PRIVACY POLICY

L STREET CAPITAL WEBSITE PRIVACY POLICY

Last Modified: May 26, 2023

Visitors that are residents of California should refer to our California Website Privacy Policy supplement.

Our commitment to privacy

Your privacy is important to L Street Capital, LP and its affiliates (together, “L Street,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.

This Website Privacy Policy (this “Privacy Policy”) describes how we gather and use information for visitors of the Site (as defined below). Please read this Privacy Policy carefully. If you do not agree with any of the terms and conditions contained herein, please do not access or otherwise use the Site.

This Privacy Policy has been established to inform you of our practices for collecting, using, maintaining, protecting, and disclosing information that we obtain from you in connection with your user of this website and its sub-pages (the “Site”), whether through a personal computer, mobile device, or otherwise. By entering and using the Site, you acknowledge your acceptance of, and agree to be bound by, the Privacy Policy stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Privacy Policy, please do not access or use the Site.

What is personally identifiable information?

Personally identifiable information (“PII”) is information about an individual, which may include first and last name, physical street address, email address, telephone number, Social Security number, payment card information, birth date, employment history, veteran status, certain health related data, passport information and photographs, or any other information that permits a specific individual to be contacted physically or online or otherwise personally identified. PII does not include aggregated information that does not allow a person in possession of such information to identify you individually.

The information we collect and how we use it

We may collect various types of information from users of the Site. For example, knowing how users use our website – tracking their movement through the Site – helps us improve website design and usefulness. As a result, L Street Capital’s server collects general data pertaining to users, including the length of time spent on the Site, the pages accessed while visiting the Site and Internet Protocol (IP) addresses. L Street Capital generally does not, however, collect any PII such as names, home addresses or email addresses from users of the Site, unless a user submits such information to us via our “Contact Us” page. In addition, when you use the Site a “cookie” may be used, as further described below.

To the extent that you provide us with any PII through or in connection with the Site, we may use such information for L Street Capital’s business purposes, but will not disclose any PII about you to anyone, except as permitted or required by law or regulation and to service providers. In providing PII to L Street Capital, you consent to L Street Capital’s use of such PII for the purposes described in this Privacy Policy.

Capacity

You represent to L Street Capital that you have the authority to visit the Site according to the Terms of Use. The Site is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to the Site who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received PII from an individual under the age of 18, we will delete that information.

Cookies

Information regarding how you access the Site (e.g., browser type, access times and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of “cookies” (a small data file placed on the hard drive of your computer) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of the Site, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of the Site. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

Security

We implement security measures designed to protect any PII submitted by or collected from you from unauthorized access. (We further protect your PII from potential security breaches by implementing certain technological security measures in accordance with generally accepted industry practices.) However, these measures do not guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software. By using the Site, you acknowledge that you understand and agree to assume these risks.

Notification of changes

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with this Privacy Policy under which the information was collected. Your continued access or use of the Site following the posting of changes to this Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing the Site. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.

Unsubscribe, Access, Questions and Further Information

You will have an opportunity to unsubscribe from our marketing email communications whenever such email communications are sent.

Data Retention

We may retain PII we collect from you and PII you provide to us in connection with our internal record-keeping policies and as reasonably necessary to comply with our legal obligations and regulatory requirements, resolve disputes, prevent fraud or abuse and enforce our Privacy Policy and Terms of Use.

Notwithstanding the foregoing, information we collect from you and information you provide to us may be retained for a limited period of time if requested by a governmental authority.

Links

The Site may contain links or references to other websites outside of our control. Please be aware that we have no control over these sites and this Privacy Policy does not apply to these sites. We encourage you to read the privacy policies/statements and terms and conditions of linked or referenced sites that you enter.

Miscellaneous

The provisions in our Terms of Use are hereby incorporated by reference.

Contact us

If you have any questions or concerns about this Privacy Policy, please contact L Street Capital at [email protected]

CALIFORNIA WEBSITE PRIVACY POLICY

Last Modified: May 2023

This California Website Privacy Policy supplements the Website Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (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 in the Website Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this California Website Privacy Policy apply to?

This California Website Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to us through another means (e.g., as an employee or seeking employment, as a client or as an investor), you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you?

We collect limited types of personal information through our website and investor reporting portals,as well as through other electronic communications (e.g., emails), as applicable (collectively, our “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on our Website over the last twelve (12) months include the following:

  • Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address);
  • Other customer records, such as telephone number and personal information provided in connection with obtaining account access;
  • Commercial information, such as account data;
  • Professional or employment-related information;
  • Education information;
  • Internet or other electronic network activity information, such as information regarding your use of our Website, fund data room and investor reporting 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.
 

We do not knowingly collect or solicit personal information from anyone under the age of 18.

How do we obtain your personal information?

In connection with forming and operating our Website, we collect and maintain your non-public personal information from the following sources:

  • Information from your communications with us in connection with our Website, including any update notices provided by you.
  • Information captured on our Website, including registration information, information provided through online forms and any information captured via cookies.
 

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

How do we use your personal information?

We will use your personal information for one or more of the following business purposes:

  • To perform services for you.
  • To improve our Website and the products and services that we offer and notify you about changes to our products and services.
  • To communicate with you, including responding to requests for information submitted by you through our Website.
  • To keep a record of your relationship with us.
  • Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
  • To audit and verify the quality and effectiveness of our services and compliance.
  • To detect security incidents and to protect against malicious, deceptive, fraudulent or illegal activity.
  • To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.
 
Who do we share your personal information with?

We do not sell any of the personal information we collect about you to third parties.

We do not disclose any nonpublic personal information about you to anyone, except 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, state and federal governmental agencies or pursuant to legal process, regulatory entities, self-regulatory organizations, consultants, third-party due diligence providers and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with our Website with affiliates and service providers as set forth above in the “What information do we collect about you?” section, above.

How do we keep your personal information secure?

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Your 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 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.

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;
  • the 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 in the “Contact us” section, below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request by emailing us at [email protected].

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 further information or your investor portal access credentials, if applicable, 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.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required. Please contact L Street Capital at [email protected] with any questions about this California Website Privacy Policy.