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Privacy Policy

Last Modified: June 2021

Visitors who are residents of the United Kingdom, the European Union or the European Economic Area should refer to our EU Privacy Notice supplement.

1. Introduction

Avesi Partners LLC and its affiliated entities (together, “Avesi” and referred to in this Privacy Policy using the pronouns “we,” “us” and “our”) is committed to respecting your personal privacy and recognizes that you may be concerned about the information you provide to us and how we treat that information.

This Privacy Policy has been established to inform you of our practices for collecting, using, maintaining, protecting, and disclosing information that we obtain from you in connection with your use of this website and its sub-pages (the “Site”), whether through a personal computer, mobile device, or otherwise. By entering the Site or by transmitting any information to the Site you acknowledge and agree to all of the terms and conditions of this Privacy Policy. Please read them carefully. This Privacy Policy is incorporated into, and part of, the Terms and Conditions, which govern your use of the Site in general.

2. What is Personally Identifiable Information?

Personally identifiable information (“PII”) is information about an individual, which may include first and last name, physical street address, email address, telephone number, Social Security number, payment card information, birth date, employment history, veteran status, certain health related data, passport information and photographs, or any other information that permits a specific individual to be contacted physically or online or otherwise personally identified. PII does not include aggregated information that does not allow a person in possession of such information to identify you individually.

3. The Personal Information We Collect and How We Use It

We may collect and store various types of information from users of this website, including through third-party service providers (Google Analytics), and through cookies. We may collect this information to support marketing performance, administer and monitor E-newsletters, aggregate user profiles, and other performance and marketing-related reasons. For example, knowing how users use our website – tracking their movement through this website – helps us improve website design and usefulness. As a result, Avesi’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (IP) addresses. Avesi generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” page. In addition, when you use the Site a “cookie” may be used, as further described below.

4. Sharing of PII

To the extent that you provide us with any personally identifiable information through or in connection with this website, we may use such information for Avesi business purposes, but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to Avesi, you consent to Avesi’s use of such personally identifiable information for the purposes described in this Privacy Policy.

5. Use of Cookies

In common with many websites, we or our service providers may use “cookies” in connection with your access to, and use of, the Site. A “cookie” is a small data file that can be placed on the hard drive of your computer and helps us to enhance your use of the Site. The only cookie we use is stored only in temporary memory of your device and is deleted when you close the web browser used to access the site. You can delete cookies at any time, or you can set your browser to reject or disable cookies. The only cookie we use checks whether your web browser is set to allow or reject cookies and is used to ensure the Site functions correctly and operates efficiently when you use it, and does not otherwise collect PII or track your use of other websites or online activity.

6. Capacity

You represent to Avesi that you have the authority to visit this website according to the Terms and Conditions. The Site is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to our Site who are under the age of 18 without parental consent. If we learn we have collected or received PII from an individual under the age of 18, we will delete that information.

7. Security

We implement security measures designed to protect any PII submitted by or collected from you from unauthorized access. We further protect your PII from potential security breaches by implementing certain technological security measures in accordance with generally accepted industry practices. However, these measures do not guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software. By using the Site, you acknowledge that you understand and agree to assume these risks.

8. Unsubscribe, Access, Questions and Further Information

You will have an opportunity to unsubscribe from our marketing email communications whenever such email communications are sent.

9. Data Retention

We may retain PII we collect from you and PII you provide to us in connection with our internal record-keeping policies and as reasonably necessary to comply with our legal obligations and regulatory requirements, resolve disputes, prevent fraud or abuse, and enforce our Privacy Policy and Terms and Conditions.

Notwithstanding the foregoing, information we collect from you and information you provide to us may be retained for a limited period of time if requested by a governmental authority.

10. Links

The Site may contain links or references to other websites outside of our control. Please be aware that we have no control over these sites and this Privacy Policy does not apply to these sites. We encourage you to read the privacy policies/statements and terms and conditions of linked or referenced sites that you enter.

11. Changes to Our Privacy Policy

We may amend and update this Privacy Policy from time to time. All changes are effective immediately when we post them, and apply to all access to and use of the Site thereafter. The date the Privacy Policy was last revised is identified at the top of the page. Your continued access of the Site following the posting of changes to this Privacy Policy constitutes your acceptance and agreement to the changes. If you object to any of the changes to this Privacy Policy, please cease accessing the Site. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.

12. Contact Information

If you have questions or concerns regarding this Privacy Policy, please contact us by emailing us at


Last Modified: June 2021

This EU Privacy Notice (this “EU Privacy Notice”) applies to the extent that EU Data Protection Legislation (as defined below) applies to the processing of personal data by an Authorized Entity (as defined below) or to the extent that a data subject is a resident of the United Kingdom (the “UK”), the European Union (the “EU”) or the European Economic Area (the “EEA”). If this EU Privacy Notice applies, the data subject has certain rights with respect to such personal data, as outlined below.

For this EU Privacy Notice, “EU Data Protection Legislation” means all applicable legislation and regulations relating to the protection of personal data in force from time to time in the EU, the EEA or the UK, including the following: the Data Protection Directive (95/46/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Data Protection (Processing of Sensitive Personal Data) Order 2000, any other legislation that implements any other current or future legal act of the EU concerning the protection and processing of personal data (including Regulation (EU) 2016/679 (the General Data Protection Regulation) and any national implementing or successor legislation) and any amendment or re-enactment of the foregoing. The terms “data controller,” “data processor,” “data subject,” “personal data” and “processing” in this EU Privacy Notice shall be interpreted in accordance with the applicable EU Data Protection Legislation. Unless the context otherwise requires, as used herein the words “include,” “includes” and “including” shall be deemed to be followed by the phrase “without limitation.” All references to “investor(s)” in this EU Privacy Notice shall be to such actual or potential investor(s) and, as applicable, any of such investor(s)’ partners, officers, directors, employees, shareholders, members, managers, ultimate beneficial owners and affiliates.

Please direct any questions arising out of this EU Privacy Notice to Avesi Partners LLC (the “Management Company” and, collectively with its affiliated investment advisory entities, “Avesi”) by emailing us at [].

Categories of Personal Data Collected and Lawful Bases for Processing

In connection with offering, forming and operating private investment funds for investors, the applicable private fund, the general partner, the Management Company, their respective affiliates and, in each case, their respective administrators, legal and other advisors and agents (the “Authorized Entities”) collect, record, store, adapt and otherwise process and use personal data, either relating to investors or to any other data subjects, including from the following sources:

  1. information received in telephone conversations, in voicemails, through written correspondence, via e-mail or on subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification and verification documentation);
  2. information about transactions with any Authorized Entity or others;
  3. information captured on any Authorized Entity’s website, including registration information and any information captured via “cookies”; and
  4. information from publicly available sources, including from:
    • publicly available and accessible directories and sources;
    • bankruptcy registers;
    • tax authorities, including those that are based outside the UK and the EEA if you are subject to tax in another jurisdiction;
    • tax authorities, including those that are based outside the UK and the EEA if you are subject to tax in another jurisdiction;
    • governmental and competent regulatory authorities to whom any Authorized Entity has regulatory obligations;
    • credit agencies; and
    • fraud prevention and detection agencies and organizations.

Any Authorized Entity may process the following categories of personal data:

  1. names, dates of birth and birth place;
  2. contact details and professional addresses (including physical address, email address and telephone number);
  3.  account data and other information contained in any document provided by investors or potential investors to the Authorized Entities (whether directly or indirectly);
  4. risk tolerance, transaction history, investment experience and investment activity;
  5. information regarding an investor’s or potential investor’s status under various laws and regulations, including their social security number, tax status, income and assets;
  6. accounts and transactions with other institutions;
  7. information regarding an investor’s or potential investor’s interest in the applicable fund(s), including ownership percentage, capital investment, income and losses;
  8. information regarding an investor’s or potential investor’s citizenship and location of residence;
  9. source of funds used to make the investment in the applicable fund(s); and
  10. anti-money laundering, identification (including passport and drivers’ license) and verification documentation.

Any Authorized Entity may, in certain circumstances, combine personal data it receives from an investor with other information that it collects from or about such investor. This will include information collected in an online or offline context. In addition, personal data of investors could be processed and controlled irrespective of whether such investor is admitted to a fund.

One or more of the Authorized Entities are “data controllers” of personal data collected in connection with the applicable fund(s). In simple terms, this means such Authorized Entities: (a) “control” the personal data that they or other Authorized Entities collect from investors or other sources; and (b) make certain decisions on how to use and protect such personal data.

There is a need to process personal data for the purposes set out in this EU Privacy Notice as a matter of contractual necessity under or in connection with the applicable agreement of limited partnership or other governing agreement (the “Partnership Agreement”) and associated documentation for the fund(s) in which the data subject has or may invest, and in the legitimate interests of the Authorized Entities (or those of a third party) to operate their respective businesses. From time to time, an Authorized Entity may need to process the personal data on other legal bases, including: with consent; to comply with a legal obligation; if it is necessary to protect the vital interests of an investor or other data subjects; or if it is necessary for a task carried out in the public interest.

A failure to provide the personal data requested to fulfill the purposes described in this EU Privacy Notice may result in the applicable Authorized Entities being unable to provide the services as contemplated by the Partnership Agreement and/or an investor’s subscription agreement (the “Subscription Agreement”).

Purpose of Processing
The applicable Authorized Entities process the personal data for the following purposes (and in respect of paragraphs (3), (4) and (6), in the legitimate interests of the Authorized Entities):

  1. The performance of obligations under the Partnership Agreement and/or the Subscription Agreement (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund.
  2. The administrative processes (and related communication) carried out between the Authorized Entities in preparing for the admission of investors to the applicable fund.
  3. Ongoing communication with investors or potential investors, their representatives, advisors and agents, (including the negotiation, preparation and signature of documentation) during the process of admitting investors to the applicable fund.
  4. The ongoing administrative, accounting, reporting and other processes and communication required to operate the business of the applicable fund in accordance with the Partnership Agreement and other applicable documentation between the parties.
  5. Any legal or regulatory requirement.
  6. Keeping investors informed about the business of the general partner of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund.
  7. Any other purpose that has been notified, or has been agreed, in writing.

The Authorized Entities monitor communications where the law requires them to do so. The Authorized Entities also monitor communications, where required to do so, to comply with regulatory rules and practices and, where not prohibited to do so, to protect their respective businesses and the security of their respective systems.

Sharing and Transfers of Personal Data

In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where not prohibited by EU Data Protection Legislation, to other service providers, employees, agents, contractors, consultants, professional advisors, lenders, data processors and persons employed and/or retained by them in order to fulfill the purposes described in this EU Privacy Notice. In addition, any Authorized Entity may share personal data with regulatory bodies having competent jurisdiction over them, as well as with tax authorities, auditors and tax advisors (where necessary or advisable to comply with law).

Any Authorized Entity may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfill the purposes described in this EU Privacy Notice and in accordance with applicable law, including where such transfer is a matter of contractual necessity to enter into, perform and administer the Subscription Agreement and Partnership Agreement, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact Avesi. For the purposes of this EU Privacy Notice, “Non-Equivalent Country” shall mean a country or territory other than (a) a member state of the EEA; or (b) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU Data Protection Legislation to ensure an adequate level of protection for personal data.

Retention and Security of Personal Data

Avesi and its affiliates consider the protection of personal data to be a sound business practice, and to that end, employ appropriate technical and organizational measures, including robust physical, electronic and procedural safeguards to protect personal data in their possession or under their control.

Personal data may be kept for as long as it is required or advisable for legitimate business purposes, to perform contractual obligations or, where longer, as long as is required to comply with applicable legal or regulatory obligations. Personal data will be retained throughout the life cycle of any investment in a fund managed by Avesi. However, some personal data will be retained after a data subject ceases to be an investor in such fund.

Data Subject Rights

It is acknowledged that, subject to applicable EU Data Protection Legislation, the data subjects to which personal data relates have the following rights under EU Data Protection Legislation: to obtain information about, or (where applicable) withdraw any consent given in relation to, the processing of their personal data; to access and receive a copy of their personal data; to request rectification of their personal data; to request erasure of their personal data; to exercise their right to data portability; and to exercise their right not to be subject to automated decision-making. Please note that the right to erasure is not absolute, and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, erasure of the personal data requested to fulfill the purposes described in this EU Privacy Notice may result in the inability to provide the services as contemplated by the Partnership Agreement and/or the Subscription Agreement.

In case a data subject to whom personal data relates disagrees with the way in which his or her personal data is being processed in relation to the Partnership Agreement and/or the Subscription Agreement, the data subject has the right to object to this processing of personal data and request restriction of the processing. The data subject may also lodge a complaint with the competent data protection supervisory authority in the relevant jurisdiction.

A data subject may raise any request relating to the processing of his or her personal data with Avesi at the contact information provided above.