Privacy Notice

Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our individual limited partners. We have a long-standing policy of protecting the confidentiality and security of information we collect about you. We are providing you with this privacy notice (the “Privacy Notice”) to help you better understand why and how we collect certain personal information, the care with which we treat that information, and how we use that information.

Information We Collect: In connection with forming and operating our private investment funds (or “funds”) for our investors, we collect and maintain the following categories of non-public personal information as needed:

Contact information: name, address, email, telephone number;
Identification information: signature, date of birth, place of birth, citizenship, location of residence, government identification and numbers;
Background information: information required to perform, or revealed in, know-your-customer (KYC) and anti- money laundering (AML) due diligence, investor accreditation and consents;
Financial information: various financial information contained in account statements;
Investment information: information about your interest in the relevant investment, including ownership percentage, capital investment, income and losses; and
Technical or account information: electronic device and usage information (for example, from cookies and similar technology), registration information and online account data.

Sources of Non-Public Information: We collect personal information from the following sources:

Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail and other electronic communications, or in subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification and verification documentation);
Information about your transactions with us or others; and
Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms and any information captured via “cookies.”

Purposes for Collecting Personal Information: We may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes:

performing services to you, including but not limited to:
- the administrative processes (and related communication) in preparing for the admission of investors to the fund(s), including administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase interests in the fund(s);
- ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund and the execution of all relevant agreements;
- the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
- ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
- keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
- facilitating the execution, continuation or termination of the contractual relationship between an investor and the general partner or managing member, the investment adviser and/or the fund(s);
- facilitating the transfer of fund interests, and administering and facilitating any other transaction, between an investor, the general partner or managing member, the investment adviser and/or the fund(s);

auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance
maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
enabling any actual or proposed assignee or transferee of the fund(s), to evaluate proposed transactions;
facilitating business asset transactions involving the funds; and
complying with U.S., state, local and non-U.S. laws, rules and regulations

Disclosure of Information: We may disclose any of the categories of personal information set out in the “Information We Collect” section above as permitted or required by law or regulation and to affiliates, portfolio companies and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, and placement agents.

Former Limited Partners: We maintain non-public personal information of our former limited partners and apply the same policies that apply to current limited partners.

Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards, which seek to protect your non- public personal information in our possession or under our control.

Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time. In the event that we do so, we will make an updated version of this Privacy Notice available to you via Arsenal’s website and the investor portal. The examples contained within this notice are illustrations only and are not intended to be exclusive. This notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that apply to you, including as set forth in our additional privacy notices.

Contact Us: If you have any questions or concerns about this Privacy Notice or wish to exercise any rights, submit requests, or appeal any of our decisions in connection with this Privacy Notice (each, a “Communication”) please contact us at (212) 771-1717 or via email at: fscrudato@arsenalcapital.com.

We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information or your investor portal access credentials, if applicable in order to verify your Communication.

For more information about our Privacy Notice Supplement for California Residents and our EU-UK Privacy Notice, please click here.