Oak HC/FT General Privacy Notice
At Oak HC/FT Management Company, LLC (collectively, with its subsidiaries and affiliates, “Oak HC/FT,” “us,” “our” or “we”) we take our obligation to maintain the confidentiality of personal information seriously. As a consequence, we do not disclose any nonpublic personal information about our investors or former investors to anyone other than our affiliates and service providers. We comply with the data privacy laws that are applicable to us (including the General Data Protection Regulation of the European Union). In the course of our business activities we may come into possession of your personal data. Oak HC/FT controls the collection and processing of this personal data. In this policy we set out the principles governing our use of personal information that we may obtain about you.
If you have any questions or comments in connection with this policy, please contact us at Oak HC/FT Management Company, LLC, 2200 Atlantic Street, Suite 300, Stamford, CT 06902, tel. (203) 717-1350 or [email protected].
Personal Data that We Collect
"Personal data" is any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. The categories of personal data that we may collect include:
- Contact information such as name, email address, telephone numbers, and business and private addresses;
- Information about your business relationship with Oak HC/FT;
- Information about your business relationships with other parties (including, without limitation, certain of your investment transactions and holdings);
- Biographical information such as your professional role, employer, background, and interests;
- Marketing, communication preferences and related information;
- Feedback and survey responses; and
- Financial information such as social security number, income, assets, billing address, bank account, wire transfer instructions, transaction history and other payment information.
How We Collect Personal Data from You
We may collect personal data directly from you in the following ways:
- When you provide us your business card or contact information through our website, in person, or via email;
- When you register to attend one of our events;
- When you use our website or one of our online services we may collect information about your visit and how you interact with our website;
- When you provide us information in order to apply for a job with us;
- When you enter into an investment advisory contract;
- When you seek financial advice;
- When you make deposits or withdrawals from your account;
- When you tell us about your investment or retirement portfolio;
- When you give us your employment history;
- When you provide us with information necessary to identify you and complete security checks when you visit our offices.
We may supplement this information from other sources, including:
- Publicly available sources of information;
- Regulatory bodies;
- Credit agencies;
- Third parties providing services to us.
We may combine personal data that you provide to us with other sources in some circumstances.
How We Use Your Personal Data
We will only use your personal data where we have a lawful reason to do so. Unless otherwise indicated, you should assume that we process your personal data for business, Oak HC/FT (and not third-party) marketing, and/or regulatory and compliance purposes, including to provide services to you, to fulfill a contract with you or when we have a legal or regulatory duty with which to comply.
We will retain your personal data for as long as necessary to fulfill the purpose for which we collected it, to comply with legal, regulatory or reporting obligations, to assert or defend against legal claims, or as applicable laws and business best practices allow.
We restrict access to nonpublic personal information about you to those employees who need to know that information to provide services to our funds and their investors. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information. In addition, we will continue to assess new technology for protecting information.
Disclosures to Affiliates and Service Providers
We collect, and may disclose to our affiliates and service providers (e.g., our attorneys, accountants, entities that assist us with distributions to our investors) on a "need to know" basis, certain nonpublic personal information about you from the following sources:
- Information we receive from or about you, such as your name, address, and social security or tax identification number; and
- Information about your transactions with us, our affiliates and service providers, or others, such as your participation in each of our funds, such as your capital account balance, capital commitment, contributions and distributions and, in the case of an investor that is an individual retirement account, information with regard to such account.
Disclosures to Unaffiliated Third Parties
We may disclose the following information to unaffiliated third parties other than our service providers, such as financial companies, non-financial companies or others (for example prospective investors in future funds):
- Information we receive from you, such as your name, address, and social security or tax identification number; and
- Information about your transactions with us, our affiliates and service providers, or others, such as your participation in each of our funds, such as your capital commitment, contributions and distributions and, in the case of an investor that is an individual retirement account, information with regard to such account.
European Union Residents
Under the General Data Protection Regulation of the European Union, a resident of the European Union may have certain rights, including:
- the right to direct us not to disclose nonpublic personal information to a nonaffiliated third party;
- the right to access his/her personal data;
- the right to restrict the use of his/her personal data;
- the right to have incomplete or inaccurate data corrected;
- the right to ask us to stop processing his/her personal data;
- the right to request for us to "port" his/her personal data in a portable, re-usable format to other organizations, where applicable and possible; and
- the right to require us to delete his/her personal data in some limited circumstances.
If you are a resident of the European Union and would like to exercise any of these rights, you must provide a written statement exercising that right. However, some of the personal data we collect may be necessary for us to provide requested services to you and if you do not wish to provide it, it will affect our ability to provide such services to you. In addition, in the event we encounter circumstances where we are compelled by law, rule or regulation or another applicable requirement to retain or disclose your personal data, we will do so even if you have exercised your right to opt out.
Opt Out
If you prefer that we not disclose nonpublic personal information about you to unaffiliated third parties (other than our service providers), you may opt out of those disclosures, that is, you may direct us not to make those disclosures (other than disclosures for our everyday business purposes, such as to process transactions and maintain accounts). If you wish to opt out of disclosures to such unaffiliated third parties, you may do so by contacting us as set forth above. Please note that this notice, as well as the ability to opt-out of certain disclosures, applies only to individuals and individual retirement accounts. Institutional and entity investors do not have the right to opt out of disclosures.