Privacy Policy

Effective Date: November 2025

DATA PRIVACY NOTICE

The purpose of this Data Privacy Notice (“Notice”) is to provide you with information on our use of Personal Data (as defined below). Our privacy practices are based on international privacy laws, including the EU General Data Protection Regulation (“GDPR”), the Cayman Islands Data Protection Act (2021 Revision) (the “DPA”) and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA” and, together with GDPR and the DPA, the “Data Protection Legislation”).

In this Data Privacy Notice, “we”, “us” and “our” refers collectively to Altamont Capital Management, L.P. and its affiliates (together, “Altamont”), including investment funds managed, advised or administered by Altamont (each, a “Fund”).

If you are an investor in a Fund or the holder of an account managed directly or indirectly by us (or, in either case, their representative), please refer to the Investor Privacy Notice for further information about how we collect and process Personal Data about current, prospective and former investors. If you are our employee, please refer to the Employee Privacy Notice. In the event of any conflict between the terms of those notices and this Data Privacy Notice, the terms of our Investor Privacy Notice and Employee Privacy Notice will control. If you are an institutional investor that provides us with Personal Data on individuals connected to you for any reason in relation to your investment with us, the content of this Data Privacy Notice applies to such individuals also (and you should provide a copy of this Notice to such individuals or otherwise advise them of its content) unless otherwise exempted pursuant to applicable law.

This Data Privacy Notice is sometimes referred to as our “Online Privacy Policy” and can be accessed online at https://www.altamontcapital.com/privacy-policy/. Our Online Privacy Policy applies only to www.altamontcapital.com and does not apply to any website or application to which it may link, such as the websites of our Portfolio Companies. Should you choose to visit those websites or applications, you should review their privacy policies to ensure that you are comfortable with them.

“Personal Data” as used in this Notice means personal information that reasonably can be used to identify any individual person or household. For example, we obtain Personal Data about investors when an investor participates in a Fund (including through the initial application and ongoing interactions with the Fund and persons engaged by the Fund) and about individuals connected with investors (for example directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents) when investors provide us with personal information about those individuals.

Notice of Collection and Use of Personal Data

What Categories of Personal Data we Collect

We collect the following categories of Personal Data:

  • Identifiers: Identifiers such as your real name, alias, postal and residential address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, state identification card number, contact details, corporate contact information, tax identification number, passport number, insurance policy number and other similar identifiers.
  • Protected Classifications: Information classified as personal or protected information by state, federal or other applicable law, including your nationality, place and date of birth, race, color, national origin, age, sex, gender, marital status, number of children, citizenship status, information on criminal history/unlawful conduct and correspondence records.
  • Commercial Information: Commercial information, including tax information, credit history, bank account details, money transfers including communications on bank transfers, source of funds details, investor profile and details related to your investment activity, including financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies.
  • Online Activity: Internet or other electronic network activity information.
  • Sensory Information: Voice mail, audio, visual (including your photograph and signature) and similar information.
  • Employment Information: Professional or employment-related information, including your employment, employer’s name, and income.
  • Education Information: Education information, including your level of education.
  • Inferences: Inferences that we draw from your personal information to create a profile about your preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

Sensitive Personal Information

We may collect information that is considered “sensitive” under some laws including the CCPA, such as your account log-in information if you log into our portal, sensitive identifiers like social security number and some financial information. When we do so, we use such information only for lawful purposes in compliance with applicable laws, such as to perform the services requested by you and to resist malicious, deceptive, fraudulent or illegal actions. Where required by applicable law, we will obtain your consent prior to processing such information.

How we Collect your Personal Data

We collect Personal Data in various ways. In particular, you will provide us with Personal Data within the forms and any associated documentation that you complete when subscribing for interests in a Fund; when you provide it to us or our service providers in correspondence and conversations (including by email); when you make transactions with respect to a Fund; when you provide remittance instructions; and when you visit our facilities.

We may also obtain Personal Data on you from our existing and potential portfolio companies, vendors (e.g., background check providers), advisors and other business partners, social media networks or other publicly accessible directories and sources. These may include websites; bankruptcy registers; tax authorities; governmental agencies and departments and regulatory authorities to whom we have regulatory obligations; credit reference agencies; sanctions screening databases; and fraud prevention and detection agencies and organizations, including law enforcement.

We may use cookies and other technologies in connection with maintaining the security of our website, to conduct analytics and to enable other website features. Our website does not respond to Do Not Track Signals.

How we Use your Personal Data

We collect, store and use your Personal Data for business or commercial purposes to which you have consented, and in addition, use for the following:

Processing that is necessary for the performance of a contract, including:

  • administering or managing each Fund;
  • processing your subscription and investment in each Fund, such as entering your information in the register of partners or shareholders;
  • sending you statements relating to your investment;
  • facilitating the continuation or termination of the contractual relationship between you and each Fund; and
  • facilitating the transfer of funds, and administering and facilitating any other transaction, between you and each Fund.

Processing that is necessary for compliance with applicable legal or regulatory obligations, including:

  • undertaking investor due diligence including anti-money laundering and counter-terrorist financing checks, including verifying the identity and addresses of our investors (and, where applicable, their beneficial owners);
  • sanctions screening and complying with applicable sanctions and embargo legislation;
  • complying with requests from regulatory, governmental, tax and law enforcement authorities;
  • surveillance and investigation activities;
  • carrying out audit checks, and instructing our auditors;
  • maintaining statutory registers; and
  • preventing and detecting fraud.

Pursuing our legitimate interests, or those of a third party to whom your Personal Data are disclosed, including:

  • complying with a legal, tax, accounting or regulatory obligation to which we or the third party are subject;
  • assessing and processing requests you make;
  • sending updates, information and notices or otherwise corresponding with you in connection with your investment in each Fund;
  • investigating any complaints, or pursuing or defending any claims, proceedings or disputes;
  • providing you with, and informing you about, investment products and services;
  • managing our risk and operations;
  • complying with audit requirements;
  • ensuring internal compliance with our policies and procedures;
  • protecting each Fund against fraud, breach of confidence or theft of proprietary materials;
  • seeking professional advice, including legal advice;
  • facilitating business asset transactions involving each Fund or related entities;
  • monitoring communications to/from us (where permitted by law);
  • creating, improving and developing our products and services; and
  • protecting the security and integrity of our IT systems.

We will only process your Personal Data in pursuit of our legitimate interests where we have considered that the processing is necessary and, on balance, our legitimate interests are not overridden by your legitimate interests, rights or freedoms.

Disclosing your Personal Data

We do not “sell” or “share” (as those terms are defined under the CCPA) any Personal Data to unaffiliated third parties and have not “sold” or “shared” any Personal Data, including no “sales” or “sharing” of Personal Data of minors under 16 years of age, in the past 12 months.

We may disclose your Personal Data to our agents and service providers. In certain circumstances we may be legally obliged to share your Personal Data with relevant regulatory authorities, administrative agencies, law enforcement agencies, ombudsmen or other oversight bodies such as the Cayman Islands Monetary Authority, the Tax Information Authority or the U.S. Securities and Exchange Commission. They, in turn, may exchange this information with foreign authorities, including tax authorities and other applicable regulatory authorities.

Our agents and service providers may process your Personal Data on our behalf, including with our banks, accountants, auditors and lawyers, which may be data controllers in their own right. Our service providers are generally processors acting on our instructions. Additionally, a service provider may use your Personal Data where this is necessary for compliance with a legal obligation to which it is directly subject (for example, to comply with applicable anti-money laundering and counter terrorist financing laws).

We may disclose your Personal Data to prospective creditors of a Fund or future or present portfolio company of a Fund, with portfolio companies directly, or with a third party that acquires, or is interested in acquiring, all or a substantial part of our assets or equity interests, or that succeeds us in carrying on all or a part of our business. In exceptional circumstances, we may share your Personal Data in connection with the investigation and assertion of legal rights.

Cookies and Similar Technologies

We or our service providers may use cookies and similar technologies to collect information passively. Cookies are small data files stored on your device. We may use these technologies to collect information about how you interact with our websites or our communications, to improve and personalize our websites, services and advertising.

You can set your browser to refuse all or some browser cookies; however, refusing cookies may affect your experience using website features or services.

We may also use third-party analytics providers (such as Google Analytics) on our websites to collect and analyze usage information using cookies and similar tools, to engage in auditing, research, or reporting, assist with fraud prevention, or provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out add-on for your browser by visiting https://tools.google.com/dlpage/gaoptout.

Do Not Track Requests

Your browser may allow you to transmit a “Do Not Track” signal to online services. Like many other online services, we do not recognize or respond to browser-initiated “Do Not Track” signals. For more information about “Do Not Track,” please visit www.allaboutdnt.com.

Sending your Personal Data Internationally

Your Personal Data may be transferred to, stored, and processed in a country other than the one in which it was collected, including from the United Kingdom, the European Union and the Cayman Islands to the United States, which may not or may not be deemed to provide the same level of protection for Personal Data. When we do so, and to the extent required by applicable Data Protection Legislation, we rely on appropriate or suitable safeguards, including standard contractual clauses approved or recognized by relevant authorities, such as the United Kingdom’s Information Commissioner’s Office, the European Commission and the Cayman Data Protection Commissioner, or we ensure that applicable service providers receive your Personal Data in a country that is deemed to provide adequate protection to your data.

You can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Information section below.

We may further rely upon appropriate or suitable safeguards of your Personal Data for international transfer, including:

  • Obtaining your consent to transfer Personal Data after first informing you about the possible risks of such a transfer;
  • When the transfer is necessary for the performance of a contract between you and Altamont, or if the transfer is necessary for the performance of a contract between Altamont and a third party, and the contract was entered into in your interest; and
  • When the transfer is necessary to establish, exercise or defend legal claims.

Retention and Deletion of your Personal Data

We will keep your Personal Data for as long as is consistent with the purposes for which we are processing it, in accordance with applicable law. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. We will generally retain an investor’s Personal Data throughout the lifecycle of the relevant investment. We will retain some Personal Data after your relationship with us ends. We expect to delete your Personal Data after there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your Personal Data.

When deciding how long to retain your Personal Data, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data described herein and whether we can achieve those purposes through other means. We may also retain your Personal Data to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.

Automated Decision-making

We do not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your Personal Data, unless we have considered the proposed processing in a particular case and concluded that such processing is appropriate.

How do we Protect Personal Data?

We apply technical, physical, and administrative information security measures designed to protect against unauthorized or unlawful processing of Personal Data, and against accidental loss or destruction of, or damage to, Personal Data, although no such measures can guarantee security or protect against unauthorized activity.

Children’s Privacy

Our services are not intended for children under the age of 18. We do not knowingly collect information from children under the age of 18, and we do not target children under the age of 18.

Data Subject Rights

Individuals in Australia, California, Canada, Cayman Islands, Europe, Hong Kong, Israel, Japan, Singapore, South Korea, Switzerland, the United Kingdom, and certain other jurisdictions, and investors in our Cayman Islands Funds, may have certain data subject rights. These rights vary, but may include a right to:

  • be informed about the purposes for which your Personal Data are processed;
  • access your Personal Data, including requesting us to disclose to you the Personal Data we have collected, used and disclosed about you during the past 12 months;
  • stop direct marketing;
  • restrict the processing of your Personal Data;
  • have incomplete or inaccurate Personal Data corrected;
  • ask us to stop processing your Personal Data;
  • be informed of a Personal Data breach;
  • complain to a data protection ombudsman;
  • obtain a copy of your Personal Data in a portable format;
  • opt out of the sale or sharing of Personal Data; and
  • request that we delete your Personal Data in some limited circumstances.

The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.

How to Exercise your Data Subject Rights

Depending on your jurisdiction, you may also be entitled to direct any complaints in relation to our processing of Personal Data to your national or local data protection supervisory authority, or to the Cayman Islands Ombudsman, if the complaint is in relation to a Cayman Islands Fund. Please consult local authorities.

Individuals who submit requests in relation to their Personal Data will be required to verify their identity by answering certain questions. We will not take action upon a request until such individual’s identity is verified. If you are making a request for access, we may not be able to provide specific pieces of Personal Data if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your Personal Data, your account with us, or our systems or networks. If you are making a request for erasure, we will ask that you confirm that you would like us to delete your Personal Data again before your request is submitted. In certain circumstances, we may not erase all Personal Data, as permitted by applicable law.

You may designate an authorized agent to submit a request on your behalf by providing that agent with your signed permission to do so. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us and directly confirm with us that you provided the authorized agent permission to submit the request before we can honor the request. Agents who make requests on behalf of individuals will be required to verify the request by submitting signed authorization from the individual. We will not honor any requests from agents until authorization is verified.

California Disclosures

In the preceding 12 months, we have collected and used Personal Data in the manner described above in the sections “Notice of Collection and Use of Personal Data – What Categories of Personal Data we Collect; – How we Collect your Personal Data; – How we Use your Personal Data.” We may have disclosed to third parties for our business purposes all of the categories of Personal Data as described above in that section. We will not discriminate against you for exercising data subject access rights.

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not share personal information with outside parties for their direct marketing.

Contact Us

Please contact us if you have any questions, concerns or complaints about this notice or the Personal Data we hold about you. You may contact us by calling 1-888-914-9661 (company code 233 715) or writing to us at [email protected] or at the following address:

Privacy Matters
Altamont Capital Partners
400 Hamilton Ave, Suite 230
Palo Alto, CA  94301

You may also contact us using the following web address:

Data Request: Privacy submission