Your privacy is important to A&M Capital Advisors, LP, such other companies forming part of the A&M Capital group of companies and our affiliates (together, “AMC”, “our”, “us”, “we” or “Fund”). To better protect your privacy, we are providing information explaining our online information practices.
This Privacy Notice (the “Notice”), which is supplemented by the EU and UK Privacy Notice and California Privacy Notice (each, a “Jurisdiction-specific Notice”), as applicable, describes how we collect and process personal data, personally identifiable information, personal information or other similar terms (referred to in this Notice as “personal data”) about you, how we use and protect your personal data and the rights you may have in relation to your personal data. Please read this Notice carefully.
If you are an individual located in the European Union (“EU”), the European Economic Area (“EEA”) or the United Kingdom (“UK”), please refer to the [ EU and UK Privacy Notice] for more information about your rights and how to exercise them, to the extent that the EU and UK Privacy Laws (as defined therein) applies.
If you are a natural person residing in California, please refer to the [California Privacy Notice] for more information about your rights and how to exercise them.
This Notice, and the Jurisdiction-Specific Notices, apply to any personal data we collect about you by us (or our service providers):
This Notice and the Jurisdiction-specific Notices do not apply to any processing of personal data by or on behalf of AMC that is covered by a more specific privacy notice, including with respect to any personal data processed about actual or potential investors of investment vehicles related to AMC.
Information regarding how we process personal data collected via the “Investor Login” page, is set out in our applicable Private Placement Memorandum and/or Subscription Booklet.
If you have any questions regarding our use of your personal data, or this Notice, please contact info@am-capital.com.
We collect, use, store and transfer the following kinds of personal data about you, depending on the nature of our relationship with you:
Further information about the legal bases under which we process your personal data is included in the section headed [Why we use your personal data].
You do not need to take any action as a result of this Notice, but you do have certain rights as described below in the section headed [Your rights] .
We rely on various legal bases under applicable data protection legislation in order to process your personal data, including our legitimate interests, contractual necessity and as required by law. We use the personal data we collect to operate our business and provide you with the services and products we offer and perform essential business operations. Please note that we may process your personal data in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law. We do not collect any special categories of personal data about you, nor information about criminal convictions and offences.
We may also process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data. We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations and failure to provide this information means that we cannot provide our services or products to you). In this case, we may have to cancel a service or investment you have with us but we will notify you if this is the case at the time.
To the extent that you provide us with, or we otherwise collect, any personal data, through or in connection with Our Website, we may use such information for the below purposes and may process your personal data on more than one legal basis depending on the specific purpose:
No automated decision-making or profiling, is used when processing your personal data.
We will only send you information communications where you have requested information from us relating to our products and services which you might be interested in, including by emailing the “general enquiries” email address listed in the “Contact” section of Our Website. You may request we stop sending you information communications by emailing info@am-capital.com at any time.
Your personal data may be shared with and processed by third parties, including our group companies and affiliates, certain service providers and our agents as necessary to fulfil the purposes set out in this Notice, including, but not limited to legal and financial professional advisors, auditors, recruitment firms, agents, contractors, IT and data security providers and data hosting providers, and in some instances, placements agents and other fund administrators. We require anyone who provides a service to, or for us, enters into an agreement with us to ensure the provider meets our standards for data security and treats your personal data in accordance with applicable data protection law. We do not allow third-party service providers to use your personal data for their own purposes in accordance with our instructions. We do not authorise these third-party service providers to use or disclose the personal data except as necessary to perform services on our behalf or comply with legal requirements.
We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal data to the new owner of the relevant business and their advisors.
We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate security measures and policies, so the information we have about you is protected to the extent possible from unauthorized access, loss, destruction or improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through Our Website; any transmission of information or data by you to or through this site is at your sole risk.
We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Notice, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. We may also retain your personal data so that we can continue to improve your experience with us and to ensure that you receive any information or marketing materials which would benefit you. We will also keep your personal data where we need to do so in connection with regulatory requirements, legal action or an investigation involving AMC and our affiliates. Once our processing of your personal data is no longer necessary, we will securely destroy your personal data in accordance with applicable laws and regulations. For further information about how long we will keep your personal data, please contact info@am-capital.com.
Our Website is only intended for individuals who are at least thirteen (13) years of age. We do not knowingly encourage or solicit visitors to this site, or collect personal data (without parental consent), from anyone who is under the age of thirteen (13). If we learn we have collected or received personal data from an individual under the age of thirteen (13), we will delete that information.
Under certain circumstances, by law you have the right to:
Please also refer to the [ EU and UK Privacy Notice] and [California Privacy Notice] (as applicable) for more specific information about your rights. If you would like more information about your rights, or have any concerns about AMC’s processing of your personal data, please let us know by getting in touch with us using the details in the [Contact us] section above.
Our Website may provide access or contain links to websites and services owned and operated by third parties. AMC does not review or monitor any such websites linked from or to the Website and is not responsible for the content of any such sites, or any products or services contained on or accessible through such other sites, their terms of use or privacy policies. Accordingly, AMC disclaims responsibility for the information, materials, products or services obtained on or from such other websites, nor will AMC be liable in any respect for any damages arising from your access to such websites.
Third party websites may have a privacy policy or security practices different from Our Website so it is important to read the policies of those sites before sharing your personal information.
We reserve the right to amend this Notice, and the Jurisdiction-specific Notices from time to time. If we decide to change this Notice, we will post those changes so our users are always aware. If at any point we decide to collect personal data or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with the Notice under which the information was collected.
We set and use cookies to run website analytics on Our Website. The use of cookies aims to help improve your user experience. More information about how we use cookies and how you can manage your settings, is set out below.
A cookie is a small text file placed on your device or computer and is used to identify the user or device and to collect data. In summary, the cookies help remember you and how you’ve used the website every time you revisit it.
At any time, you can reset your browser so as to refuse any cookie or to alert you to when a cookie is being sent. Web browsers allow you to control cookies stored on your hard drive through the web browser settings. If you wish to know more about cookies, you will find links to some useful resources below. https://us.norton.com/internetsecurity-how-to-what-are-cookies.html https://computer.howstuffworks.com/internet/basics/question82.htm
We use cookies for several purposes. To make it easier for you to understand why we need them, we have put our cookies into the following categories (based on the guidelines found in the [UK Information Commissioner’s Office’s Cookie Guide] ):
1. Strictly Necessary Cookies: These cookies are essential to enable you to move around the website and use its features. Without these cookies, we may not be able to provide certain services you have asked for. Further details are provided in the table below:
2. Performance Cookies: These cookies collect information about how you use the website. This information may include the internet browser used, the domain name of a website previously visited, and traffic log data to identify which pages are being used. These cookies are used to help us analyse data about web page traffic, optimise the website and make it more user-friendly. Further details are provided in the table below:
3. Functionality Cookies: These cookies allow the website to remember choices you make and provide enhanced, more personal features. For example, we may store your intranet username and password, language preference, or your geographic location. We may also remember preferences such as text size, fonts and other customisable site elements. The information these cookies collect may be anonymised, will not personally identify you and cannot track your browsing activity on other websites.
We use Google Analytics to collect statistical information about how you use the website. We use the information to improve the website. The cookies collect information relating to the number of visitors to the website, and where the visitors have come to the website from. Further details are provided in the table below:
4. Advertising Cookies: Advertising cookies are used to make advertising messages more relevant to you. They prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and in some cases select advertisements that are based on your interests. Further details are provided in the table below:
5. Analytics and Customisation Cookies: Analytics and customisation cookies [, including Google Analytics] are used to provide enhanced functionality and make our website easier to use, by remembering your preferences, including the preferences you have indicated on our cookies tool. As third parties set these cookies, you must use your browser settings or visit the third party site and follow the instructions in their cookie notice in order to refuse them. Further details are provided in the table below:
To learn more about opting out of Google Analytics, please click [here].
It is important that you understand what cookies are being used by us, so please make sure you read this policy carefully. Where cookies are not necessary for us to provide the services you have requested, we will ask you to consent to their use when you first visit the website. If you wish to then manage the cookies we use, you have the ability to change the settings on your internet browser to see what cookies you have and delete them individually, accept all cookies, to notify you when a cookie is set, or to not receive cookies at any time. You can visit the ‘options’ or ‘preferences’ menu on your browser to change cookie settings. We will not need your consent to use non-privacy intrusive cookies which are necessary for the functioning of the website (i.e. the ‘Strictly Necessary Cookies’ as described in the [What We Use Cookies For] section above. Please note that if you ‘opt-out’ and choose not to consent to the use of particular cookies, we may be unable to provide certain services to you (which we will indicate at the point you opt-out).
You may wish to know more about cookies. Below are some useful resources that will provide you with detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org/ or www.allaboutcookies.org/.
If you have any questions about this Cookie Policy, please contact us at info@am-capital.com.
Last Updated: October 2023
This California Privacy Notice supplements the Notice 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 focused supplement is otherwise set forth in the Notice. 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.
We collect limited types of personal data through Our Website as well as through other electronic communications (e.g., emails), as applicable. The types of personal data we collect about you depends on the nature of your interaction with us. The categories of personal data we collect or have collected from individuals over the last twelve (12) months include the following:
We do not collect or use sensitive personal information other than:
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked.
We may use your personal data for one or more of the business or commercial purposes set forth above in the “Why We Use Your Personal Data” section of the Notice. We retain the categories of personal information set forth above in the “Information We Collect” section of this California Website Privacy Policy only as long as is reasonably necessary for those business or commercial purposes set forth in the “Why We Use Your Personal Data” section of the Notice, except as may be required under applicable law, court order or government regulations.
We do not sell or share (as such terms are defined in the CCPA) any of the personal data we collect about you to third parties, nor have we done so in the past twelve (12) months.
We do not disclose any nonpublic personal data 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 disclosed each of the categories of personal data collected with affiliates and service providers for a business or commercial purpose as set forth in the chart below.
We may also share your personal data with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding or other disposition of all or a portion of our business, assets or shares.
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 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 and use of personal information specific to you. Such information includes:
Correction Right: You have the right to request that we correct any inaccuracies in the PII 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.
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 on your behalf using any of the methods set forth in the Contact us section below.
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 using any of the methods set forth below.
Call us using the following toll-free number: 1-844-977-2060
Submit a request online using the following online form: https://www.a-mcapital.com/#contact.
Submit a request online using the following email: info@a-mcapital.com
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.
Please contact the Chief Compliance Officer at the email address above with any questions about this California Website Privacy Policy.
This EU and UK Privacy Notice supplements the general [Privacy Notice] with respect to individuals located in the EU, the EEA, or the UK, to the extent that EU and UK data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK implementation of the GDPR, and the UK Data Protection Act 2018 (collectively, “EU and UK Privacy Laws”) applies to the personal data processing activities set out in the general Privacy Notice. Information that is required to be disclosed to individuals located in the EU, EEA or UK that is not set out in this EU and UK Privacy Notice is otherwise set out in the general Privacy Notice.
For the purposes of applicable EU and UK Privacy Laws, AMC and/or one or more of our affiliates will be a controller of any personal data collected by us. As a "controller" under applicable data protection laws, we are responsible for deciding how we collect and use personal data about you and for the information contained in this EU and UK Privacy Notice.
If you are a natural person in the EU or the UK and the EU and UK Privacy Laws apply to you, and have any questions about the EU and UK Privacy Notice, including any requests to exercise your legal rights, you may contact us at info@am-capital.com.
Our general Privacy Notice sets out [The Data We Collect about You] . We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, etc.).
We rely on various legal bases under the EU and UK Privacy Laws in order to process your personal data, as we have set forth in the general Privacy Notice in the section [Why We Use Your Personal Data] . The section also sets out the specific purposes for which we use your personal data, which in general is to operate our business, conduct business with you and perform essential or legitimate business operations.
If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of failure to provide this personal data (e.g., inability to conduct business with you and cancelling an existing arrangement, receiving an unoptimized user experience when visiting our website, etc.).
Your personal data may be transferred to, and stored at, a destination outside the EEA which may not always have data protection laws providing equivalent protection. To the extent your personal data is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable data privacy laws and we will take steps to ensure that your information is protected by appropriate organisational and security measures, and that any such transfers are done using specific legally-approved safeguards. For further information about the safeguards used and details of any relevant non-EEA countries, please contact info@am-capital.com.
Note that this section of the EU and UK Privacy Policy only applies to the extent that the EU and UK Privacy Laws apply to you. You have the right to access and control (in certain ways) the personal data we process about you. To exercise these rights and controls, please contact info@am-capital.com.
We may need to request specific information from you to help us confirm your identity and ensure your right to exercise the above rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. We would, however, appreciate the opportunity to deal with your concerns before you approach a relevant supervisory authority, so please contact us in the first instance.
In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.
In the EU, please contact your local supervisory authority in particular in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.
This EU and UK Privacy Notice may be updated periodically to reflect changes in our personal data practices or as required by law. We reserve the right to amend this EU and UK Privacy Notice from time to time by updating this EU and UK Privacy Notice. Accordingly, users should review this EU and UK Privacy Notice regularly. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users by posting changes on this page.
If you have any questions or requests regarding this Notice or the personal data that we hold about you, or need additional information, please contact info@am-capital.com.
The following companies are your “controllers” and are responsible for the collection, use, disclosure, retention and protection of your personal data in accordance with our privacy standards as well as the EU and UK Privacy Laws:
A&M Capital Europe
6 Grosvenor Street
Mayfair, London W1K 4PZ
8 Rue Lou Hemmer, L-1748,
Senningerberg, Luxembourg
A&M Capital North America
1 Pickwick Plaza
3rd Floor
Greenwich, CT 06830
1201 Morningside Drive
Suite 200 – 2nd Floor
Manhattan Beach, CA 90266
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