U.S. Privacy Policy

OUR COMMITMENT TO YOUR PRIVACY 

Your privacy is important to Grant Avenue Capital LLC and its affiliates (together, “Grant Avenue”, “we”, “us”, “our”, or “company”). To better protect your privacy, we are providing you with information explaining our online information practices.

We are sensitive to the privacy concerns for visitors of this website – https://www.grantave.com -or any other websites, pages, features or content we own or operate (collectively, the “Sites”). We have a policy of protecting the confidentiality and security of information we collect about you. We are providing you with this U.S. Privacy Policy (the “Privacy Policy”) to help you better understand why and how we collect certain personal information, the care with which we treat that information and how we use that information. This Privacy Policy is in addition to the privacy notice that is provided to investors in the investment products sponsored and/or managed by Grant Avenue.

For users of the Site, your use of the Site signifies your acknowledgment and acceptance of the Privacy Policy. If you are a Grant Avenue investor or a representative of an investor, please see the investor privacy notice, which is available on our investor portal, about our collection, use and sharing practices with respect to investor personal information.

INFORMATION WE COLLECT 

When you visit this Site, we may collect three different types of information about you: (i) information you provide to us, (ii) information we collect through technology, and (iii) information we collect from third parties.

• Information you provide to us. You may choose to contact Grant Avenue by using the options provided on this Site, including via email. If you choose to contact us, we will collect your name, email address, and any other information you choose to provide us. Depending on your interactions with us, we may also collect information, such as your home address, job title, employment position, telephone number, educational history, and the type of investor you are. Additionally, we may collect and retain a record of all our communications with you. Please do not provide us with personal information that you do not want us to have.
• Information we collect through technology. We may collect certain information about your use of the Site through cookies, pixels, internet server logs, web beacons and/or similar technologies. This information may include internet protocol (IP) addresses, browser type and version, device and internet service connection, operating system, dates and times of Site visits, and clickstream data. We may also use these and similar technologies in emails we send to you to collect certain information, such as whether you opened or clicked on links in our email. In addition, we may collect information about your visit to the Site, including referring and exiting web pages and URL’s, full web addresses that you access, the number of clicks through and from the Site, landing web pages within the Site, content viewed on the Site and the order of those web pages, the date and time you used the Site, length of visits to certain pages, the frequency of your use of the Site, error logs, and other similar information. We may use third-party web analytics providers and technologies, including cookies and similar tools, to assist with the collection of such information.
• Information we collect from third parties. We may also collect information from third parties including your employer or funds or other third parties with who you are associated, such as a CV received from a recruiting firm, background information received from a background check provider, information we view on social media, details obtained from publicly available lists of individuals or organizations, or information we receive for anti-money laundering purposes.

HOW WE USE IT

Grant Avenue is the sole owner of information collected on this Site. We will use your information to respond to you regarding the reason you contacted us, as applicable and as appropriate.

To the extent you provide us with any personal information through or in connection with the use of this Site, we may use such information for our business purposes, but will not disclose personal information about you to anyone, except as permitted or required by law or regulation and to service providers. We may also use your personal information for:

• The purposes for which you provided it to us or a service provider;
• To provide and improve our investment services, including evaluating potential investments and managing existing investments;
• Developing new investment opportunities;
• To improve the content and features of this Site;
• To communicate with you, including responding to requests for information submitted by you through the Site;
• To keep a record of your relationship with us;
• For internal research and reporting;
• For ongoing operations, administrative, accounting, reporting, account maintenance, and other processes;
• To audit and verify the quality and effectiveness of our services and compliance;
• To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity;
• To comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities;
• Enforce the terms and conditions that govern the Site; and
• To administer and troubleshoot the Site.

INFORMATION SECURITY

We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic, and procedural safeguards, which seek to protect your personal information in our possession and under our control.

Unfortunately, the transmission of information and data via the internet is not completely secure. Although we try to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through this Site; any transmission of information or data by you to or through this Site is at your own risk.

HOW WE SHARE YOUR INFORMATION

Depending on the nature of your relationship with us, we may share your information in the following circumstances:

• With your consent;
• To our affiliates; 
• To other service providers in the course of professional services they render to us, including but not limited to, auditors, administrators, lenders, banks, insurers, law firms, consultants, and placement agents; 
• As permitted or required by applicable law or regulation, including to governmental agencies, self-regulatory organizations, or pursuant to legal process;
• Acquirers and other relevant participants in business transactions (or negotiations of such transactions) involving corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Grant Avenue or our affiliates (including, in connection with a bankruptcy or similar proceedings).

CAPACITY

You represent to Grant Avenue that you have the authority to visit this Site. This Site is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this Site who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete such information.

OTHER SITES AND SERVICES

This Site may contain links to websites and other online services operated by third parties. Additionally, our content may be integrated into web pages and online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions, including their privacy policies.

NOTIFICATION OF CHANGES

Grant Avenue reserves the right to amend this Privacy Policy from time to time by updating this posted policy. Users are strongly encouraged to check this Privacy Policy periodically to review any changes. Your continued use of this Site following the posting of changes to this Privacy Policy means you accept such revisions, changes and/or amendments. If you object to any of the changes to the Privacy Policy, please stop accessing this Site. 

CONTACT US

If you have any questions or concerns about this Privacy Policy, wish to view in an alternative format, or wish to exercise any rights, submit requests, or appeal any of our decisions in connection with this Privacy Policy,  please contact us at info@grantavecap.com.

SUPPLEMENTAL INFORMATION

The examples contained in this Privacy Policy are illustrative only and are not intended to be exhaustive. This Privacy Policy complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (collectively the “GLB Rights”), the GLB Rights shall apply to you, including as set forth in our additional privacy notices.

Users of this Site that are residents of California should refer to the California Privacy Policy set forth below as it contains additional information with respect to the California Consumer Privacy Act of 2018.

Users of this Site that are residents of the United Kingdom, the European Union, or the European Economic Area should refer to our EEA-UK Privacy Policy available elsewhere on this Site as it contains important additional information with respect to privacy laws in such jurisdictions.

CALIFORNIA PRIVACY POLICY

This notice (this “California Privacy Policy”) supplements the Privacy Policy set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended, and any implementing or successor legislation to the foregoing (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This California Privacy Policy 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 California Privacy Policy is otherwise set forth above in the Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act or Regulation S-P (the “GLB Rights”), the GLB Rights shall apply to you.

APPLICATION OF CALIFORNIA PRIVACY POLICY

This California Privacy Policy applies solely to your interactions with us through this Site. If you provide personal information to us through another means (e.g., via email, phone call, or as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice that will govern that personal information.

INFORMATION WE COLLECT

We collect limited types of personal information through this Site. The type of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we collect may include:

• Identifies: Identifies such as name, contact details, address (including physical address, email address and IP address), and other identification (including social security number, passport number, and drivers’ license or state identification card number);
• Additional Data Subject to Cal. Civ. Code § 1798.80: Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets);
• Protected Classifications: Date of birth, citizenship, birthplace, race, color, sex, gender, marital status, medical condition, disability, and military and veteran status;
• Commercial Information: Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, and source of funds used to make investment in applicable fund(s);
• Internet or Similar Network Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements;
• Employment and Educational Information: Professional or employment-related information and educational history;
• Inferences: Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes; and
• Sensitive Personal Information

We do not knowingly collect or solicit personal information from anyone under the age of 18.

HOW WE COLLECT INFORMATION

In connection with forming and operating this Site, we collect and maintain your nonpublic personal information from the following sources:

• Information from your communications with us in connection with this Site, including any update notices provided by you;
• Information captured on our website, including registration 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 WE SHARE PERSONAL INFORMATION

We do not share 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.

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, insurers, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, cloud service providers and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

We disclose, or within the last twelve (12) months we have disclosed, personal information collected from you for a business purpose to the categories of third parties indicated in INFORMATION WE COLLECT. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries. 

We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.

RIGHTS UNDER THE CCPA

If you are a natural person who is a resident of California, you may have the following rights in relation to personal information that we collect about you. 

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain 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 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 to 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.

Correction Right: You have the right to request that we correct any inaccuracies in the 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.

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 the California Privacy Policy in an alternative format, please submit a request using any of the methods set forth below:

Email us at the following email address: info@grantavecap.com.

Write to us at the following address: Grant Avenue Capital LLC, c/o Compliance Department, 437 Madison Ave,. Suite #1901, New York, NY 10022.

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 your investor portal access credentials 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. 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.