Privacy Notice

Charlesbank Capital Partners, LLC and its affiliated investment funds

Commitment to Protection of Privacy

Charlesbank Capital Partners, LLC (“we”) consider privacy to be fundamental to our relationship with the investors in our affiliated investment funds. We are committed to maintaining the confidentiality, integrity, and security of their nonpublic personal information. We have developed internal policies to protect this confidentiality, while allowing us to serve your needs as investors. We will adhere to the policies and practices described in this notice regardless of whether you are a current or former investor.

We restrict access to nonpublic personal information to those employees and consultants under our supervision who need to know such information to provide products or services to you. We also maintain physical, electronic, and procedural safeguards that comply with Massachusetts law and federal standards to guard your nonpublic personal information.

Collection of Investor Information

We collect nonpublic personal information about you (such as your name, address, birth date, social security number, assets and income) and your transactions with us (such as investments, distributions, investment performance and capital account balances) from our discussions with you, from documents that you may deliver to us (for example, subscription agreements), and in the ordinary course of managing your investments.

Disclosure of Investor Information

In order to provide you with investment management and advisory services, we may disclose the nonpublic personal information that we collect, as described above, to our affiliates in order to service your account. In addition, we may disclose such information to certain unaffiliated third parties under one or more of the following circumstances:

As Authorized – if you request or authorize disclosure of the information.
As Required by Law – for example, to comply with properly authorized civil, criminal or regulatory investigations or to respond to judicial process or regulatory authorities.
As Permitted by Law – for example, we may share nonpublic personal information with companies that maintain, process, or service customer accounts or financial products and services, or effect or administer investor transactions. We may also share nonpublic personal information with lawyers, accountants or other service providers. We believe that sharing information for these purposes is essential to providing our investors with necessary or useful services with respect to their investments.
Under Joint Agreements – for example, we may share nonpublic personal information with companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements.

We require third party service providers and financial institutions with which we have an agreement to protect the confidentiality of your nonpublic personal information and to use such information only to perform the services for which the information was disclosed.

If you are an individual, federal law gives you the right to limit some, but not all, sharing of your nonpublic personal information. If you prefer that we not disclose nonpublic personal information about you to unaffiliated third parties (other than as permitted by law), you may “opt out” and direct us not to make such disclosures. If you wish to opt out, you may contact us by telephone at 617-619-5400 or by writing to:

Charlesbank Capital Partners, LLC
200 Clarendon Street
Boston, MA 02116
Attn: General Counsel

If we make any substantial changes in the way we use or disseminate nonpublic personal information, we will notify you.