CoastRock Capital Management

Privacy Policy

General

For purposes of this Privacy Policy, the terms “you” and “your” include any former, current, and/or prospective clients and/or investors in the pooled funds advised by and/or investment strategies utilized by CRC Equity Investors, L.P., in addition to the other uses of such terms as indicated in the preliminary provisions of these Terms of Use.

CoastRock Capital Management takes precautions to maintain the privacy of your nonpublic personal information (“Nonpublic Personal Information”) that is obtained by or on behalf of CoastRock Capital Management in connection with your access to and use of a CoastRock Capital Management Website, or your investment in any of the CoastRock Capital Management pooled funds and/or investment strategies. These precautions include the adoption of certain physical, technical and/or administrative procedures designed to maintain and secure such Nonpublic Personal Information from unauthorized disclosure to third parties. Federal regulations require CoastRock Capital Management to inform you of this privacy policy.

Nonpublic Personal Information may be provided by you or on your behalf (such as through a Purchaser Representative) and contained in the following documents or formats that will be accessible by CoastRock Capital Management:

Subscription documents or other investment-related documents or forms available on or through a CoastRock Capital Management Website;

Account statements maintained by CoastRock Capital Management or third parties pertaining to your transactions in any of the CoastRock Capital Management pooled funds and/or investment strategies; and/or

Reports from consumer reporting bureaus and/or other information reporting sources.

Information Handling

With respect to outside entities and individuals who are not CoastRock Capital Management Parties, CoastRock Capital Management does not disclose any of your Nonpublic Personal Information, except in the following circumstances and/or for the following purposes:

where you provide a written authorization allowing CoastRock Capital Management to release your Nonpublic Personal Information to a designated third-party, such as (by way of example only and not limitation) professional service providers, brokerage and trading firms, and financial institutions that provide services to CoastRock Capital Management and/or any of the CoastRock Capital Management pooled funds and/or investment strategies, or granting such third-parties access to your Nonpublic Personal Information for purposes relating to your investment in any of the pooled funds and/or investment strategies (such designated third-parties referred to separately and collectively as “Designated Recipients”);

to ensure compliance with obligations under applicable regulatory regimes, and/or as required or permitted to comply with laws or regulations as applicable to the business activities of CoastRock Capital Management, including (but not limited to) disclosing all or portions of such Nonpublic Personal Information to regulatory authorities in connection with regular or special inquiries, inspections or examinations;

in response to any facially valid judicial or quasi-judicial order or non-judicial compulsory process issued in connection with any private civil, criminal, and/or regulatory enforcement proceeding or action.

CoastRock Capital Management requires Designated Recipients to demonstrate that they have policies and procedures reasonably designed to safeguard the confidentiality of any Nonpublic Personal Information that is shared with them, and that such policies and procedures are continuously enforced and routinely monitored. In addition, Designated Recipients must agree to use the information only for the purpose(s) for which it is disclosed to them.

With respect to the affiliated entities and individuals who comprise the CoastRock Capital Management Parties, CoastRock Capital Management allows access to your Nonpublic Personal Information only in the following circumstances and/or for the following purposes:

to employees and consultants who are bound by confidentiality obligations that restrict the disclosure and use of Nonpublic Personal Information, and whose employment or contractual responsibilities to CoastRock Capital Management place them in a position of needing to know the information in order to facilitate the ability of CoastRock Capital Management to provide investment advisory and related services, or to otherwise to lawfully discharge legal or fiduciary obligations.

for internal CoastRock Capital Management business purposes.

All CoastRock Capital Management employees are bound by an Employee Handbook that includes policies and procedures for safeguarding confidential and proprietary information, including Nonpublic Personal Information, and which include an array of sanctions up to and including termination of employment for events of noncompliance. Each consultant to CoastRock Capital Management is required to sign our Non-disclosure Agreement that incorporates provisions similar to those contained in the Employee Handbook.

CoastRock Capital Management maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard Nonpublic Personal Information and which CoastRock Capital Management believes are adequate to prevent unauthorized disclosure of such information.

Information Collected Through a CoastRock Capital Management Website

Personally Identifiable Information

In addition to the foregoing, CoastRock Capital Management may collect personally identifiable information through a CoastRock Capital Management Website, such as your name, address, telephone number, e-mail address, or other similar information. Your submission of such information is entirely voluntary. However, if you decline to provide such information when prompted, you may not have full access to certain features or areas of a CoastRock Capital Management Website, or to certain Content.

By submitting personally identifiable information on a CoastRock Capital Management Website, you are consenting to the use of such information by CoastRock Capital Management in the manner described under the “Information Handling” heading above, and you further grant CoastRock Capital Management the right to use and store such information on its internal systems and to transfer it to other CoastRock Capital Management Parties, whether inside or outside the United States, for the purpose of providing services to you.

If you are a citizen of a member country of the European Union, you should be aware that the standards of protection required with respect to the handling of personal data may not be as high in countries outside the European Union.

In addition to the uses described under the “Information Handling” heading above, CoastRock Capital Management may use or disclose personally identifiable information if CoastRock Capital Management deems it reasonably necessary to protect the rights or property of any of the CoastRock Capital Management Parties, any former, current, and/or prospective clients and/or investors in the pooled funds advised by and/or investment strategies utilized by CRC Equity Investors, L.P., any other users of a CoastRock Capital Management Website (for example in response to a denial of service attack or the introduction of malicious software to a CoastRock Capital Management Website), and any CoastRock Capital Management Website itself.

Non-Personally Identifiable Information

When you enter a CoastRock Capital Management Website, CoastRock Capital Management automatically collects information about your browser type and your Internet Protocol (IP) address(es), as well as statistical and other information that your browser sends whenever you visit websites generally (for example, the amount of time you spend on other websites and the names of websites you might have visited before you visited a CoastRock Capital Management Website). CoastRock Capital Management uses this Non-Personally Identifiable information in the aggregate to do such things as improve the service offerings on a CoastRock Capital Management Website, or to customize your experience with a CoastRock Capital Management Website. By entering a CoastRock Capital Management Website, you consent to the collection and use of such information.

Cookies

A CoastRock Capital Management Website may use “cookies,” which are small text files that are stored on your computer that retain your information and preferences relative to your activities on a website. Cookies are meant to enhance your experience on a CoastRock Capital Management Website and are used primarily to recognize registered users. For example, if you tell us to, we will send a cookie to your machine that remembers your access authorization credentials for a CoastRock Capital Management Website, thereby relieving you of the need to enter the information every time you access that CoastRock Capital Management Website.

Should you wish to prevent your computer from accepting cookies from a CoastRock Capital Management Website, you can change the settings on your web browser to either block the cookies sent from a CoastRock Capital Management Website or disable your machine from accepting cookies altogether.

A CoastRock Capital Management Website may not function properly, or may function differently, if you choose not to receive cookies or to disable the cookie functionality.