge that such information may be included in general update letters and while you may choose not to receive such updates, we are under no obligation to provide redacted versions of such letters or otherwise create separate reports on your behalf excluding such marketing information. You can also let us know at any time that you wish to change your mind and to start receiving such messages. You can do this by replying directly to the marketing message or at any time by contacting us.
Disclosure of Personal Information
We do not disclose any personal information about you except as detailed in this privacy policy. We disclose your personal information to the following third parties:
Fund and Firm vendors needed to operate the Website and the Portal, and the fund(s) associated with you, including, but not limited to: (i) legal counsel, (ii) accountants, (iii) audit firms, (iv) banks, (v) administrators, (vi) tax consultants, (vii) tax preparers, (viii) placement agents, (ix) financial advisors, (x) broker-dealers, (xi) transfer agents, (xii) custodians, (xiii) persons or entities that are assessing our compliance with industry standards, and (xiv) vendors supporting the Website or the Portal;
law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. (including the U.S. Securities and Exchange Commission) or of other countries with whom a fund (or a fund’s portfolio companies) transacts who request or require such information in order to issue business or regulatory licenses or permits; and
third parties with whom a fund (or a fund’s portfolio companies) transacts who require information to comply with local anti-money laundering laws, including banks and other financing counterparties.
In addition, we may disclose personal information as follows:
to law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. (including the U.S. Securities and Exchange Commission) or of other countries, where we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation, or if we reasonably consider that this is necessary to help prevent or detect fraud or other crime or to protect our rights, property, or safety, or that of our clients, investors or others. Such disclosure (including tax status, identity or residency or other personal or payment information, documents or self-certifications) may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
if we are under a duty to disclose or share your personal information with tax authorities, such information requested by such tax authorities, who may transfer such information to the government or the tax authorities in another country where you may be subject to tax. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
subject to any contractual confidentiality obligations, we may disclose investor names, participation on any limited partner advisory committee, jurisdiction of the investor and/or commitment size to other limited partners or prospective investors of a Greenbelt Capital Management-sponsored fund; and
if you use a financial or other adviser (as indicated on your subscription agreement or subsequently communicated to us), the details of your investments and valuations may also be provided to such adviser(s).
We do not sell or offer to sell any personal information about you to third parties.
The Firm’s Security Policies and Practices
We acknowledge that the personal information you provide may be confidential and we maintain policies and procedures designed to maintain the confidentiality of and protect your personal information in accordance with our normal procedures and all applicable laws. We maintain physical, electronic, and procedural safeguards designed to comply with U.S. federal regulations and other applicable laws, safeguard your personal information and prevent unauthorized access thereto.
We restrict access to personal information about you to solely those employees and representatives who need to know that information to provide products or services to you or otherwise in accordance with this privacy policy. When personal information about you is disclosed to non-affiliated third parties, our practice is to enter into contractual agreements, or otherwise take appropriate steps to ensure that such non-affiliated third parties have privacy policies or obligations in place, intended to protect the confidentiality of such information and to restrict such third parties from using such information other than to carry out the purposes for which we disclose such information or as otherwise required by applicable laws.
Unfortunately, the storage and transmission of electronic information is not completely secure. Although we strive to protect your personal information, for example by encrypting our outgoing email communications, we cannot guarantee the security of information stored on our or our vendors’ servers or transmitted via email or through the Website or the Portal; you transmit personal information to us at your own risk. In addition, links on the Website or the Portal may take you to third-party websites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.
We have put in place certain procedures to address any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so and otherwise as determined by the Firm.
Cookies
When you visit the Website or the Portal, one or more “cookies” are generated and deployed with your consent (if required). If you do not agree to our use of cookies, you should set your browser settings accordingly or not use the Website or the Portal. Please be aware that if you disable the cookies that we use, this may impact your user experience while using the Website or the Portal.
Two types of cookies may be used on the Website or the Portal – “session cookies” and “persistent cookies.” Session cookies are temporary cookies that remain on your device until you leave the Website or the Portal. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings).
The table below summarizes the different types of cookies we use on the Website or the Portal, together with their respective purpose and duration (i.e., how long each cookie will remain on your device).
Type of Cookie
Performance / Analytical
What do they do?
Cookies that help us understand how visitors interact with our web properties by providing information about the areas visited, the time spent on the Website and any issues encountered, such as error messages. They help us improve the performance of the Website, alert of any concerns and more.
Do these cookies collect my personal information/identify me?
These cookies do not identify you as an individual. All data is collected and aggregated anonymously. To opt out of the aggregation and analysis of data collected about you on the Website by Google Analytics, visit https://tools.google.com/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.
The Performance / Analytical cookies used on the Website includes:
Name of Cookie: _ ga
First / Third Party: First
Provider: Google
Purpose: Used to distinguish usersName of Cookie: _ gid
First / Third Party: First
Provider: Google
Purpose: Used to distinguish usersName of Cookie: _ gat_gtag_UA_2563069_13
First / Third Party: First
Provider: Google
Purpose: Used to throttle request rateName of Cookie: AMP_TOKEN
First / Third Party: First
Provider: Google
Purpose: Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
Google may adjust their cookies from time to time. Please visit https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#analyticsjs
to review their latest cookie details.
What are Cookies?
Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit the Website or the Portal. A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e., how long it will remain on your device) and a value, which is usually a randomly generated unique number.
We use cookies to make the Website or the Portal easier to use and to better tailor our web presence and products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on the Website or the Portal. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our web properties and to help us improve web structure and content. We cannot identify you personally from this information.
Most internet browsers are initially set up to automatically accept cookies. You can change the settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.
If you disable the cookies that we use, this may impact your experience while on the Website or the Portal. For example, you may not be able to visit certain areas of the Website or the Portal.
If you use different devices to view and access the Website or the Portal (e.g., your computer, smartphone, tablet), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.
If you would like more information about cookies, we can recommend www.aboutcookies.org and www.allaboutcookies.org as helpful resources. Both websites also provide instructions on how to reject cookies if you would like to do so.
Additional Information for Individuals Whose Personal Data is Subject to the GDPR
Residents of the European Economic Area (“EEA” and such residents, “EEA Resident”) have certain rights with respect to their personal data(2) pursuant to the General Data Protection Regulation (EU) 2016/679 (“GDPR”), as further described in this section. If you are an EEA Resident and do not agree with the Firm’s use of your personal data as set forth in this privacy notice, you should not submit your personal data to the Firm. However, if you do not submit certain personal data to the Firm, or if you exercise your rights to prevent the Firm from using such personal data, you should be aware that the Firm may not be able to do business with you.
For the purposes of applicable data privacy legislation, the Firm is a “controller” of EEA Residents’ personal data. We transfer, use, store and/or otherwise process your personal data outside of the EEA, primarily in the U.S., and the laws of the U.S. and certain other destination countries may not offer the same standard of protection for personal data as countries within the EEA. EEA Residents’ personal data also may be processed by staff operating outside the EEA who work for us or for one of our vendors (for example, those who supply support services to us). In addition to the U.S., we currently transfer personal data to the following countries outside of the EEA: Hong Kong and Japan.
In cases of cross-border transfers to countries outside of the EEA, if your personal data will be processed in a country with laws that may not be equivalent to, or as protective as, the laws of your home country, the Firm will take appropriate steps, in accordance with applicable laws, to require or maintain an adequate level of protection and security for your personal data. For additional information regarding such steps, please contact us using the details set forth at the end of this privacy notice.
1. Our bases for collecting and using personal information. We are entitled to use your personal data in the ways set out in this policy on the following bases:
the use of personal data is necessary for the performance of a contract with you for provision of our products and/or services (including fund subscription agreements and fund limited partnership agreements) or to take steps at your request prior to entering into such a contract;
we have legal obligations that we have to discharge (including legal obligations set forth in fund limited partnership agreements, investment advisory agreements and other operative documents);
the use of your personal data is necessary for our legitimate interests in marketing to prospective investors for the fund in which you are invested, successor funds or other Greenbelt Capital Management sponsored funds;
you have consented to such use; and/or
to establish, exercise or defend our legal rights for the purposes of legal proceedings.
We do not expect to process “sensitive” or “special” categories of personal data under the GDPR;(3) however, if we were to process such personal data, we would do so only where we have asked for your explicit consent, or otherwise where this is necessary for the establishment, exercise or defense of legal claims, or as may otherwise be permitted under applicable laws.
Provision of certain of your personal data is a legal and contractual requirement necessary to becoming an investor in any Greenbelt Capital Management sponsored fund or other pooled vehicle. If you choose not to provide such personal data, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you. If you choose to provide your consent with respect to certain processing of your personal data, you can withdraw it at any time by contacting us.
2. Retention of Personal Information. We will keep your information only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal information are available in our retention policy, which you can request by contacting us. When determining the relevant retention periods, we take into account factors, including, but not limited to, the following:
our contractual and business relationships with you;
legal obligations under applicable law to retain data for a certain period of time;
statute of limitations under applicable law);
(potential) disputes; and
guidelines issued by relevant supervisory authorities.
3. Your rights in connection with personal data. Under certain circumstances, by law you have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully;
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected;
Request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see above);
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and/or
Request the transfer of your personal data to another party in a machine-readable, commonly used and structured format.
If you want to exercise any of these rights then please contact us using the details set forth at the end of this privacy notice. The various rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your personal data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.
We will respond to your request within one month of receipt of your request. In some cases, we may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.
4. Your duty to inform us of changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your working relationship with us.
5. Fees. You will not have to pay a fee to access your personal data (or to exercise any of the other above-listed rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.
6. What we may need from you. To access your personal data (or to exercise any of the other above-listed rights), we may need to request specific information from you to help us confirm your identity and ensure your right to access the personal data (or to exercise any of your other above-listed rights). This is another appropriate security measure designed to ensure that personal data is not disclosed to any person who has no right to receive it.
7. Right to complain. If you wish to request further information about any of the above-listed rights, or if you are unhappy with how we have handled your personal data, please contact us using the details set forth at the end of this privacy notice. If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with the GDPR or other applicable data privacy legislation, you can make a complaint to the supervisory authority in your country. For example, in the UK you should contact the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/ or 0303 123 1113.
Additional Information for Individuals Whose Personal Information is Subject to the CCPA
Residents of the state of California have certain rights with respect to their personal information pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) as further described in this section. Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act (Public Law 106-102) and/or the Fair Credit Reporting Act (12 CFR 1022).
Under certain circumstances, under the CCPA you may have the right to:
Request that we disclose, free of charge, the categories and specific pieces of personal information we collect about you (and, if applicable, sell or otherwise disclose to a third party and the categories of such third parties), the sources from which such personal information was collected, and the business purpose for collecting, selling or disclosing such personal information;
Choose to opt out of the sale of your personal information. Currently, we do not sell your personal information; and
Request that we delete the personal information we have collected about you.
We will not discriminate against any California resident who exercises the rights set forth in this section.
You have the right to appoint an authorized agent to exercise these rights on your behalf. If you want to exercise any of these rights, or have your authorized agent exercise any of these rights on your behalf, then please contact us using the details set forth at the end of this privacy policy. To exercise any of these rights, we may need to request specific information from you or your authorized agent to help us confirm your identity and ensure your right to exercise these rights.
These rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you are currently an investor in one of our funds and you request that we delete the personal information we have collected about you, the CCPA permits us to deny such request and retain your personal information to the extent necessary to manage the applicable fund and our business relationship with you in connection with that fund.
For consumers with disabilities who need to access this privacy policy in an alternative format, please contact us using the details set forth at the end of this privacy policy.
(1) For the purposes of this privacy policy, the term “personal information” has the meaning given to such term (or to terms of similar intent, such as “personal data”) under applicable law, as and to the extent applicable to your rights and our obligations with respect to such information, including (as and to the extent applicable): (i) “personal information” as defined under the California Consumer Privacy Act of 2018, (ii) “non-public personal information” as defined under the Gramm-Leach-Bliley Act (Public Law 106-102), and/or (iii) “personal data” as defined under the General Data Protection Regulation (EU) 2016/679.
(2) For the purposes of this section, “personal data” has the meaning given to such term in the GDPR.
(3) “Special” or “sensitive” categories of personal data include, among other things, data concerning your health, revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or concerning your sexual orientation.
This privacy policy is current as of December 16, 2021. We reserve the right to change this privacy policy at any time, as circumstances or requirements change.
Should you have any questions or concerns relating to this privacy policy or the processing of personal information we hold about you, please contact us:
By post:
Greenbelt Capital Management L.P.
c/o Investor Relations
301 Congress Avenue | Suite 2050
Austin, TX 78701
By phone: +1-212-607-8450
By email: ir@gbcp.com