Privacy Policy

Privacy Policy (Including Notice to CA Residents)

Last updated: April 2024

At Oak Hill Capital Management, LLC (“Oak Hill”, “we”, “us” or “our”), we are committed to handling information about you responsibly and we recognize and respect your right to privacy. This privacy policy (“Policy”) describes our privacy practices with respect to the Personal Information we collect in the course of operating our business, such as through the Oak Hill Capital Management website (https://oakhill.com/) or when providing our financial products and services (collectively, the “Services”), including the types of Personal Information we collect about you, how we may use that information, and to whom we disclose it. It also describes the measures we take to protect your Personal Information, your rights in relation to your Personal Information and how you can reach us to answer any questions you may have about our privacy practices or this Policy.

When you or your employer applies to become a client or investor, and during the course of our dealings with you, we will collect some Personal Information about you. Please see our Privacy Notice link for more information about our privacy practices when providing our financial products or services.

 

PERSONAL INFORMATION WE COLLECT 

Personal Information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household and includes your personal data. Through our interactions with you, we may collect the following categories of Personal Information:

• Identifiers, such as your name, alias, user name, unique personal identifier, online identifier, Internet Protocol address, account name, or signature;
• Contact information, including personal or business contact information, such as physical address, telephone number, or email address;
• Demographic information, which may include protected characteristics or special category information under local, state or Federal law, such as age, gender, or disability status;
• Financial information, such as bank account number;
• Commercial information, including records of financial products or services that you obtained or considered;
• Internet or other electronic network activity information, such as information about your interactions with our website;
• Audio, electronic, visual, or similar information, such as CCTV or call recordings;
• Professional or employment-related information, such as the name of your employer, business contact information, and employment history;
• Education information, such as colleges or universities attended and degrees earned;
• Inferences drawn from any of the categories of information above; and
• Sensitive Personal Information, such as your Social Security number and copies of your driver’s license, passport, or other identification.

We collect Personal Information from the following categories of sources:

• Directly from you. We collect Personal Information that you choose to provide to us when you interact with us by:
  • Registering for and accessing your account on the Oak Hill Extranet.
  • Signing up to receive news, alerts and publications from Oak Hill.
  • Contacting us, for example through the “Contact Us” link on our website.
  • Through various features on our website.
  • Providing information as or on behalf of an investor, prospective investor, client, or financial advisor.

For example, name, contact information, and professional or employment related information.

• Automatically collected. We may automatically collect certain information when you visit the website, including:
  • Usage information, such as which pages of the website that you visit and the date and time of your visit; and
  • Device information, such as device ID, hardware model, operating system, and other browser or device attributes.

• Third parties. We may also get information about you from other sources, for example, placement agents or business partners, such as business contact information.

HOW WE USE YOUR PERSONAL INFORMATION

We use Personal Information for the following purposes:

• To provide Services to you, including to process your transactions, create and maintain your account(s), verify your identity, or provide customer service.
• To respond to your inquiries and send you information, including technical notices, updates, alerts, or other messages related to our Services or our relationship with you, our investors, or potential investors.
• To send you information about products and services that may be of interest to you (unless you have opted out of marketing, or we are otherwise prevented by law from doing so) and to provide interactive or personalized elements on the Services.
• To maintain and improve our Services, including to run analytics, assess the quality of our services, enhance our offerings, and other related internal business purposes.
• To maintain and improve the security of our systems, including debugging to identify and repair errors and to ensure the security and integrity of our operations.
• To perform internal operations necessary to run our business, such as to conduct audits or prevent, detect, or investigate fraud, or in order to receive services from our vendors, service providers, and business partners.
• To perform analytics and market research.
• To improve our advertising and marketing mechanisms.
• To assess your creditworthiness and eligibility to contribute to the Partnership.
• For legal purposes, such as to respond to requests from courts, regulators, or law enforcement; comply with applicable laws; enforce our policies or agreements; or protect, defend, or enforce our rights, privacy, safety, or property, and/or that of you or others.
• As part of the consideration, negotiation, completion of a business transaction, including investments or the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
• For any other purposes of which you are notified, and if applicable, provide consent.

We do not process sensitive Personal Information in order to infer characteristics about you or for purposes other than as specified by California law. We may collect and use sensitive Personal Information in order to:

• Verify your identity.
• Prevent, detect, and investigate security incidents that may compromise Personal Information.
• Resist malicious, deceptive, fraudulent, or illegal actions or prosecute those responsible for those actions.
• Verify or maintain the quality of our products and services.

In some countries we need a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:

• To fulfil our contractual obligations to you, for example to provide our Services to you and to authenticate your access to our Services.
• To comply with our legal obligations.
• To meet our legitimate interests, for example to understand how you use our Services and to enable us to derive knowledge from that to enable us to develop new services.

When we process Personal Information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

We may obtain your explicit consent to collect and use certain types of Personal Information when we are required to do so by law. If we ask for your consent to process your Personal Information, you may withdraw your consent at any time by contacting us using the details at the end of this Policy.

DISCLOSURES OF PERSONAL INFORMATION

We may disclose your Personal Information to the following categories of third parties for the purposes described in the section above:

• Our legal and other professional advisers, auditors, and compliance consultants.
• Governmental and regulatory bodies such as tax authorities, financial regulators/ombudsmen, and non-financial regulators (depending on the circumstances of the sharing).
• Other organizations and businesses who provide services to us under contract such as maintaining or servicing customer accounts, providing marketing services to us (such as a placement agent), back up and server hosting providers, IT software and maintenance providers, document storage providers, and suppliers of other back office functions.
• Buyers or successor managers of a fund and their professional representatives as part of any restructuring or sale of our business or assets. We will use reasonable efforts to try to ensure that buyers or successor managers to which we transfer your Personal Information to, use it in a manner that is consistent with this Privacy Policy.
• Identity verification agencies.
• Companies related to Oak Hill Capital by common ownership or control, including financial and nonfinancial companies (“Affiliates”) for administration of their products and services, conducting marketing and credit checks. Oak Hill is an affiliate to each fund in the Oak Hill Capital Partners family of funds.

• Persons involved in the consideration, negotiation, completion of a business transaction, including investments or the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.

 

• Other third parties with your specific consent.

The following chart details the categories of Personal Information that we have disclosed to third parties for a business purpose during the preceding 12 months and the third parties to whom we have disclosed such Personal Information during the preceding 12 months.

Categories of Personal Information Disclosed	Categories of Third Parties to Whom We Have Disclosed the Personal Information
Identifiers	·        Placement agencies and business partners ·        Internet service providers ·        Data analytics providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms
Contact information	·        Placement agencies and business partners ·        Internet service providers ·        Data analytics providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms
Demographic information	·        Placement agencies and business partners ·        Internet service providers ·        Data analytics providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms
Financial information	·        Placement agencies and business partners ·        Internet service providers ·        Data analytics providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms
Commercial information	·        Placement agencies and business partners ·        Internet service providers ·        Data analytics providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms
Internet or other electronic network activity information	·        Internet service providers ·        Data analytics providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms
Audio, electronic, visual, or similar information	·          ·        Internet service providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms
Professional or employment related information	·        Placement agencies and business partners ·        Internet service providers ·        Data analytics providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms
Education information	·        Placement agencies and business partners ·        Internet service providers ·        Data analytics providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms
Inferences drawn from the information above	·        Placement agencies and business partners ·        Internet service providers ·        Data analytics providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms
Sensitive Personal Information	·        Placement agencies and business partners ·        Internet service providers ·        Anti-fraud protection providers ·        Operating systems and platforms ·        Professional services organizations, such as auditors and law firms

We do not knowingly sell or share Personal Information, including Personal Information about individuals under 16 years of age. Because we do not sell or share Personal Information, we do not recognize opt-out preference signals designed to opt out consumers from selling or sharing.

RETENTION OF PERSONAL INFORMATION

We may keep Personal Information for as long as necessary to fulfil the purposes we collected it for, and provided we have an ongoing legitimate business need to do so (including without limitation to provide you with a service that you have requested or to comply with any applicable legal, tax or accounting requirements). We may also retain Personal Information for the purposes of responding to any questions or complaints, maintaining records according to rules that apply to you, or preventing fraud or other financial crime.

We reserve the right to use de-identified or aggregate data for any purpose without limitation, and we will not attempt to re-identify the information.

 

TRANSFER OF PERSONAL INFORMATION

We may transfer your Personal Information to jurisdictions which do not offer the same level of protection as in your home jurisdiction and, in such circumstances, we will comply with the requirements under applicable data protection laws to ensure that there are appropriate safeguards in place to protect the Personal Information and will ensure that we will only disclose such information on a need to know basis and solely for the purposes of complying with our obligations in the context of providing services, including any related legal or regulatory requirements. For more information on the appropriate safeguards in place and to obtain a copy of such safeguards, please contact us at the details below.

 

HOW WE KEEP YOUR INFORMATION SECURE

We maintain technical and organizational measures to keep your information confidential and secure in accordance with our internal procedures covering the storage, access and disclosure of information. Please note, however, that communications and submissions over the Internet might not be secure. Please consider this fact before communicating or submitting any Personal Information or other confidential information to us or through our website.

 

COOKIES AND SIMILAR TECHNOLOGIES

We and our third-party service providers may collect certain information by automated means when you visit our website, such as how many users visit our website and the pages accessed. We collect this information through various means such as “cookies” “web beacons,” or similar technologies. These technologies are used to support essential functioning of the website, including website security. .

 

LINKS TO THIRD PARTY SITES

The website may provide access or contain links to Internet sites and services owned and operated by third parties. Inclusion of these links and services on the website does not constitute our endorsement of the materials on those third-party sites and does not signify any association with the owners or operators of those third-party sites and services. We are not responsible for and have no control over the privacy policies of those sites. We encourage you to review the privacy policies of those sites prior to providing them with any information. You agree that we will not be responsible for or liable for any loss or damage of any sort incurred as the result of any of your transactions with third parties. Any questions, complaints, or claims related to any third-party product or service should be directed to the appropriate vendor.

 

CHANGES TO THIS POLICY

We reserve the right to update this Policy at any time, and we will notify you when we make any substantial updates.

We may also provide you with specific notices about the processing of your Personal Information in connection with your use of certain Services.

 

PRIVACY RIGHTS

Depending on where you are located, and subject to data protection laws, you may have certain rights with respect to your Personal Information including:

• Right to Access and Portability: You may have the right to request a copy of the specific pieces of Personal Information that we have collected about you in a portable and, to the extent technically feasible, readily usable format.
• Right to Know: You may have the right to know what Personal Information we have collected about you, including, as applicable, the categories of Personal Information we have collected, the sources from which we collected that Personal Information, the business or commercial purposes for which we collected, sold, or shared that Personal Information, and the categories of third parties to whom we disclose the Personal Information.
• Right to Request Deletion: You may have the right to request that we delete the Personal Information we have collected about you.
• Right to Request Correction: You may have the right to request that we correct any inaccurate or out of date Personal Information that we maintain about you.
• Right to Withdraw Consent: You may have the right to withdraw your consent to the processing of Personal Information at any time, where consent was the lawful basis for processing your data.
• Right to object: You may have the right to object to our processing of Personal Information, where applicable e.g., where processing is based on our legitimate interests.
• Right to restrict: You may have the right to request a restriction on further processing of your Personal Information (e.g., where there is a dispute in relation to the accuracy or processing of your Personal Information)
• Right to lodge a complaint: You may have the right to lodge a complaint with your local data protection authority
• Right to Be Free from Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by applicable privacy laws.

We encourage you to contact us to update or correct your information if it changes or if the Personal Information we hold about you is inaccurate. We will contact you if we need additional information from you in order to honor your requests. If you would like to discuss or exercise the rights described above, please contact us at the details below::

1. Calling us at 212-527-8400
2. Sending an email to privacy@oakhill.com.

Your request should include your name, preferred contact information, and the nature of your request, including which rights you would like to exercise. Depending on the nature of your request, we may ask you to provide additional Personal Information so that we, or a third-party verification service, may verify your identity by, for example, matching the information you provide to the information we have on file.

You may designate an authorized agent to act on your behalf to make a request under applicable data protection laws by using the same channels for exercising your rights described above. If you use an authorized agent to exercise your rights under applicable data protection laws, we may require that you (a) provide your authorized agent with signed permission to act on your behalf and (b) verify your own identity directly with us and/or confirm with us directly that you have provided your authorized agent with permission to submit the request on your behalf. If your authorized agent does not submit proof that they have been authorized by you to act on your behalf, we reserve the right to deny their request.

CONTACT US

Oak Hill Capital Management is the controller responsible for the Personal Information we collect and process.

If you have questions or concerns about this Policy or our privacy practices, please contact privacy@oakhill.com.

Data Protection Officer

65 East 55^th Street

32^nd Floor

New York, NY 10022

(212) 527-8400