Under U.S. federal law, registered investment advisers must adopt and implement policies and procedures that are reasonably designed to protect the confidentiality of nonpublic personal records. Financial companies choose how they share your personal information, and U.S. federal law allows you to limit some but not all sharing of personal information. Kimmeridge is committed to protecting the confidentiality of all non-public information regarding its clients, investors, prospects and employees. Kimmeridge collects and maintains personal information in limited circumstances as outlined below.
Information We Collect
• Contact Information such as name, address, telephone number, email address, family and marital status, tax status including tax ID and related information, education and employment information, financial data such as bank account details, credit history and profile and related information required to process billing and payments.
• Identification Information, such as in connection with investors completing and submitting subscription documents for fund investments, including social security number, passport, driver license or similar identification required in support of applicable know-your client (KYC) and anti-money laundering (AML) compliance purposes and in order to provide financial services.
How We Collect Information
• We may collect this information through several means, including, as noted above, directly from investors or their intermediaries who complete subscription documentation and supporting information, or otherwise provide information to us in order to provide services to you. We could also collect this information through our affiliates or unaffiliated entities such as a credit bureau or other third party.
How We Use This Information
• We will use this information in the ordinary course of our business as required in order to provide services to you and to comply with applicable law or regulation. This may include supporting recordkeeping and account maintenance, including with third party service providers. We may also use this information to market products or services to you, to respond to regulatory requests, court orders and legal investigations, and to provide investment advisory and investment management services.
Sharing This Information
• We may share this information with affiliates and third party service providers such as fund administrators, auditors, attorneys, consultants, and other professional advisors, regulators and law enforcement authorities, as required by law, and your authorized agents. Third party service providers are contractually obligated to maintain the confidentiality of the information we provide to them to use the information only to provide services to us. You may not be able to limit the use of this information under all circumstances pursuant to U.S. federal privacy laws.
How We Protect This Information
• In an effort to protect your information from unauthorized access and use, Kimmeridge has implemented security measures designed to comply with applicable law. These measures include, among others, storing data on secure platforms and limiting access to appropriate recipients.
How Long Is Information Maintained
• We maintain records of this information for the length of time that you remain an investor in any Kimmeridge vehicle and thereafter for the period of time required under applicable law.
• We use Google Analytics to collect information regarding visitors to our website. Google Analytics uses text files placed on your computer (“Cookies”) to analyze how visitors use the website. This information is stored on Google’s servers and they use it to prepare reports and analysis on website activities and usage. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.