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Xtranet PRIVACY POLICY FOR
THIS WEB SITE AND ITS AFFILIATED FUNDS,
GENERAL PARTNERS AND
MANAGEMENT COMPANIES
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We are adopting this Xtranet privacy policy to comply with our obligations
under various federal laws and regulations. This Policy covers our presently
existing and future private investment funds and affiliated management
entities, including our funds, general partners, managers and/or managing
members, and other management entities.
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"Customer" includes limited partners in our private equity funds. "Individual
Customer Information", including such information handled or maintained on our
behalf by Service Providers or our affiliates, shall be: (i) kept confidential,
(ii) protected against threats or hazards to its security or integrity and
(iii) protected against unauthorized access or use that could result in
substantial harm or inconvenience to any Customer within the scope of our
Privacy Notice. A copy of our Privacy Notice is available upon request. The
Privacy Notice generally states that we do not disclose Individual Customer
Information to anyone except as may be permitted by law or regulation, or to
Service Providers as necessary and appropriate.
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Any Service Provider we retain that receives or has access to Individual
Customer Information must be capable of maintaining appropriate safeguards for
such information to comply with applicable law.
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If we receive any non-public Individual Customer Information ("Third Party
Individual Customer Information") from any unaffiliated financial institution
(e.g., a third party general partner or private fund investor or co-investor),
we will follow the same safeguarding procedures employed for our Individual
Customer Information.
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