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Cliffwater LLC (“Cliffwater”) is committed to protecting the personal and financial information that it may receive related to its clients and the representatives of its clients. In the course of providing investment advisory services to you or the firm you represent, we may collect and maintain in limited circumstances certain non-public personal information about you. This privacy policy notice answers some questions about what non-public personal information we collect, what we do with it, and how we protect it.

What types of non-public personal information about me does Cliffwater collect?

As a client of Cliffwater or a representative of a client of Cliffwater, you may provide certain periodic disclosures to Cliffwater or disclosures to third parties (to which Cliffwater has access) with the following types of information:

  • Information provided by you in writing, in person, by telephone, electronically or by any other means such as your name, address, social security number or other identification number, date of birth, employment information and similar information.
  • Information related to you personally that you provided to your Cliffwater client service representative.
What types of non-public personal information about me does Cliffwater disclose?

Cliffwater discloses the non-public personal information about you described above primarily to provide you with the advisory services you and/or the firm you represent seek from us. We do not generally request non-public personal information, but we may request it to provide services related to your account or the account of the firm you represent, or come by it through your relationship with your Cliffwater client service representative, other employees or a third party.

To what employees of Cliffwater is my non-public personal information disclosed?

Cliffwater discloses non-public personal information about you only to those employees of Cliffwater who need to know that information in connection with the servicing or processing of services requested by you, maintaining or servicing your account or the account of the firm you represent, or as required by law.

To what other firms is my non-public personal information disclosed?

Cliffwater discloses non-public personal information about you to nonaffiliated third parties who Cliffwater utilizes in connection with: (i) the servicing or processing of services requested by you related to your account or the account of the firm you represent, (ii) maintaining or servicing your account or the account of the firm you represent, and/or (iii) servicing or processing transactions for your account or the account of the firm you represent. For example, we may provide information to nonaffiliated companies such as funds or their administrators where we are assisting you or the firm you represent as an investor. These companies are required to keep your personal information confidential and have their own privacy policies and notification of those policies.

Cliffwater may also disclose non-public personal information to nonaffiliated third parties: (i) to respond to a subpoena or court order, judicial process, regulatory authorities or as otherwise required by law; or (ii) to protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities. Such nonaffiliated third parties may, without limitation, include federal and state government/regulatory organizations such as the Securities and Exchange Commission. Disclosures for which you have provided your consent are also permitted.

Cliffwater does not disclose non-public personal information about former clients or their representatives, except with their consent or as required by law. Cliffwater does not sell your non-public personal information.

How does Cliffwater protect the confidentiality and security of my non-public personal information?

Cliffwater maintains physical, electronic and procedural safeguards to guard your non-public personal information.

To whom do I direct questions regarding Cliffwater’s Privacy Policy?

Please email compliance@cliffwater.com or call Cliffwater LLC at 800-278-8125.

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 (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.

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:

  • name, date of birth and birthplace;
  • contact details and professional address (including physical address, email address and telephone number);
  • account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly);
  • information regarding your use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history);
  • risk tolerance, transaction history, investment experience and investment activity;
  • information regarding investors’ status under various laws and regulations, including social security number, tax status, income and assets;
  • accounts and transactions with other institutions;
  • information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses;
  • information regarding citizenship and location of residence;
  • source of funds used to make the investment in the applicable fund(s); and
  • anti-money laundering, identification (including passport and drivers’ license) and verification documentation.

We may share the above categories of personal information with third-party service providers as set forth 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:
    • the administrative processes (and related communication) related to the onboarding of individual clients;
    • ongoing communication with potential individual clients, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the onboarding process;
    • the performance of obligations under an agreement with individual clients (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of investments for such clients;
    • ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the client relationship in accordance with documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
    • keeping individual clients informed about their investments, the possibility of new investments and related advertising;
  • auditing and verifications related to individual client 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 statutory 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 and use 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, please submit a request using the contact information shown above at the end of the standard privacy policy notice.

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.