{"entry":{"globalPrivacyNotices":"

Last Updated August 19, 2022

General Privacy Notice

This Global Privacy Statement (“Statement”) describes how Magnitude Capital, LLC (“Magnitude”, “we”, “us”, or “our”) and the investment funds and related vehicles that we manage and/or sponsor (the “Magnitude Funds”) collect, use, and disclose personal information collected from users of our services, visitors to our website (https://magnitudecapital.com/firm) (“Site”), current, prospective, and former investors in the Magnitude Funds, and in specific cases as outlined below, Personnel of Fund Managers (collectively, “you”). “Fund Managers” means investment managers, investment advisers and/or sponsors of funds or other investment vehicles or entities in which the Magnitude Funds have a current or prior investment or are considering investing. “Personnel” means Fund Managers’ employees, principals, officers, directors, partners, and individuals in similar capacities or roles. Except as otherwise stated below, this Statement applies to individuals only and may be changed at any time.

What Information We Collect and Maintain

We may collect one or more of the following categories of personal information about you:

Identifiers, such as your name, email address, postal address, Social Security number or other similar personal identifiers;
Other personal information categories
Including as listed in the California Customer Records statute, such as a signature, telephone number, education, employment, employment history, bank account number, or any other financial information, medical information, or health insurance information;
Protected classification characteristics
Including those under California or federal law, such as race, citizenship, marital status, or sex;
Commercial information;
Internet or other similar network activity, such as information on your interaction with a website, application, or advertisement;
Geolocation data, such as your IP address when you use our website;
Professional or employment-related information, such as current or past job history or performance evaluations;
Non-public education information, such as education records directly related to a student maintained by an educational institution or party acting on its behalf; and
Inferences drawn from other personal information.

We do not knowingly collect or solicit personal information from anyone under the age of 16.

We may collect personal information from the following categories of sources:

Your communications with us or communications from your agents or representatives;
Service providers, including, but not limited to, administrators, custodians, lenders, banks, brokers, auditors, tax advisors, law firms, consultants, vendors, and recruiting and staffing firms;
Third-party background check providers;
Nonprofit organizations; and
Government entities.

Personal Information from Investors. In addition, in connection with individual investors’ investments in the Magnitude Funds, such investors may provide Magnitude and/or the Magnitude Funds with their personal information, such as address, social security number, information about other assets, income information, and other information (i) in subscription documents and related documents; (ii) in correspondence and conversations with Magnitude personnel; and (iii) through transactions in the Magnitude Funds (e.g., subscriptions / redemptions). Magnitude and/or the Magnitude Funds may also collect personal information about investors from third parties that have been authorized by the investor, such as financial advisors, consultants, or other financial institutions. As described below, Magnitude and/or the Magnitude Funds share this information with third parties in certain circumstances in the course of their day-to-day businesses, but otherwise seek to treat the information with the highest standards of confidentiality.

Cookies. We may also use cookies on the Site. Cookies are small files that are stored on your computer by your web browser. A cookie allows our Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.

How We Use and Process Your Information

Magnitude and/or the Magnitude Funds may collect, store, and use personal information for lawful purposes, including, in particular: (i) where this is necessary for the performance of rights and obligations under the subscription documents and/or the constitutional and operational documents of the Magnitude Funds; (ii) where this is necessary for compliance with a legal or regulatory obligation to which Magnitude and/or the Magnitude Funds are subject (such as compliance with anti-money laundering requirements); and/or (iii) where this is necessary for the purposes of Magnitude’s and/or the Magnitude Funds’ legitimate interests, including, but not limited to, fraud prevention, due diligence, information technology security, and marketing, and such interests are not overridden by investors’ or other users’ interests, fundamental rights, or freedoms.

We may use also the personal information we collect for one or more of the following purposes:

Providing you with information about our products and services; and
Providing you with performance and other updates;
- One or more of the following business purposes:
- Performing services for you (by us or our service providers) such as account servicing, processing orders and payments, and analytics;
- Auditing related to our interactions with you (e.g., counting ad impressions to unique visitors, verifying positioning/quality of ad impressions, etc.);
- Legal and regulatory compliance;
- Detecting and protecting against security incidents, fraud, and illegal activity;
- Debugging;
- Internal research for technological improvement;
- Internal operations;
- Activities to maintain and improve our services; and
- Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about you.

With Whom and Why We Share Your Information

We may disclose personal information in one or more of the categories identified above:

To service providers, including but not limited to, administrators, lenders, banks, brokers, auditors, tax advisors, law firms, consultants, vendors, and recruiting and staffing firms;
To our affiliates;
To legal or government regulatory authorities as required by applicable law or regulation; and
In connection with a potential business transfer.

In the past 12 months, we have not sold any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

As it relates to investors, Magnitude and the Magnitude Funds do not disclose non-public personal information about investors to third parties without the respective investors’ consent, except as described below. Magnitude and/or the Magnitude Funds may disclose non-public personal information in the following circumstances:

To employees and affiliates for day-to-day business purposes;
To professional representatives of Magnitude or the Magnitude Funds, such as lawyers, accountants, tax advisors, and auditors;
To third parties that assist in servicing investor accounts, such as administrators, sub- administrators, custodians, sub-custodians, banks, promoters, placement agents, and similar parties;
To representatives of the investor or other third parties at the request of the investor, such as IRA custodians, independent financial advisors, consultants, tax preparers, and other similar parties; or
Pursuant to a lawful request by a regulatory or law enforcement authority or as required by applicable law or regulation.

In addition, Magnitude and/or the Magnitude Funds may share investor personal information with other financial companies that perform marketing services on Magnitude’s behalf. Investors may contact Magnitude at any time by telephone at +1 212.915.3900 or by email at magnitudecapital@magnitudecapital.com\nto limit sharing for marketing purposes. Magnitude may begin sharing an investor’s information for marketing purposes 30 days from the date the investor receives this Statement.

Security. Magnitude maintains physical, electronic, and procedural safeguards that have been reasonably designed to protect the non-public personal information that Magnitude and/or the Magnitude Funds obtain from you.

Data Retention. We retain personal information about you necessary to fulfill the purpose for which that information was collected or as permitted by law.

Additional Rights. State or international laws, including the Cayman Islands DPL, CCPA, or GDPR (each, as defined below), as applicable, may give you additional rights to limit sharing of personal information, as well as grant you certain rights to obtain access to, or request the correction or deletion of, personal data. Please see below for more information about additional rights.

Contact Us. Please contact Magnitude by telephone at +1 212.915.3900 or by email at magnitudecapital@magnitudecapital.com\nfor more information about these rights or about Magnitude’s or the Magnitude Funds’ privacy policies more generally.

Cayman Islands Data Protection Law

Any transfer of personal data received by Magnitude Funds domiciled in the Cayman Islands (the “Cayman Funds”) or Magnitude, as the investment manager to the Cayman Funds, or either Magnitude’s or the Cayman Funds’ duly authorized affiliates and/or delegates outside of the Cayman Islands, shall be in accordance with the requirements of the Data Protection Law, 2017 of the Cayman Islands (the “DPL”). If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) in a Cayman Fund that provides the Magnitude Funds or Magnitude with personal information on individuals connected to you for any reason in relation to your investment in the Cayman Funds, this will be relevant for, and applicable to, those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Privacy Notice for California Consumers

This notice contains disclosures required by the California Consumer Privacy Act (“CCPA”), is only relevant to residents of California, and applies only to the collection or other use of “personal information” that is subject to the CCPA. Consumers with disabilities may access this notice by downloading a PDF of the notice by clicking here.

Rights of California Consumers. The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:

The right to request (i) the categories and specific pieces of personal information we collect, use, disclose, and sell about you, (ii) the categories of sources from which we collected your personal information, (iii) our purposes for collecting or selling your personal information, (iv) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (v) the categories of third parties with which we have shared personal information;
For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties;
The right to request that we delete the personal information we have collected from you or maintain about you;
The right to opt out of our sale(s) (if any) of your personal information; and
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

You may submit requests relating to your exercise of rights under the CCPA to us by phone at +1 212.915.3900 or by email at magnitudecapital@magnitudecapital.com.

We may need to request additional information from you to verify your identity or understand the scope of your request. In verifying requests, we will require you to provide, at a minimum, a telephone number and mailing address. If we are unable to verify your identity, we will need to deny your request.

You may designate an authorized agent to make a CCPA request on your behalf by mailing two forms of identification showing your first name, last name, and current address, and a signed authorization allowing an agent to request information on your behalf.

Privacy Notice for United Kingdom and European Union Consumers

This notice contains disclosures required by the European Union General Data Protection Regulation (“GDPR”) and the United Kingdom General Data Protection Regulation (“UK GDPR”). This section is only relevant to residents of the European Economic Area (\"EEA\") and the UK.

Legal Bases for Collecting Your Information. We use the information that we collect for a variety of purposes. Our legal bases for processing your personal information are: (i) our legitimate interest in running and maintaining our business and the business of the Magnitude Funds; (ii) performance and fulfillment of our contracts and the contracts of the Magnitude Funds; (iii) your consent; and (iv) compliance with our legal or regulatory obligations or those of the Magnitude Funds. In many instances, more than one of these legal bases apply to the processing of your personal information.

Rights of EEA, UK Consumers. If you are a resident of the EEA, UK, or another jurisdiction with an applicable privacy law, you may have certain rights available to you. These rights may include:

The right to be informed about our data collection practices;
The right to access and rectify your data;
The right to erase or delete your data;
The right to data portability;
The right to restrict and object to the processing of your data (including for direct marketing purposes);
The right to opt out of the sale of your information;
The right to opt out of marketing emails and text messages;
The right to limit our use of any automated decision-making processes;
The right to lodge a complaint to your local data protection authority; and
The right to withdraw consent (to the extent applicable).

To exercise any of the rights listed above, please contact us via email at magnitudecapital@magnitudecapital.com. We will endeavor to respond to your request reasonably promptly and, in any event, within the time period required by applicable law.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html. If you have any questions, you may reach out to us via email at magnitudecapital@magnitudecapital.com\nor by phone at +1 212.915.3900.

Privacy Notice in Relation to Background Checks Conducted in the United Kingdom and the European Union

If you are Personnel of a Fund Manager we are considering investing with or have an existing investment with, we may need to process your personal data to conduct background checks on you as part of our due diligence processes relating to potential investment opportunities. Magnitude may also request information from your employer (i.e., a Fund Manager) or your manager at your employer to discuss personal information not covered in a background check, as well as disclose and discuss personal information obtained by a background check to your employer or manager.

In the event that you have not received a separate privacy notice concerning such background checks, we provide the following information in accordance with Article 14 of the GDPR and the UK GDPR. Our legal bases for processing your personal information for background checks are: (i) compliance with legal obligations which we are subject to; and (ii) our legitimate interest. In many instances, more than one of these legal bases apply to the processing of your personal information. The following personal data may be processed in the conducting of such background checks: contact information; property ownership records; criminal, police, or court records; driving records; education history; employment or volunteering history; financial history; information on gaps in employment; identity numbers and documents; watch or sanctions lists; membership in regulatory or professional bodies; mentions in online or print media; social media activity; and other people’s opinions about your performance or character. We will engage a third-party data processor to conduct background screenings. Magnitude takes appropriate measures to protect your rights and freedoms and legitimate interests in this processing. If you have any questions about this processing activity, you may reach out to us via email at magnitudecapital@magnitudecapital.com\nor by phone at +1 212.915.3900.

"}}