Introduction

Douglass Park Asset Management, LLC and its affiliates (“Douglass Park,” “we·: “us” or “our”) are committed to safeguarding your privacy. The purpose of this notice (“Privacy Policy”) is to inform individuals who invest or are interested in investing in any accounts managed or advised by Douglass Park, or other individuals who access the website (“you” or “your”), www.douglassparkgroup.com (the “Site”), of the types of information we collect on the Site, how we use such information and to whom and under what circumstances we may disclose it. This Privacy Policy intends to comply with all applicable law, including the notice and disclosure regulations promulgated by the U.S. Securities and Exchange Commission under Regulation S-P This Privacy Policy applies only to this Site, and any other personal information obtained when you call, email, or otherwise communicate with Douglass Park. By accessing the Site on any computer, mobile phone, tablet, or other device or otherwise interacting with Douglass Park, you agree to the terms of this Privacy Policy. If you do not agree to the policy, please do not use the Site. We may modify this Privacy Policy at any time, and will post the current version on the Site. We encourage you to periodically review our Privacy Policy to stay informed about how we are using the information we collect.

Personal Information That You Give Us

We collect personal information from you when you submit it to us during your interactions with us, including when you contact us or create an account on the Site. This information may include (1) your contact information (e.g., your full name, business and/or home mailing address, telephone number, business and/or personal email address, job title); (2) other personal identifiers (e.g., your date of birth, social security number, tax or other identification numbers and documents); (3) your financial information (e.g., documents and information about your income, account transactions and holdings with us); and (4) your employment information and educational information (e.g., job title, present and former employer name and details, income details, and level of education). We may collect the same type of information about you from third parties such as our business partners and service providers. In some jurisdictions, individuals may have the right to opt-in or withdraw consent for certain uses. If you reside in such jurisdictions (e.g., California), you may have additional rights.

Personal Information That We Collect Automatically

When you visit the Site, we may collect certain information from you, including your Internet Protocol (IP) address, MAC address, browser type, operating system, device­identifying information, the specific web pages visited during your connection, and the domain name from which you accessed the Site. In addition, we may collect information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Site and other clickstream data. We may also use non-personal or aggregated information for statistical analysis, research, and other purposes.

Like many commercial websites, we analyze how visitors use our Site through what is known as “cookie” technology. A cookie is a small text file that is placed on your computer when you access the Site and allows us to recognize you each time you visit the Site. We may use cookies to: (1) allow you to use the Site without having to re­enter your user name and password; (2) enhance or personalize your Site usage; (3) monitor Site usage; (4) manage the Site; and (5) improve the Site and our services. If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Site, or that we may put on our Site in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.

Use of Personal Information

We may use the personal information we collect from and about you for any of the following purposes: (1) to provide you services; (2) to respond to your inquiries; (3) to retain records of our business transactions and communications; (4) for compliance with legal and regulatory requirement; (5) to verify the status or eligibility of an actual or prospective client of Douglass Park for services offered by us and for compliance with tax reporting requirements; (6) to conduct due diligence or monitoring activities of counter-parties; (7) in connection with actual or potential litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving us or our clients; (8) to operate our Site efficiently and improve our service to you; and (9) any other legitimate business interests.

Disclosure of Personal Information

We may disclose your personal information to non-affiliated third parties as permitted by law and in accordance with the agreements governing your investment, including: (1) other service providers to our investment funds, such as accounting, legal or tax preparation services; (2) other partners and potential investors in our investment funds; and (3) transfer agents, portfolio companies, brokerage firms and others, in connection with distributions to our limited partners. Douglass Park does not sell or share any of your personal information with any non-affiliated or affiliated companies for any other business or marketing related purposes.

We may also disclose your personal information as necessary (1) if we believe that there has been a violation of this Privacy Policy or of our rights or the rights of any third party; (2) to respond to legal process (such as a search warrant, regulatory request or inquiry, subpoena or court order) and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and (3) in the event that Douglass Park or substantially all of its assets are acquired, your personal information may be one of the transferred assets.

We may also disclose your personal information with your express consent. We may share aggregate, non-personally identifiable information about Site users with third parties.

Access, Correction, & Deletion

We respect your right to access and correct your personal information. You may access your personal information by signing into your account. From there, you can correct or modify your information. You may also exercise your rights, subject to applicable laws, to request that we delete or restrict access to your personal data. We may need to retain it for legally permitted purposes and this will be explained to you if necessary.

If you need assistance correcting or updating your personal information, or would like to request that we delete your personal information, please contact us using the contact information detailed in the “Contact Us” section below.

Retention of Personal Information

Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided in agreements between you and Douglass Park or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made de-identified.

Security

We maintain reasonable and appropriate measures designed to maintain information we collect in a secure manner. We have taken reasonable physical, electronic, and administrative steps to safeguard and secure the information we collect from visitors to the Site. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect and we cannot promise, and you should not expect, that your information will be secure in all circumstances.

Changes to This Privacy Policy

Douglass Park may revise and update this Privacy Policy from time to time in our sole discretion, and as required to keep current with rules and regulations, new technologies and security standards. All changes are effective immediately when we post them and apply to all access to and use of the Site thereafter. Users’ continued use of the Site following the posting of a revised Privacy Policy means that you accept and agree to the changes. Users are expected to check this page each time you access this Site so you are aware of any changes, as they are binding. If we change this Privacy Policy in a material and retroactive manner, we will provide appropriate notice to you.

Visitors from Outside the United States-Cross-Border Transfer

The Site is hosted in the United States. If you are visiting the Site from outside the United States, your information may be transferred to, stored and processed in the United States or other countries in accordance with this Privacy Policy. The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Site and/or providing personal information to us, you consent to transfer of your information to our facilities as described in this Privacy Policy.

Right to Lodge Complaints

We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.

Contact Us

If you have questions or concerns about this Privacy Policy or how we collect and use the information of our customers, you can contact us by emailing us at ir@douglassparkgroup.com, or by telephone at (646) 974-8041.

Last revised: 07/28/2021