HCG PRIVACY POLICY

Last Updated: November 15, 2023

We at HCG Fund Management LP, our subsidiaries and affiliates (“HCG,” “we,” “us,” or “our”) would like to thank you for your interest and welcome you to our websites. We are committed to protecting your privacy. This Privacy Policy (“Policy”) helps you understand how we collect, use, secure, and share your personal information collected by us. This Policy applies while you visit our website located at www.hcgfunds.com, jobs.lever.co/HCGFunds, or any other websites, pages, or features we own or operate (collectively, the “Site(s)”) that link to or incorporate this Policy. To the extent you are located in the European Economic Area, the United Kingdom, or Switzerland (collectively, the “European Countries”) at the time of data collection, please see our UK/EU for details.

Please read this entire Policy to make sure that you fully understand it. By accessing, visiting, or using our Sites, you the collection, use, and disclosure of your personal information as described in this Policy, and you agree to the accompanying Terms and Conditions. If you do not agree with or are not comfortable with any part of this Policy, please immediately discontinue access or use our Sites.

We reserve the right to amend or revise this Privacy Policy from time to time without notice. If we change this Policy in a way that we believe materially affects how we process your personal information or reduce your rights, we will provide notice via email, mail, or by posting a prominent notice on our Sites. This Privacy Policy is not intended to, and does not, create any contractual or other legal rights in or on behalf of any visitor to our Sites.

Personal Information We Collect

We may collect the following kinds of personal information that you voluntarily provide while using our Sites:

Transaction Information. When you carry out transactions through our Sites, we may collect transactional information such as financial account number.
Customer Support Information. When you choose to get in touch with us via email or using the contact us form on our Sites, we may collect your first and last name, email address, copies of your correspondence, and additional information you choose to share with us.
Career Information. When you apply to join our team through the Sites, we may collect your first and last name, email address, phone number, current company name, and any employment related information contained in your resume/CV.
Other Information. We may collect any other information that you voluntarily send to us.

To the extent permitted under applicable law, and to improve the performance of our Sites, we may collect the following types of personal information automatically from you:

Log Data and Usage Information. When you browse our Sites, we automatically collect log data such as your web request, browser type, referring and exit pages and URLs, pages viewed and the order of these page views, the date and time you access our servers, and other diagnostic data.

How We Use Your Personal Information

Our primary purpose in collecting personal information is to provide you with a secure and smooth experience on our Sites. In general, we use personal information to create, develop, operate, deliver, and improve our Sites. We may use your personal information in the following ways:

We may use the information to deliver a service or product to you, provide you with requested information or materials.
We may use the information to notify you of our services and products and send administrative, account, or transaction-related communications to you.
We may use the information to maintain our legal and regulatory compliance and respond to law enforcement and regulatory agency requests, as required by applicable law, court order, or governmental regulations.
We may use the information to enforce our terms in our agreements.
We may use the information to detect and prevent abusive use of our Sites, enhance security, and combat other security risks.
We may use the information to respond to you when you contact us with questions, concerns, and feedback.
We may use the information to understand how you use and interact with our Sites to improve our existing Sites and build new Sites.
We may use the information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We may use the information for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services requested, with your permission or upon your direction

We do not use the information that we collect on this website in any fashion that will affect your eligibility, healthcare coverage, claims payments, or premiums.

How We Share Your Personal Information

We may share your personal information listed above with third parties and service providers when necessary for business purposes. The categories of third parties with whom we may share your personal information include:

a) Our Affiliates and Subsidiaries. We may share information between and among HCG subsidiaries and affiliates for management, analysis, client, and investor support, and other business purposes.
b) Our Service Providers. We may share your information with service providers performing necessary business functions for us, such as secure website hosting, cloud storage, information technology maintenance, and analytics.
c) Authorized Third Parties. We may disclose your information to third parties that you authorize us to disclose personal information in connection with products or services we (or they) provide you.
d) Corporate Transaction. We may disclose your information to buyers or other successors in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred. By engaging with us or using our Sites, you understand and agree to our assignment or transfer of rights to your personal information.
e) As Required by Law. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of HCG or our clients and investors.
f) With Your Consent. We may disclose your personal information for any purpose with your consent.

We will not share, rent, or sell personal information unless required or permitted by applicable law. When we disclose personal information to third parties, we will seek reasonable assurances from them to hold the information confidential and treat it in accordance with applicable privacy laws.

Cookies and Similar Tracking Technologies

We, and third parties on our behalf may employ various tracking technologies, such as cookies and other similar technologies (collectively, “Tracking Technologies”) to collect personal information automatically as you interact with our Sites, to help us customize your experience and better manage content on our Sites, including to:

Analyze our web traffic using an analytics package
Identify whether you already visited our Sites
Store information about your preferences
To recognize when you return to our Sites

Cookies are small text files that a website can use to recognize a repeat visitor to the Site. The following types of cookies may be used on our Sites:

Strictly Necessary Cookies. These cookies are essential because they enable you to use our Sites as you reasonably expect. Without these cookies, some Site features cannot function. This category of cookies is essential for our Site to work and so they cannot be disabled.
Functional Cookies. We use functional cookies to remember your choices so that we may tailor our Sites to provide you with enhanced features and personalized content. While these cookies can be disabled, this may result in less functionality during your use of our Site.
Analytics Cookies. These cookies allow us to collect passive information about your use of our Sites, for example, count page visits and traffic sources to measure and improve our Sites’ performance.
Advertising Cookies. These cookies may be set through our website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to your interests.

You have the right to decide whether to accept cookies. Suppose you do not want HCG to deploy cookies in your browser. In that case, you may exercise your preference by modifying your web browser setting to either (1) refuse some or all cookies or (2) notify you and ask for your permission when a website tries to set a cookie. If you want to learn the correct way to modify your browser settings, please use the “Help,” “Tools,” or “Edit” menu in your browser or review the instructions provided by your local browse. If you choose to disable cookies in your browser, you can still use our Sites, although your ability to use some of the features may be affected.

Our Sites and our third-party technology providers use third-party analytics services (such as Google Analytics) to evaluate your use of the Sites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Sites and Internet usage. For more information on how to opt-out of Google Analytics’ tracking, please

Interest-Based Advertising. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.

How We Protect Your Personal Information

We maintain our Sites and all associated information with technical, administrative, and physical safeguards to protect against the loss, unauthorized access, destruction, misuse, modification, and improper disclosure of your personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the internet. If you feel that the security of any account you might have with us has been compromised, you should contact us immediately at compliance@hcgfunds.com.

What We Want You To Know About Sending eMail to Us

You should be aware that, email communication may not be secure. When sending an email to us, it is possible that other Internet users may, without permission and/or notice, be able to view your email correspondence. You should take special care in deciding what information you send to us via email, and please do not send us sensitive information, such as financial account information or government-issued IDs. If you wish to ensure that your communication is kept private and confidential, please call or write directly to us using the contact information on our Sites. We do encourage your feedback, comments, and suggestions about ways we can better communicate with you. Your comments are welcome and important. You can contact us by following this link.

Retention of Your Personal Information

We will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. We will cease to retain your personal information or remove the means by which the data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes.

Notice to California Residents

This section only applies to California residents. The purpose of this section is to inform California residents (“consumers” or “you”), at or before the time of collection of personal information, about HCG’s data collection practices and your privacy-related rights under California privacy laws, including the California Consumer Privacy Act of 2018, as amended (“CCPA”). For the purpose of this section, the term “personal information,” as defined under the CCPA, is used. Personal information does not include publicly available information from government records, de-identified or aggregated information, or information excluded from the CCPA’s scope, including: personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Categories of Personal Data Collected

The chart below describes the categories of personal information HCG has collected in the preceding 12 months, the sources, and purpose of such collection, and the parties to whom the information was shared for business purposes.

Personal Information Category (corresponds to categories in CCPA §1798.140(o)(1))	Sources of Personal Information *(see Section 1 above for more information)*	Purpose of Information Collection	Disclosure of Personal Information (see Section 5 above for more information)
(A) Identifiers	See Section 1, subsection (a) – (d).	See Section 2, subsection (a) – (i).	See Section 3, subsection (a) – (f).
(B) Personal information under California Civil Code section 1798.80	See Section 1, subsection (a) – (d).	See Section 2, subsection (a) – (i).	See Section 3, subsection (a) – (f).
(D) Commercial information, such as records of service purchased	See Section 1, subsection (a) – (c).	See Section 2, subsection (a)-(f), (h), (i).	See Section 3, subsection (a)-(c), (e), and (f).
(F) Internet activity information, such as browsing history.	See Section 1, subsection (e).	See Section 2, subsection (a), (c), (d), (e), (g) and (h).	See Section 3, subsection (a), (b), (e), and (f).
(I) Professional or employment related information	See Section 1, subsection (c).	See Section 2, subsection (a) and (h).	See Section 3, subsection (a) –(c).
(J) Inferences about preferences, characteristics, etc.	See Section 1, subsection (e).	See Section 2, subsection (b) and (g).	See Section 3, subsection (a), (b) and (e).

Your Privacy Rights

Subject to certain exceptions, if you are a California Resident, you may be able to assert the following rights identified below with respect to your personal information:

Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.
Right to Correct/Rectification. You may have the right to correct any of your personal information in our records and systems. You may request us to rectify, correct or update any of your personal information held by us that is inaccurate.
Right to Delete/Erasure. Under certain circumstances, you may have the right to request that we delete the personal information that we hold about you. This right is not absolute, and we may refuse your right to delete if it is reasonably necessary for us to provide a service requested by you; to perform a contract between us; to maintain functionality and ensure security of our systems; to enable solely expected internal uses of your personal information; to exercise a right provided by law; to comply with a legal obligation, or if there are compelling legitimate grounds for keeping your personal information.
Right to Portability. Under certain circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another entity.
Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.
Right to Object to Automated Decision-Making. You may have the right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.

Right to Limit Use or Disclosure of Sensitive Personal Information. without your consent.

Submitting a Request to Exercise Your Privacy Rights

To assert your privacy rights, please email compliance@hcgfund.com. Please note that to protect your privacy and security, we must be able to verify your identity before we can process your request. We may conduct the verification process by email or phone, and we may ask you to provide information such as your name, contact information, and any additional relevant information based on your relationship with us. You may also use an authorized agent to submit a request on your behalf if you provide the authorized agent signed written permission to do so.

Right to Opt-Out of Sale and Sharing

If you reside in California, you may have the right to opt-out of sale and sharing of your personal information to third-parties for behavioral or cross-contextual advertising purposes. We sell or share your personal information.

Shine the Light Law

If you are a California resident, you may opt out of us disclosing your personal information to third parties for direct marketing purposes. In your request, please specify that you want a “California Shine the Light Notice.”

Do Not Track

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

Access To Other Websites From Our Sites

During your visit to our Sites, you may have the opportunity to link to other websites. Please be aware that we do not have any access, control, input, or authorization over any of the materials or content contained on these websites. Additionally, we are not liable or responsible for the privacy practices, content, or policies of any of these other websites.

Contact Us

If you have any questions about this Privacy Policy, want to exercise a privacy right with respect to your personal information if you are a California resident, or have a privacy-related complaint, please contact us by email at , by phone at 919.300.7702, or by writing us at 133 Fayetteville St, 3rd Floor, Raleigh, NC 27601.