This Online Privacy Policy constitutes a legally binding agreement between Riverwood and you, the user of this Website. By entering and using this Website, you acknowledge your acceptance of, and agree to be bound by, the Online Privacy Policy stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Online Privacy Policy, please do not access or use this Website.
Visitors that are residents of California should also refer to our California Website Privacy Policy supplement.
What Information We Collect
This Online Privacy Policy applies to information collected from, or which may be submitted to, the Website.
At the present time, we do not collect any personally identifiable information about visitors to the publicly available areas of our Website, including any visitors’ names, addresses, phone numbers, or email addresses, unless a user submits such information to us via our “Contact” page. At times, visitors to our Website may choose to email individuals at Riverwood using links available on our Website; in such instances, a visitor’s email address may be collected as part of the process of sending the email to us in order to enable us to reply to those emails. In addition, we may receive information from you that you submit to us through the investor reporting portals and data rooms. If you are using our investor reporting portal or data room, you will receive our Privacy Notice applicable to investors which contains additional information on the personally identifiable connection collected in that context. We do not use any “cookies” technology on our Website.
How We Use Information We May Collect
To the extent that you provide us with any personally identifiable information through or in connection with this Website, we may use such information for Riverwood’s business purposes. We do not share or disclose any personally identifiable information collected from the publicly available areas of our Website with any parties outside of Riverwood, but we reserve the right to disclose any such information we do collect to the extent required by law, regulation, or legal or judicial process, including pursuant to a request from a regulatory agency with competent jurisdiction over Riverwood, or to service providers. In the event that a visitor submits its email address or any other personally identifiable information to us via our Website while requesting information or sending any email to someone at Riverwood, other than as described above or in the Privacy Notice, we will not use such information for any other purpose, and will not disclose such information to any outside party.
Access to Portfolio Company and Other Third Party Websites
Our Website contains links to websites controlled and maintained by third parties. We provide these links solely as a convenience for you. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites are used. This Online Privacy Policy does not govern the use of information collected on such third party websites.
Capacity
You represent to Riverwood that you have the authority to visit this website according to the Terms of Use. This Website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this Website who are under the age of 18 or knowingly collect personally identifiable information from anyone under the age of 18 without parental consent. If we learn we have collected or received personally identifiable information from an individual under the age of 18, we will delete that information.
Notification of Changes
We reserve the right to amend this Online Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Online Privacy Policy. Accordingly, users are strongly encouraged to review our Online Privacy Policy regularly. If we decide to change our Online Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Online Privacy Policy under which the information was collected. Your continued access or use of this Website following the posting of changes to this Online Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Online Privacy Policy, please stop accessing this Website. Please check this page frequently and review any changes to this Online Privacy Policy carefully so you are aware of any changes, as they are binding on you.
Contact Us
If you have any questions or concerns about this Privacy Policy, please contact the Chief Compliance Officer of Riverwood at cco@rwcm.com.
CALIFORNIA WEBSITE PRIVACY POLICY
DATE: JULY 2024
This California Website Privacy Policy supplements the Online Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, 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 in the Online Privacy Policy. 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.
WHAT DOES THIS PRIVACY POLICY APPLY TO?
This Website Privacy Policy applies solely to your interactions with us through the Riverwood website and investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a contractor, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
We collect limited types of personal information through our Website. The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
| Category | Examples | Collected |
| A. Identifiers | Name, contact details and address (including physical address, email address, account name, and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number). | Yes |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information (including accounts and transactions with other institutions and anti-money laundering information). Some personal information included in this category may overlap with other categories. | Yes |
| C. Protected classification characteristics under California or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status. | Yes |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | No |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No |
| F. Internet or other similar network activity | Use of our website, fund 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. | Yes |
| G. Geolocation data | Physical location or movements. | Yes |
| H. Sensory data | Audio, electronic, visual, or similar information. | Yes |
| I. Professional or employment-related information | Current or past job history or performance evaluations, pay stubs, timesheets, direct deposit information, tax withholding. | No |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | No |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No |
| L. Sensitive Personal Information (see further information on use of sensitive personal information below) | Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, in combination with any required security or access code, password, or credentials allowing access to an account; geolocation; the contents of a consumer’s mail, email, text messages, and chats. | Yes |
We do not knowingly collect or solicit personal information from anyone under the age of 18.
We do not collect or use sensitive personal information other than:
- To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
- As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
- As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
- For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
- To perform services on behalf of our business;
- To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
HOW DO WE OBTAIN YOUR PERSONAL INFORMATION?
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
- Information from your communications with us in connection with this Website, including any update notices provided by you.
- Information captured on our Website, including registration and account information, information provided through online forms and any information captured via cookies.
- We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We will use your personal information for one or more of the following business or commercial purposes:
- To perform services for you, including but not limited to the administrative processes (and related communication) in connection with an investment.
- To create, maintain, customize, and secure your account with us.
- To provide, support, personalize, develop and improve our Website and the products and services that we offer and notify you about changes to our products and services.
- To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website.
- To provide advertising and marketing services.
- To keep a record of your relationship with us.
- To conduct ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
- To keep investors informed about the business of the general partner or managing member of the applicable investment vehicle and its affiliates generally, including investor notices and reporting.
- To audit and verify the quality and effectiveness of our services and compliance.
- To maintain the safety, security and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
- As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
We retain the categories of personal information set forth above in “WHAT INFORMATION DO WE COLLECT ABOUT YOU?” section of this California Website Privacy Policy only as long as is reasonably necessary for those purposes set forth above in “HOW DO WE USE YOUR PERSONAL INFORMATION?”, except as may be required under applicable law, court order or government regulations.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
| Personal Information Category | Category of Third-Party Recipients |
| A. Identifiers | Administrators, lenders, banks, auditors, law firms, tax advisors, compliance advisors, governmental agencies or pursuant to legal, regulatory, or compliance process, self-regulatory organizations, consultants and placement agents. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Administrators, lenders, banks, auditors, law firms, tax advisors, compliance advisors, governmental agencies or pursuant to legal, regulatory, or compliance process, self-regulatory organizations, consultants and placement agents. |
| C. Protected classification characteristics under California or federal law | N/A |
| D. Commercial information | N/A |
| E. Biometric information | N/A |
| F. Internet or other similar network activity | Administrators, law firms, governmental agencies or pursuant to legal, regulatory, or compliance process, consultants and placement agents. |
| G. Geolocation data | N/A |
| H. Sensory data | N/A |
| I. Professional or employment-related information | N/A |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | N/A |
| K. Inferences drawn from other personal information | N/A |
| L. Sensitive Personal Information | Administrators, auditors, law firms, tax advisors, compliance advisors, governmental agencies or pursuant to legal, regulatory, or compliance process, consultants and placement agents. |
HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?
We consider the protection of personal information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
YOUR RIGHTS UNDER THE CCPA
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. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
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. 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;
- the categories of third parties with whom we disclose 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 on your behalf using any of the methods set forth in the Contact us section below.
CONTACT US
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below. Call us using the following toll-free number: 1-888-638-2461. Email us at the following email address: cco@rwcm.com. 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 further information or your investor portal access credentials, if applicable, 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, but in certain cases, additional time might be required. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received. Please contact the Chief Compliance Officer of Riverwood at the email address above with any questions about this California Website Privacy Policy.