Privacy Policy

Our Commitment to Your Privacy

We are sensitive to the privacy concerns of our individual investors. Our policy is to protect the  confidentiality and security of information we collect about you. We are providing you with this 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 Nonpublic Information

In connection with forming and operating our private investment funds and/or performing asset management  services for our limited partners and clients, we collect and maintain nonpublic personal information from  the following sources:

  • Information we receive from you in conversations over the phone, through email, and through  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, 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 may disclose any of the information we collect, as described above, in connection with Fund transactions,  financial reports, or other reports, or for other purposes to third parties and our financial service or non financial service affiliates, including:

  • Financial service providers, such as broker-dealers, custodians, banks, lenders, and others used  to facilitate transactions for investors or our private funds;
  • Other service providers to the general partner, the manager, their affiliates and/or our private  funds, such as legal, consulting, administration, accounting, auditing, or tax preparation services  and placement agents,
  • Portfolio companies, co-investors in portfolio companies and their respective advisors, if  requested in connection with an investment and,
  • Other private fund partners or investors in alternative investment vehicles in connection with  closing documentation, investor reports, financial statements, or other investor  communications.

We may also disclose nonpublic personal information about you to third parties as permitted by law or  regulation and to affiliates and service providers, including, but not limited to, affiliates and government  agencies or pursuant to legal process and self-regulatory organizations, consultants and placement agents.

2 This Privacy Notice is intended only for individuals and certain entities that are essentially “alter egos” of individuals  (e.g., revocable grantor trusts, IRAs or certain estate planning vehicles).

Former Fund Investors

We maintain nonpublic 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 nonpublic 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 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 foreign or domestic laws that apply to you, including as  set forth in our additional privacy notices.

Opt Out Instructions

While we feel that the ability to disclose certain nonpublic personal information about you to affiliates and  to non-affiliated third parties will allow us to best serve you, if you prefer that we not so disclose such  information about you, you may opt out of those disclosures (other than disclosures otherwise permitted by  law or regulation). To do so, please contact the General Partner. If you do not wish to opt out of such  disclosures, no action is required by you.

PRIVACY NOTICE SUPPLEMENT FOR CALIFORNIA RESIDENTS

This notice*  supplements the Sentinel Global Privacy Policy with respect to specific rights granted under the  California Consumer Privacy Act of 2018 (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:

  • Identifiers, such as name, contact details, and address (including physical address, email  address, and IP address), and other identification (including social security number, passport  number, and drivers’ license or state identification card number);
  • Other customer records, such as 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);
  • Protected classification characteristics under California or federal law, such as date of birth,  citizenship, and birthplace;
  • Commercial information, such as 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, and/or source of funds used to make the  investment in the applicable fund(s); and
  • Internet or other electronic network activity information, such as information regarding your  use of our website, 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.

Within the last twelve (12) months, we have shared each of the categories of personal information collected  with affiliates and third-party service providers as set forth in “Disclosure of Information” in the Privacy  Notice above, and we collect personal information from the sources set forth in “Sources of Nonpublic  Information” in the Privacy Notice above.

Purposes for Collecting Personal Information

We may collect or share 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:

* To be conformed subscription booklet privacy policies, when finalized.

  • the administrative processes (and related communication) in preparing for the admission of  investors to the Funds;
  • 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 Funds;
  • 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 their governing documents and other documentation between the parties, including  customer service, processing, or fulfilling transactions, verifying personal information,  processing contributions, and distributions and financing; and
  • 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;
  • auditing and verifications related to investor interactions, including but not limited to verifying  the quality and effectiveness of services and compliance;
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal  activity; and
  • complying with U.S., state, local, and non-U.S. laws, rules, and regulations.

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

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.

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; • 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 by emailing compliance@sentinelglobal.xyz.

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 your investor portal access credentials 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. We will inform you in writing if we cannot meet that timeline. Please contact the Compliance  Department at compliance@sentinelglobal.xyz with any questions about this Privacy Notice.

EU PRIVACY NOTICE

This EU Privacy Notice4 applies to the extent that EU Data Protection Legislation (as defined below) applies  to the processing of personal data by an Authorised Entity (as defined below) or to the extent that a data  subject is a resident of the United Kingdom (the “UK”), the European Union (“EU”), or the European  Economic Area (“EEA”). If this EU Privacy Notice applies, the data subject has certain rights with respect  to such personal data, as outlined below.

For this EU Privacy Notice, “EU 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 Luxembourg, including, without limitation: Regulation (EU) 2016/679 (the General Data Protection  Regulation) and any national implementing or successor legislation (including any data protection law  applicable in Luxembourg such as the law of 1st August 2018 on the organization of the National  Commission for Data Protection and the general regime on data protection, as may be amended or replaced),  or any other legislation which implements or supplements any other current or future legal act of the  European Union concerning the protection and processing of personal data and any national implementing  or successor legislation, and including any amendment or re-enactment of the foregoing. The terms “data  controller”, “data processor”, “data subject”, “personal data”, and “processing” in this EU Privacy Notice  shall be interpreted in accordance with the applicable EU Data Protection Legislation.

Please contact the CCO with any queries arising out of this EU Privacy Notice.

Categories of personal data collected and lawful bases for processing

In connection with offering, forming and operating private investment funds for existing and potential  investors, the General Partner acting as data controller on behalf of the Partnership (the “Data Controller”)  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 existing  and 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 “existing  investor(s)” or “potential investor(s)” in this EU Privacy Notice shall be to such existing investor(s) or  potential investor(s), respectively, and, as applicable, any of these other persons as relate to such existing  investor(s) or potential investor(s), respectively):

(a) 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,  “know-your-client”, identification, and verification documentation);

(b) information about transactions with any Authorized Entity or others;

(c) information captured on any Authorized Entity’s website, including registration  information and any information captured via “cookies”; and

(d) information from available public sources, including from:

  • publicly available and accessible directories and sources;
  • bankruptcy registers;
  • tax authorities, including those that are based outside the UK and the EEA if an existing  or potential investor is subject to tax in another jurisdiction;

4 To be conformed to subscription booklet privacy policies, when finalized.

  • governmental and competent regulatory authorities to whom any Authorized Entity has regulatory obligations;
  • credit agencies; and
  • fraud prevention and detection agencies and organizations.

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

  1. names, dates of birth and birth place;
  2. contact details and professional addresses (including physical addresses, email addresses and telephone numbers); account data and other information contained in any document provided by investors to the Authorized Entities (whether directly or indirectly);
  3. information regarding your use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history);
  4. risk tolerance, transaction history, investment experience and investment activity;
  5. information regarding an investor’s status under various laws and regulations, including social security number, tax status, income and assets;
  6. accounts and transactions with other institutions;
  7. information regarding an investor’s interest in the Partnership, including ownership percentage, capital commitment, income and losses and any other Confidential Information relating to an investor;
  8. information regarding an investor’s citizenship and location of residence; (i) source of funds used to make the investment in the Partnership; and
  9. 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 an existing or  potential investor with information that it collects from, or about such potential investor. This will include  information collected in an online or offline context.

The Authorized Entities may, as the case may be, process the personal data as data processors (when  processing the personal data on behalf and upon instructions of the Data Controller), or as distinct data  controllers (when processing the personal data for their own purposes, namely fulfilling their own legal  obligations).

There is a need to process personal data for the purposes set out in this EU 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 (orthose 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 an existing investor, a potential investor or other data subjects; or if it is necessary for a  task carried out in the public interest.

The legitimate interests referred to above are the processing purposes described in point (f) and (g) of the  below section, the provision of the proof, in the event of a dispute, of a transaction or any commercial  communication as well as in connection with any proposed purchase, merger or acquisition of any part of  the Partnership’s business; and exercising the business of the Partnership in accordance with reasonable  market standards.

A failure to provide the personal data requested to fulfil the purposes described in this EU Privacy Notice  may result in the applicable Authorized Entities being unable to provide the services in connection with the  Partnership Agreement and/or the Subscription Agreement.

Purpose of processing

The applicable Authorized Entities process the personal data for the following purposes (and in respect of  paragraphs (c), (d) and (f), below in the legitimate interests of the Authorized Entities):

(a) The performance of obligations under the Partnership Agreement and/or the Subscription  Agreement (and all applicable anti-money laundering, “know-your-client” and other  related laws and regulations), including in assessing suitability of potential investors in the  Partnership.

(b) The administrative processes (and related communication) carried out between the  Authorized Entities in preparing for the admission of investors to the Partnership.

(c) Ongoing communication with existing investors and potential investors and their respective  representatives, advisors and agents, (including the negotiation, preparation and signature  of documentation), including during the process of admitting potential investors to the  Partnership.

(d) The ongoing administrative, accounting, reporting and other processes and communication required to operate the business of the Partnership in accordance with the Partnership  Agreement and other applicable documentation between the parties.

(e) Any legal or regulatory requirement.

(f) Keeping existing and potential investors informed about the business of the General Partner  and its affiliates generally, including offering opportunities to make investments other than  to the Partnership.

(g) Any other purpose that has been notified, or has been agreed, in writing.

The Authorized Entities monitor communications where the law requires them to do so to comply with  regulatory rules and practices and, where permitted 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 permitted by EU Data Protection Legislation, to other service providers, employees, agents,  contractors, consultants, professional advisers, lenders, data processors and persons employed and/or  retained by them in order to fulfil the purposes described in this EU 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 advisers (where necessary or required by law).

Any Authorized Entity may transfer personal data to a Non-Equivalent Country (as defined below), in order  to fulfil the purposes described in this EU 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 and in order to get copies of such safeguards as the  case may be, please contact the General Partner. For the purposes of this EU Privacy Notice, “Non 

Equivalent Country” shall mean a country or territory other than (i) a member state of the EEA; or (ii) a  country or territory which has at the relevant time been decided by the European Commission in accordance  with EU 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, subject to  statutory limitation periods.

Data Subject Rights

It is acknowledged that, subject to applicable EU Data Protection Legislation, the data subjects to which  personal data relates, have certain rights under EU 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; to object to the processing of personal  data for marketing purposes and 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 fulfil the purposes described in this EU Privacy Notice, may result in the  inability to provide the services required pursuant to this Subscription Agreement and the Partnership  Agreement.

In case the data subject to whom personal data relate disagrees with the way in which their personal data is  being processed in relation to this Subscription Agreement or the Partnership 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 General  Partner.

The data subjects are also informed of the existence of their right to lodge a complaint with any competent  data protection supervisory authority in their EU Member State of residence.