Privacy Policy

1.1

This Privacy Policy (this Policy) describes how Conqord Capital Partners, LLC and its affiliates (the Firm, we or us) collect, use, disclose, retain and safeguard personal information in connection with the website at conqordcapital.com (the Site).

1.2

This Policy applies to information collected through the Site. It does not apply to information collected by third parties whose services may be reached from the Site, nor to information governed by a separate agreement, including subscription documents and the limited partnership agreement, which contain their own confidentiality provisions.

1.3

This Policy forms part of the Terms of Use. Capitalized terms not defined here have the meanings given in the Disclosures.

2.1

Information you provide. When you submit an inquiry or request the quarterly letter, we collect your name and electronic mail address and, where you supply them, your telephone number, organization, the capacity in which you are enquiring, the substance of your message, any statement you make as to accredited investor status, any description of how you are connected to the Firm, and your acknowledgements.

2.2

Technical information. Our hosting provider records standard server log data, including internet protocol address, browser type and version, pages requested, referring page and timestamp, for the purposes of security, diagnostics and operation of the Site.

2.3

Typography. The Site loads typefaces from a third-party font service. That service may receive your internet protocol address in the course of delivering those files.

2.4

What we do not collect. The Site does not operate advertising networks, behavioral tracking, third-party analytics cookies or cross-site trackers. We do not knowingly collect special categories of personal data, and you should not submit them.

2.5

Sensitive financial information. You should not transmit account numbers, taxpayer identification numbers, government identification numbers, credentials or similar information through the Site or by unencrypted electronic mail. If you do so, you accept the risk inherent in that transmission.

3.1

We process personal information in order to respond to and route your inquiry; to send the quarterly letter where requested; to assess eligibility before furnishing any Offering Document; to maintain records required under securities, anti-fraud, anti-money laundering and tax law; to protect the Site and the Firm against misuse, fraud and abuse; and to comply with legal obligations.

3.2

Where the General Data Protection Regulation or a comparable regime applies, our legal bases are the performance of steps taken at your request prior to entering a contract, our legitimate interests in operating and protecting the Firm, your consent where given (including for the quarterly letter, which you may withdraw at any time), and compliance with legal obligations.

4.1

We do not sell, rent, trade or license personal information, and we do not disclose it to third parties for their own marketing purposes.

4.2

We disclose personal information to service providers who process it on our instructions and under obligations of confidentiality, including providers of electronic mail and productivity services, website hosting, legal and accounting services, and, where a prospective investor proceeds, investor administration and data room services.

4.3

We may disclose personal information where required by law, court order, subpoena or regulatory demand; where necessary to establish, exercise or defend legal claims; where necessary to prevent fraud or harm; and to professional advisers in connection with a corporate transaction, in which case the recipient will be bound by obligations no less protective than this Policy.

5.1

Inquiries and related correspondence are retained for so long as is reasonably necessary for the purposes described in Article 3 and for such further period as is required by record-keeping obligations applicable to private offerings, which may extend for several years following the last communication.

5.2

Quarterly letter subscriptions are retained until you unsubscribe, following which a suppression record is retained so that we do not contact you again in error.

6.1

Subject to applicable law and to our record-keeping obligations, you may request access to the personal information we hold about you; request correction of information that is inaccurate; request deletion; object to or request restriction of processing; and request a copy in a portable format.

6.2

You may unsubscribe from the quarterly letter at any time by replying to any issue with the word unsubscribe, or by writing to the address in Article 10.

6.3

Residents of certain jurisdictions, including California, Virginia, Colorado and Connecticut, have specific statutory rights. We do not sell personal information or share it for cross-context behavioral advertising as those terms are defined under applicable state law. We will not discriminate against you for exercising any right.

6.4

To exercise a right, write to info@conqordcapital.com. We may require information sufficient to verify your identity before acting, and will respond within the period prescribed by applicable law.

7.1

We maintain administrative, technical and physical safeguards designed to protect personal information against unauthorised access, disclosure, alteration and destruction, including transport encryption, access controls and multi-factor authentication on administrative accounts.

7.2

No method of transmission over the internet, and no method of electronic storage, is completely secure. Electronic mail in particular is not a secure medium. We cannot and do not guarantee absolute security.

8.1

The Site functions without cookies for its ordinary informational purposes and does not set advertising or analytics cookies. Where any cookie is set, it is strictly necessary to the operation or security of the Site.

8.2

Most browsers permit you to refuse or delete cookies. Doing so will not impair your use of the Site.

9.1

The Site is directed to adults engaged in professional or investment activity. It is not directed to children under the age of eighteen, and we do not knowingly collect personal information from them. A parent or guardian who believes a child has provided information should contact us and we will delete it.

10.1

The Firm operates in the United States and information submitted through the Site is processed there. If you access the Site from another jurisdiction, you do so on your own initiative and acknowledge that your information will be transferred to and processed in the United States, which may afford protections different from those in your jurisdiction.

10.2

We may amend this Policy from time to time. The date stated at the head of this document identifies the version in effect. Material amendments will be identified on the Site.

10.3

Enquiries and requests may be addressed to Conqord Capital Partners, LLC, Attention: Privacy, 3343 Peachtree Road NE, Suite 2235, Atlanta, Georgia 30326; electronic mail info@conqordcapital.com.