Privacy Policy

Privacy Notice

Leeds Equity Advisors LLC

Leeds Illuminate Advisors LP

Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our individual limited partners and clients. We have a long-standing policy of protecting the confidentiality and security of information we collect about you. We are providing you with this Privacy Notice to help you better understand why and how we collect certain personal information, the care with which we treat that information, and how we use that information.

Sources of Non-Public Information: In connection with forming and operating our private investment funds (or “funds”) and/or performing asset management services for our limited partners and clients, we collect and maintain non-public personal information from the following sources:

Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail and other electronic communications, or in subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification and verification documentation),
Information about your transactions with us or others, and
Information captured on our website, fund data room and/or investor reporting portal (as applicable) including registration information, information provided through online forms, and any information captured via “cookies.”

Disclosure of Information: We do not disclose any non-public 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, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

Former Limited Partners and Clients: We maintain non-public personal information of our former limited partners and clients and apply the same policies that apply to current limited partners and clients.

Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards, which seek to protect your non-public personal information in our possession or under our control.

Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time. The examples contained within this notice are illustrations only and are not intended to be exclusive. This Privacy Notice is intended to comply with the privacy provisions of applicable U.S. federal law and certain privacy provisions of other laws. You may have additional rights under other state or non-U.S. laws that apply to you, including as set forth in our additional privacy notices.

PRIVACY NOTICE SUPPLEMENT FOR CALIFORNIA RESIDENTS

This notice supplements the Privacy Notice set forth above 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 above in the Privacy 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.

Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers	Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets).	YES
C. Protected classification characteristics under California or federal law	Date of birth, citizenship and birthplace.	YES
D. Commercial information	Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).	YES
E. Biometric information	Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.	NO
F. Internet or other similar network activity	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	YES
G. Geolocation data	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	NO
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. Sensitive Personal Information (see further information on use of sensitive personal information below)	Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.	YES, as to the following types of information: social security, driver’s license, state identification care, or passport numbers, account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only.

We do not collect or use sensitive personal information other than:

To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
To perform services on behalf of our business;
To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Purposes for Collecting Personal Information: We may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes:

performing services to you, including but not limited to:

the administrative processes (and related communication) in preparing for the admission of investors to the fund(s), including administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase interests in the fund(s);
ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund and the execution of all relevant agreements;
the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
facilitating the execution, continuation or termination of the contractual relationship between an investor and the general partner or managing member, the investment adviser and/or the fund(s);
facilitating the transfer of fund interests, and administering and facilitating any other transaction, between an investor, the general partner or managing member, the investment adviser and/or the fund(s);
auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
enabling any actual or proposed assignee or transferee of the fund(s), to evaluate proposed transactions;
facilitating business asset transactions involving the funds; and
complying with U.S., state, local and non-U.S. laws, rules and regulations.

We collect personal information from the sources set forth in “Sources of Non-Public Information” in the Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this Privacy Notice Supplement only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.

Disclosure of Information: We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we have disclosed personal information collected from you for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category	Category of Third-Party Recipients
A. Identifiers	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal law	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
D. Commercial information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
E. Biometric information	N/A
F. Internet or other similar network activity	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
G. Geolocation data	N/A
H. Sensory data	N/A
I. Professional or employment-related information	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	N/A
K. Inferences drawn from other personal information	N/A
L. Sensitive Personal Information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

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 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. 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;
Categories of third parties with whom we disclose 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.

Correction Right: You have the right to request that we correct any inaccuracies in the 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.

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 below.

Call us using the following toll-free number: [888] 230-0061

Email us at the following email address: [compliance@leedsequity.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. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Please contact the Chief Compliance Officer of Leeds Equity Advisors, LLC. at compliance@leedsequity.com with any questions or concerns about this Privacy Notice.

GDPR Privacy Notice

LEEDS EQUITY ADVISORS, LLC.
LEEDS ILLUMINATE ADVISORS, LP.

This GDPR Privacy Notice applies to the extent that EU, UK or Cayman Islands Data Protection Legislation (as defined below) applies to the processing of personal data by an Authorized Entity (as defined below). If this GDPR Privacy Notice applies, the relevant data subject has certain rights with respect to such processing of their personal data, as outlined below.

For this GDPR Privacy Notice, “EU, UK and Cayman Islands Data Protection Legislation” means all applicable legislation and regulations relating to the protection of personal data in force from time to time in the EU, the EEA, the UK, or the Cayman Islands, including (without limitation): (a) Regulation (EU) 2016/679 (the General Data Protection Regulation); (b) the General Data Protection regulation as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of Section 2 of the European Union Withdrawal Act 2018; (c) any other legislation which implements any other current or future legal act of the European Union or the United Kingdom concerning the protection and processing of personal data and any national implementing or successor legislation; and (d) the Cayman Islands Data Protection Law, 2017, and including any amendment or re-enactment of any of the foregoing. The terms “data controller,” “data processor,” “data subject,” “personal data” and “processing” in this GDPR Privacy Notice shall be interpreted in accordance with the applicable EU, UK and Cayman Islands Data Protection Legislation.

Please contact the Chief Compliance Officer of Leeds Equity Advisors, LLC. at compliance@leedsequity.com with any queries arising out of this GDPR Notice.

Categories of Personal Data Collected and Lawful Bases for Processing

In connection with offering, forming and operating private investment funds for potential investors, the Partnership, the General Partner, the Management Company, their Affiliates and, in each case, their administrators, legal and other advisors and agents (the “Authorized Entities”) collect, record, store, adapt and otherwise process and use personal data, either relating to potential investors or to their partners, officers, directors, employees, shareholders, ultimate beneficial owners or affiliates or to any other data subjects, from the following sources (and all references to “potential investor(s)” in this GDPR Privacy Notice shall be to such potential investor(s) and, as applicable, any of these other persons as relate to such potential investor(s)):

Any Authorized Entity may process the following categories of personal data:

information received in telephone conversations, in voicemails, through written correspondence, via e-mail, or on subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification and verification documentation);
information about transactions with any Authorized Entity or others;
information captured on any Authorized Entity’s website, including registration information and any information captured via “cookies”; and
information from publicly available sources, including from:
(a) publicly available and accessible directories and sources;
(b) bankruptcy registers;
(c) tax authorities, including those that are based outside the UK and the EEA if you are subject is subject to tax in another jurisdiction;
(d) governmental and competent regulatory authorities to whom any Authorized Entity has regulatory obligations;
(e) credit agencies; and
(f) fraud prevention and detection agencies and organizations.
Any Authorized Entity may process the following categories of personal data:
names, dates of birth and birth place;
contact details and professional addresses (including physical addresses, email addresses and telephone numbers);
account data and other information contained in any document provided by potential investors to the Authorized Entities (whether directly or indirectly);
risk tolerance, transaction history, investment experience and investment activity;
information regarding a potential investor’s status under various laws and regulations, including their social security number, tax status, income and assets;
accounts and transactions with other institutions;
information regarding a potential investor’s interest in the Partnership, including ownership percentage, capital commitment, income and losses;
information regarding a potential investor’s citizenship and location of residence;
source of funds used to make the investment in the Partnership; and
anti-money laundering, identification (including passport and drivers’ license) and verification documentation.

Any Authorized Entity may, in certain circumstances, combine personal data it receives from a potential investor with information that it collects from or about such potential investor. This will include information collected in an online or offline context.

One or more of the Authorized Entities are “data controllers” of personal data collected in connection with the Partnership. In simple terms, this means such Authorized Entities: (a) “control” the personal data that they or other Authorized Entities collect from potential investors or other sources; and (b) make certain decisions on how to use and protect such personal data.

There is a need to process personal data for the purposes set out in this GDPR Privacy Notice as a matter of contractual necessity under or in connection with the Partnership Agreement and associated Partnership documentation and, in the legitimate interests of the Authorized Entities (or those of a third party), to operate their respective businesses. From time to time, an Authorized Entity may need to process the personal data on other legal bases, including: with consent; to comply with a legal obligation; if it is necessary to protect the vital interests of a potential investor or other data subjects; or if it is necessary for a task carried out in the public interest.

A failure to provide the personal data requested to fulfill the purposes described in this GDPR Privacy Notice may result in the applicable Authorized Entities being unable to provide the services in connection with the Partnership Agreement and/or an investor’s subscription agreement (the “Subscription Agreement”).

Purpose of Processing

The applicable Authorized Entities process the personal data for the following purposes (and in respect of paragraphs (3), (4), (6), (8) and (9) in the legitimate interests of the Authorized Entities):

The performance of its contractual and legal obligations (including all applicable anti-money laundering, know-your-customer and other related laws and regulations) in connection with assessing suitability of potential investors in the Partnership.
The administrative processes (and related communication) carried out between the Authorized Entities in preparing for the admission of investors to the Partnership.
Ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and execution of documentation) during the process of admitting investors to the Partnership and execution of the Partnership Agreement.
The ongoing administrative, accounting, reporting and other processes and communications required to operate the business of the General Partner and/or the Partnership in accordance with the Partnership Agreement and other applicable documentation between the parties.
To administer, manage and set up your investor account(s) to allow you to purchase your holding (of shares) in the Partnership (and any other funds operated by the General Partner or its affiliates).
To facilitate the execution, continuation or termination of the contractual relationship between you and the General Partner and/or the Partnership (as applicable).
To facilitate the transfer of funds, and administering and facilitating any other transaction, between you and the Partnership.
To enable any actual or proposed assignee or transferee, participant or sub-participant of the Partnership’s rights or obligations to evaluate proposed transactions.
To facilitate business asset transactions involving the Partnership’s partnership or Partnership-related vehicles.
Any legal or regulatory requirement.
Keeping investors informed about the business of the General Partner and its affiliates generally, including offering opportunities to make investments other than in the Partnership.
Any other purpose that has been notified, or has been agreed to, in writing.

The Authorized Entities monitor communications where the law requires them to do so. The Authorized Entities also monitor communications, where required to do so, to comply with regulatory rules and practices and, where not prohibited to do so, to protect their respective businesses and the security of their respective systems.

Sharing and Transfers of Personal Data

In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where not prohibited by EU, UK and Cayman Island Data Protection Legislation, to other service providers, employees, agents, contractors, consultants, professional advisors, lenders, data processors and persons employed and/or retained by them in order to fulfill the purposes described in this GDPR Privacy Notice. In addition, any Authorized Entity may share personal data with regulatory bodies having competent jurisdiction over them, as well as with the tax authorities, auditors and tax advisors (where necessary or required by applicable law).

Any Authorized Entity may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfill the purposes described in this GDPR Privacy Notice and in accordance with applicable law, including where such transfer is a matter of contractual necessity to enter into, perform and administer the Subscription Agreement and Partnership Agreement, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact the General Partner. For the purposes of this GDPR Privacy Notice, “Non-Equivalent Country” shall mean a country or territory other than (a) a member state of the European Economic Area; (b) the United Kingdom; or (c) a country or territory which has at the relevant time been decided by the European Commission or the Government of the United Kingdom (as applicable) in accordance with EU, UK and Cayman Islands Data Protection Legislation to ensure an adequate level of protection for personal data.

Retention and Security of Personal Data

The General Partner and its Affiliates consider the protection of personal data to be a sound business practice, and to that end, employ appropriate technical and organizational measures, including robust physical, electronic and procedural safeguards to protect personal data in their possession or under their control.

Personal data may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations or, where longer, such longer period as is required by applicable legal or regulatory obligations. Personal data will be retained throughout the life cycle of any investment in the Partnership. However, some personal data will be retained after a data subject ceases to be an investor in the Partnership.

Data Subject Rights

It is acknowledged that, subject to applicable EU, UK and Cayman Islands Data Protection Legislation, the data subjects to which personal data relates have the following rights under EU, UK and Cayman Islands Data Protection Legislation: to obtain information about, or (where applicable) withdraw any consent given in relation to, the processing of their personal data; to access and receive a copy of their personal data; to request rectification of their personal data; to request erasure of their personal data; to exercise their right to data portability; the right not to be subject to automated decision-making. Please note that the right to erasure is not absolute, and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, erasure of the personal data requested to fulfill the purposes described in this GDPR Privacy Notice may result in the inability to provide the services required pursuant to the Partnership Agreement and/or the Subscription Agreement.

In case the data subject to whom personal data relates disagrees with the way in which their personal data is being processed in relation to the Partnership Agreement and/or the Subscription Agreement, the data subject has the right to object to this processing of personal data and request restriction of the processing. The data subject may also lodge a complaint with the competent data protection supervisory authority in the relevant jurisdiction.

The data subject may raise any request relating to the processing of his or her personal data with the Chief Compliance Officer of Leeds Equity Advisors, LLC. at the contact information provided above.