Last updated and effective as of June 1, 2024

Crossbow Capital Partners considers privacy to be fundamental to the relationship with you. The Firm is committed to maintaining the confidentiality, integrity and security of your personal information. Accordingly, the Firm has developed internal policies and practices to protect the confidentiality of your personal information while still meeting your needs. The Firm is providing this policy to you so that you know what kinds of information the Firm collects about you, how that information is used, the circumstances in which that information may be disclosed to third parties, and certain rights you may have with respect to that information.

Collection of information

As part of your interaction with the Firm, as a visitor to the Firm’s offices or as a prospective, current or former investor, the Firm collects certain personal information about you. The below chart describes the categories of personal information that the Firm may collect and the business purposes for which that personal information may be used:

  • Identifiers (including name, physical address, e-mail address, phone number, Social Security number, passport number, driver’s license information):
    • Operational purposes (including setting up and managing your investor accounts and transactions, detection and prevention of fraud as well as making distributions)
    • Marketing (including to communicate with you and provide you with information the Firm believes may be of interest to you)
    • Customer service (including sending communications to you in connection with your investment)
    • Compliance with Know Your Client (“KYC”) and anti-money laundering (“AML”) laws and regulations as well as legal compliance with any other applicable laws or regulations
    • Detecting security incidents; protecting against malicious, deceptive, fraudulent or illegal activity and prosecuting those responsible for that activity
    • Ensuring a safe and healthy office environment for the Firm’s employees and visitors
  • Personal records, including bank account number, Know Your Client (“KYC”) and anti-money laundering (“AML”) information, including country of origin/nationality, country of domicile/tax residence, tax reference number:
    • Operational purposes (including setting up and managing your investor accounts and transactions, detection and prevention of fraud as well as making distributions)
    • Compliance with Know Your Client (“KYC”) and anti-money laundering (“AML”) laws and regulations as well as legal compliance with any other applicable laws or regulations
    • Ensuring a safe and healthy office environment for the Firm’s employees and visitors
  • Demographic, protected classification and association information, such as date of birth; information relating to politically-exposed persons and foreign political figures:
    • Operational purposes (including setting up and managing your investor accounts and transactions, detection and prevention of fraud as well as making distributions)
    • Compliance with Know Your Client (“KYC”) and anti-money laundering (“AML”) laws and regulations as well as legal compliance with any other applicable laws or regulations
  • Professional Information, such as occupation, employment history and education:
    • Operational purposes (including setting up and managing your investor accounts and transactions, detection and prevention of fraud as well as making distributions)
    • Compliance with Know Your Client (“KYC”) and anti-money laundering (“AML”) laws and regulations as well as legal compliance with any other applicable laws or regulations
  • Internet or network activity information, such as user authentication information
    • Operational purposes (including setting up and managing your investor accounts and transactions, detection and prevention of fraud as well as making distributions)
    • Compliance with Know Your Client (“KYC”) and anti-money laundering (“AML”) laws and regulations as well as legal compliance with any other applicable laws or regulations
  • Sensitive personal information, such as age, Social Security number, driver’s license number or other government-issued identification card information, passport number, national origin, citizenship and visa status, marital status, gender and contents of mail, email and text messages:
    • Operational purposes (including setting up and managing your investor accounts and transactions, detection and prevention of fraud as well as making distributions)
    • Customer service (including sending communications to you in connection with your investment)
    • Compliance with Know Your Client (“KYC”) and anti-money laundering (“AML”) laws and regulations as well as legal compliance with any other applicable laws or regulations
    • Detecting security incidents; protecting against malicious, deceptive, fraudulent or illegal activity and prosecuting those responsible for that activity
    • Ensuring a safe and healthy office environment for the Firm’s employees and visitors

Sources of information

Crossbow Capital Partners obtains the categories of personal information listed above from the following sources:
– Information directly from you through subscription agreements, questionnaires or other forms that you submit to the Firm
– Information from your interactions with the Firm’s online platforms
– Information from transactions made with the Firm or third parties
– Information the Firm may acquire through meetings, telephone conversations, e-mail messages and other interactions the Firm may have with you over the Internet or via other technologies
– Information from publicly available sources (e.g., court records)
– Third-party service providers, such as KYC service providers

Disclosure of information

Crossbow Capital Partners may disclose the categories of personal information described above, as needed to achieve the stated business purposes above, to:
– service providers, as allowed by applicable law or regulation, including any anti-money laundering or anti-terrorist laws or regulations
– companies that perform various services for the Firm such as accountants, attorneys, auditors, banks, escrow agents, administrative agents, marketing service firms, broker-dealers and other similar relationships, to facilitate the acceptance and management of your investment

Additional uses of information

Crossbow Capital Partners will only process your personal information in pursuance of the Firm’s legitimate interests, where the Firm has considered that processing is necessary and, on balance, the Firm’s legitimate interests are not overridden by yours. The Firm does not collect personal information from you, including through cookies, on this Website and does not permit third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different websites. The Firm currently does not take action on “do not track” signals.
In addition to the disclosures described above, the Firm may also disclose personal information (i) if compelled to do so by law or in connection with any government or regulatory organization request or investigation; (ii) with certain portfolio investments and/or their advisors, when necessary to meet withholding tax requirements or other legal and/or regulatory obligations or to facilitate transaction-related matters; (iii) in the event the Firm sells or transfers (or is in negotiations to sell or transfer) all or a portion of its business or assets (including in the event of a reorganization, dissolution or liquidation); or (iv) when you direct the Firm to do so.
Any third party that receives personal information is required to use your information only for the purposes for which the Firm discloses the information to them and as allowed by applicable law or regulation. Such third party is not permitted to disclose or use this information for any other purpose.
In the preceding 12 months, the Firm has neither (i) sold personal information, nor (ii) shared your personal information to a third party for cross-context behavioral advertising.

Retention period

Crossbow Capital Partners retains your personal information for as long as reasonably necessary and proportionate to achieve the purposes and uses set out in this policy, as authorized by law, and to meet legal, taxation, accounting, risk management or business requirements. The Firm may retain personal information for longer where required by its regulatory obligations, or where the Firm believes it is necessary to establish, defend or protect its legal rights and interests or those of others.

How Crossbow Capital Partners protects your information

To protect your personal information, Crossbow Capital Partners permits access only to authorized employees who need access to that information to provide services to you or in connection with the administration of the Firm. The Firm maintains physical, electronic and procedural safeguards, pursuant to applicable law, which are designed to guard your personal information. An individual’s rights under this policy extend to all forms of contact with the Firm, including telephone, written correspondence and electronic media, such as the Internet.

California Residents
This provision supplements the information contained above and applies solely to residents of California.
Much of the personal information that Crossbow Capital Partners collects is exempt from the rights provided by California Consumer Privacy Act (CCPA). The rights under the CCPA described below do not apply, for instance, to personal information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. As a general matter, those laws apply to non-public personal information about individuals who obtain financial products or services primarily for personal, family or household purposes. This section therefore does not cover information falling within the scope of these exemptions or to which the CCPA’s relevant provisions do not apply.
You have the right to request that the Firm discloses the following information to you about the collection, disclosure and use of your personal information over the 12 months prior to the date of your request:
– The categories of personal information the Firm collects about you
– The categories of sources for the personal information the Firm collects about you
– The Firm’s business or commercial purpose for collecting that personal information
– The categories of personal information the Firm has sold or shared; the categories of third parties with whom the Firm sells or shares that personal information and the business purpose for doing so
– The specific pieces of personal information collected about you
– The categories of personal information the Firm has disclosed; the categories of third parties that the Firm has disclosed them with and the business purpose for doing so
You have the right to request that the Firm deletes any of your personal information that the Firm collected and retained. The Firm will not, however, delete your information if it is needed (i) to fulfill the Firm’s obligations to you or (ii) to comply with legal and regulatory obligations or (iii) to protect the security or functionality of the Firm’s operations or (iv) for certain other reasons in accordance with applicable law or regulation.
The Firm takes reasonable steps to ensure that information held about you is accurate and complete. However, you have the right to request that the Firm corrects any inaccurate personal information that it has about you.
To exercise the rights described above, you may submit a verifiable consumer request by e-mailing at stefano@crossbowcapitalpartners.com. The request must provide sufficient information that allows the Firm to reasonably verify you are the person about whom the Firm collected personal information and it must describe your request with sufficient detail that allows the Firm to properly understand, evaluate and respond to it. The Firm will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf. The agent must be a natural person or a business entity registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to provide the Firm with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. The Firm will also require that you verify your identity directly or confirm that you provided the agent with permission to submit the request.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
The Firm endeavors to respond to a verifiable consumer request within the time periods provided by the CCPA. The Firm will not deny services, offer a different quality of service or otherwise discriminate against you for exercising these rights.