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Privacy Policy     
                                       

1. Information Collection and Use

 

DW Partners, LP (“DW”) recognizes that it is important for you to feel confident in the knowledge that your personal information is secure. We are committed to protecting and safeguarding the confidential data that you have entrusted to us.

 

In the ordinary course of business, DW collects non-public and personally identifiable information regarding our investors. Such information includes, but is not limited to, your name, residential and email addresses, place and date of birth, government- issued identification number, account balances, bank information and representations you made to us regarding your assets, income and sources of funds (collectively, “Confidential Personal Information”).

 

DW obtains access to your Confidential Personal Information primarily through the following sources:

 

  • Subscription forms, investor questionnaires and other information you provide to us, whether in writing, in person, by telephone, electronically or by any other means; and

 

  • Transactions facilitated by DW, including provision of account balances, subscriptions and redemptions.


2. What Information DW Will Disclose and to Whom DW Will Disclose That Information

 

DW may disclose your Confidential Personal Information as permitted or required pursuant to applicable laws or regulations. Such circumstances include the following:

 

  • To government entities, in response to subpoenas or information requests, or to comply with applicable laws or regulations;

 

  • When you instruct, or consent to, DW’s disclosure of Confidential Personal Information;

 

  • To service providers that perform services for DW, such as external auditors and outside legal counsel, and to service providers that facilitate DW’s transactions (custodians, broker-dealers, prime brokers, third-party administrators, etc.);

 

  • To DW affiliates, if the disclosure is deemed necessary for the provision of services to DW or for compliance with applicable laws or regulations; and

 

  • To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.

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3. Information About Former Investors

 

To the extent that DW retains Confidential Personal Information regarding former investors, it will adhere to the privacy policies and procedures set forth herein.

 

4. How DW Safeguards Information

 

DW requires that all employees, affiliates and service providers keep your Confidential Personal Information secure. DW maintains safeguards that comply with the applicable standards to protect your Confidential Personal Information. It restricts access to your personal and capital account information to those employees who need to know such information in order to fulfill their job responsibilities. Third parties with which DW shares your information must also adhere to appropriate standards of security and confidentiality.

 

5. Additional Information for Investors Based in the European Economic Area (“EEA”)

 

DW is considered a “data controller” under the EU General Data Protection Regulation (“GDPR”). Certain of its affiliates and

third-party service providers may act as “data processors” under GDPR.

 

DW may collect, store and use your Confidential Personal Information for lawful purposes, including where necessary for: (i) the performance of its investment management services pursuant to your Subscription Agreement; (ii) compliance with legal or

 

regulatory obligations to which it is subject (such as anti-money laundering obligations or recordkeeping obligations); and/or (iii) the legitimate interest of DW (including direct marketing) or a third party, so long as such legitimate interest is not overridden by your interests, fundamental rights or freedoms. DW may retain your Confidential Personal Information for so long as it permissible pursuant to items (i), (ii) and/or (iii) above.

 

DW may disclose your Confidential Personal Information to recipients (including affiliates of DW) located in countries outside of the EEA. Such countries, including the United States, may not have data privacy laws equivalent to GDPR. In such circumstances, DW will take all necessary steps to ensure the safety of your Confidential Personal Information in accordance with GDPR.

 

Under GDPR, you may have a right to: (i) request access to and rectification or erasure of your Confidential Personal Information;

(ii) obtain restriction of processing or to object to the processing of your Confidential Personal Information; and (iii) data portability. As we do not process personal data on a large scale, we are not required to designate a data protection officer. Therefore, if you wish to exercise any of these rights, please contact the DW Compliance Department at the telephone number or email address listed below. Additionally, please be advised that you have the right to lodge a complaint regarding the processing of your Confidential Personal Information with your local data protection authority.

 

DW will notify you of any data breach affecting your Confidential Personal Information that is likely to result in a high risk to your interests, fundamental rights or freedoms.

 

By signing your Subscription Agreement, you acknowledge that we may use your Confidential Personal Information as described herein. You also consent to the transfer of your Confidential Personal Information to DW and the other recipients described herein, any of which may be located outside of the EEA.

 

If this Privacy Policy changes in any material way, you will be notified through appropriate means. If you have questions or comments, please contact the DW Partners Compliance Department at (212) 751-6100 or DW.Compliance@dwpartners.com.

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