WEBSITE PRIVACY NOTICE
Paine Schwartz Partners, LLC
January 2026
Our Commitment to Your Privacy: Your privacy is important to Paine Schwartz Partners, LLC and its affiliates (together, “our”, “us”, “we” or “PSP”). We have a policy of protecting the confidentiality and security of information we collect about you. We are providing you this Website 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.
This website privacy notice (this “Website Privacy Notice”), together with the California Website Privacy Notice supplement and the EEA-UK Website Privacy Notice Supplement, describes how we gather and use information in connection with https://paineschwartz.com/ (the “website”) and your communication with us in relation to the website. We gather limited types of personal information through the website, and the types of personal information we collect about you depends on the nature of your interaction with us. If you provide personal information through other means (e.g., as an employee or seeking employment, or as a client or investor in other contexts), you will receive a separate privacy notice in each such context which will govern our processing of such personal information. For simplicity, we use the terms “personal information”, personally identifiable information” and “personal data” in this Website Privacy Notice (and any additional jurisdiction-specific privacy notices) interchangeably. Please read this Website Privacy Notice carefully. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, the Website Privacy Notice stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Website Privacy Notice, please do not access or use this website.
Jurisdiction-Specific Information: This Website Privacy 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 foreign or domestic laws that may apply to you, including as set forth in our California Website Privacy Notice supplement. If you are a California resident, please also see the California Website Privacy Notice supplement.
If you are located in the European Economic Area, the European Union, or the United Kingdom, or your personal data is otherwise subject to EEA and/or UK data protection laws, please also see the EEA-UK Website Privacy Notice Supplement.
What information do we collect about you: The types of personal information we collect about you depends on the nature of your interaction with us and our reasons for collecting your personal information. We may collect the following categories of personal information from you in connection to our website:
- identifiers, such as Internet Protocol address, as well as any email addresses, names or other identifiers;
- internet or other electronic network activity information, such as information regarding use of our website (e.g., cookies, browsing history and/or search history); and
- any other personal information that you may provide us during the course of your interaction with our website, including by contacting us at our email address (e.g., example@paineschwartz.com).
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
How do we obtain your personal information: In connection with operating our website, we collect and maintain your personal information from the following sources:
- information from your communications with us in connection with our website; and
- information captured on our website, including any information captured via cookies (or similar technology).
We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources or third parties. This will include information collected in an online or offline context.
How do we use your personal information: We may use any personal information provided to us through or in connection with our website, for one of the following business or commercial purposes:
| Purpose | Legal Basis (relevant to the EEA-UK Privacy Notice) |
| To perform services for you. | Contractual necessity; and/or our legitimate interest in operating our business. |
| To provide, support, personalize, develop and improve our website and the products and services that we offer, and notify you about changes to our products and services. | Our legitimate interest in operating our business. |
| To provide you with support and to communicate with you, including responding to requests for information submitted by you through our website. | Our legitimate interest in operating our business. |
| To provide advertising and marketing services. | Our legitimate interest in operating our business. |
| To keep a record of your relationship with us. | Our legitimate interest in operating our business. |
| Ongoing operations, administrative, reporting and other processes. | Legal requirement; contractual necessity; and/or our legitimate interest in operating our business. |
| To audit and verify the quality and effectiveness of our services and compliance. | Our legitimate interest in operating our business. |
| To maintain the safety, security and integrity of our websites, products and services, databases, technology assets and business including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity. | Our legitimate interest in operating our business. |
| As needed, to comply with U.S., state, local, and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations. | Legal requirement. |
| For any other purpose that has been notified in writing. | Consent or as notified. |
We may process your personal information on more than one legal basis depending on the specific purpose for which we are using your personal information.
Marketing Communications: Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us, and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.
Disclosure of Information: Your personal information may be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this Website Privacy Notice. We use a number of service providers that provide a wide range of services, including, but not limited to, administrators, lenders, banks, auditors, law firms, governmental agencies, self-regulatory organizations, recruitment firms, IT and data security providers, data hosting providers, consultants and/or placement agents. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.
We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal data to the new owner of the relevant business and their advisors.
Former Investors: We maintain personal information of our former investors and apply the same policies that apply to current investors.
Security and Retention of Personal Information: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, operational, electronic and procedural safeguards to safeguard and secure our data networks, which seek to prevent unauthorized access to personal information and protect your personal information in our possession or under our control. However, the transmission of information and data via the Internet is not completely secure, and although we make an effort to protect your personal information, we cannot guarantee the security of any information or data transmitted to or through our website. Any transmission of personal information or data by you to or through this website is at your sole risk.
We will retain your personal information only for as long as is reasonably necessary and proportionate for the purposes set out in this Website Privacy Notice, unless a longer retention period is required by law. We may retain personal information for longer where required by our regulatory obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others. Your personal information may be deleted when it is no longer relevant or when you withdraw consent (pursuant to the rights detailed directly in this may be exercised by using the contact information contained at the end of this Website Privacy Notice) within the parameters of applicable law.
Further Information: We reserve the right to change our privacy policies and this Website Privacy Notice (and any jurisdiction-specific privacy notices) at any time, in our sole discretion, without notice, by updating this Website Privacy Notice (and any jurisdiction-specific privacy notices). Accordingly, users are strongly encouraged to review this Website Privacy Notice (and any applicable jurisdiction-specific privacy notices) regularly. If we decide to change what information we collect, how we use it and under what circumstances, if any, we disclose it, we will update this Website Privacy Notice. If at any point we decide to collect personal information through this website or use any collected information from this website in a manner different from that stated at the time it was collected, we will notify users by making updated information available on this page. Your continued access or use of this website following the posting of changes to this Website Privacy Notice (and any applicable jurisdiction-specific privacy notices) means that you accept such revisions, changes and/or amendments. The examples contained within this notice are illustrations only and are not intended to be exhaustive. This Website Privacy Notice is intended to comply with the privacy provisions of applicable U.S. federal law and certain privacy provisions of other laws. You may have additional rights under state or non-U.S. laws that apply to you, including as set forth in our additional privacy notices.
Capacity: You represent to PSP that you have the authority to visit this website according to the Terms of Use. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
Cookies: Information regarding how you access the website (e.g., browser type, access times, and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of our website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of our website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used, and how you manage your cookie preferences.
Subject to your consent, the website will place the cookies listed below:
| Cookie | Name | Type/Purpose | Duration |
| Functional | _cf_bm | Cloudflare set the cookie to support Cloudflare Bot Management. | 29 minutes |
| Analytics | -ga_* | Google Analytics sets this cookie to store and count page views. | 1 year 1 month 4 days |
| Analytics | -ga | Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. | 1 year 1 month 4 days |
| Performance | none | n/a | n/a |
| Advertisement | none | n/a | n/a |
Contact Us: If you have any questions or concerns about this Website Privacy Notice, or if you wish to appeal any of our decisions, exercise any of your rights hereunder or request to view this Website Privacy Notice in an alternate format, please contact us at rmalavazzi@paineschwartz.com.
CALIFORNIA WEBSITE PRIVACY NOTICE
This California website privacy notice (this “California Website Privacy Notice”) supplements the Website Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, and together with its implementing regulations and guidelines, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth above in the Website Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
What does this California Website Privacy Notice apply to: This California Website Privacy Notice applies to California residents and solely with respect to your interactions with PSP through our website, as described above in the Website Privacy Notice. If you provide personal information to use through another means (e.g., as an investor or an employee seeking employment) you will receive a separate privacy notice and that notice will govern that personal information.
Categories of Personal Information We Collect: The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this website over the last twelve (12) months include the following:
| Category | Examples | Collected |
| A. Identifiers | Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number). | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets). | YES |
| C. Protected classification characteristics under California or federal law | Date of birth, citizenship and birthplace. | YES |
| D. Commercial information | Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s). | YES |
| E. Biometric information | Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. | NO |
| F. Internet or other similar network activity | Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries | YES |
| G. Geolocation data | Physical location or movements. | NO |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
| L. Sensitive Personal Information (see further information on use of sensitive personal information below) | Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. | YES, as to the following types of information: social security, driver’s license, state identification care, or passport numbers, account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only. |
We do not collect or use sensitive personal information other than:
- To perform services, or provide goods, as would reasonably be expected by an investor who requests those goods or services;
- As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
- As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
- For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
- To perform services on behalf of our business;
- To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
Purposes for Collecting Personal Information: We collect personal information for the business and commercial purposes and from the sources set forth in “How do we use your personal information” and “How do we obtain your information” respectively, in the Website Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this California Website Privacy Notice only as long as is reasonably necessary for those purposes set forth in the Website Privacy Notice above in “How do we use your personal information”, except as may be required under applicable law, court order or government regulations.
Disclosure of Information: We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
Within the last twelve (12) months, we have disclosed personal information collected from you for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
| Personal Information Category | Category of Third-Party Recipients |
| A. Identifiers | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| C. Protected classification characteristics under California or federal law | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| D. Commercial information | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| E. Biometric information | N/A |
| F. Internet or other similar network activity | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| G. Geolocation data | N/A |
| H. Sensory data | N/A |
| I. Professional or employment-related information | N/A |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | N/A |
| K. Inferences drawn from other personal information | N/A |
| L. Sensitive Personal Information | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
How do we keep your personal information secure: We consider the protection of personal information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting such personal information;
- Categories of third parties to whom we disclose the personal information;
- The specific pieces of personal information we have collected about you; and
- Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this California Website Privacy Notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the “Contact Us” section below.
Contact Us: For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below:
Call us using the following toll-free number: (877) 423-4975
Submit a request online using the following online form: https://paineschwartz.com/contact/
Email us at the following address: rmalavazzi@paineschwartz.com
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable in order to verify your identity or right to receive the information requested, including through a third-party verification service. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.
Please contact the Chief Compliance Officer of Paine Schwartz Partners, LLC at rmalavazzi@paineschwartz.com with any questions or concerns about this California Website Privacy Notice.
EEA-UK WEBSITE PRIVACY NOTICE SUPPLEMENT
Paine Schwartz Partners, LLC
Paine Schwartz Food Chain Fund VI GP, L.P.
Paine Schwartz Food Chain Fund VI, L.P.
Paine Schwartz Food Chain Fund VI-A, L.P.
This EEA-UK Website Privacy Notice Supplement (this “EEA-UK Website Privacy Notice”) supplements the general Website Privacy Notice to the extent that EEA-UK Data Protection Legislation (as defined below) applies to the processing of personal data by us.
For purposes of this EEA-UK Privacy Notice, “EEA-UK Data Protection Legislation” means all applicable legislation and regulations relating to the protection and/or processing of personal data in force from time to time in the EU, the EEA or the UK, including (without limitation) the following: (a) Regulation (EU) 2016/679 (the “GDPR”); (b) the GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR”); and (c) any other legislation that implements any other current or future legal act of the EEA, EU or UK (or any of their member states) concerning the protection and processing of personal data and any national implementing or successor legislation and any amendment or re-enactment of the foregoing. The terms “controller,” “processor,” “data subject,” “personal data” and “processing” in this EEA-UK Privacy Notice shall be interpreted in accordance with the applicable EEA-UK Data Protection Legislation.
To the extent that EEA-UK Data Protection Legislation applies to our processing of your personal data, we will be a “controller” of your personal data. In simple terms, where applicable, this means we: (a) “control” the personal data that we collect from you or other sources; and (b) make certain decisions on how to use and protect such personal data.
Please direct any questions arising out of this EEA-UK Privacy Notice to Paine Schwartz Food Chain Fund VI GP, L.P. (the “General Partner”) at rmalavazzi@paineschwartz.com.
What categories of personal data do we collect?
We collect limited categories of personal data through our website, as further set forth in “What information do we collect about you” section in the general Website Privacy Notice above.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or any information about criminal convictions and offences.
If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data.
How do we obtain your personal data?
In connection with forming and operating our website, we collect and process your personal data from you and other third parties and/or publicly available sources listed in “How do we obtain your personal information” section in the general Website Privacy Notice above.
How do we use your personal data?
There is a need to process personal data for the purposes and on the legal bases set out in the “How do we use your personal information” section in the general Website Privacy Notice above.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
A failure to provide the personal data requested to fulfill the purposes described in this EEA-UK Privacy Notice may result in the us being unable to provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
No automated decision-making, including profiling, is used when processing your personal data.
Sharing and transfers of personal data
To the extent your personal data is transferred to a Non-Equivalent Country (as defined below), such transfer will only be made in accordance with the EEA-UK Data Protection Legislation. For the purposes of this EEA-UK Privacy Notice, “Non-Equivalent Country” shall mean a country or territory other than (a) a member state of the EU or EEA; (b) the United Kingdom; or (c) a country or territory which has at the relevant time been decided by the European Commission or the Government of the United Kingdom and/or the UK Information Commissioner’s Office in accordance with EEA-UK Data Protection Legislation to ensure an adequate level of protection for personal data.
Retention and security of personal data
We employ appropriate technical and organizational measures, including physical, electronic and procedural safeguards to protect personal data in our possession or under our control, as described in the “Security and Retention of Personal Information” section in the general Website Privacy Notice above.
Data Subject Rights
To the extent that EEA-UK Data Protection Legislation applies to our processing of your personal data in connection with our website, you may have the following rights under EEA-UK Data Protection Legislation:
- Access: You may have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
- Correction: You may have the right to notify us of changes to your personal data if it is inaccurate or needs to be updated.
- Deletion: If you think that we should not be holding or processing your personal data anymore, you may request that we delete it. Please note that this may not always be possible due to legal and regulatory obligations.
- Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data override your own rights.
- Object: You may have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
- Portability: If you wish to transfer your personal data to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
- Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
These rights are not absolute and in certain circumstances their exercise may not be possible including when personal data must be maintained to comply with applicable laws.
To exercise these rights and controls, please contact rmalavazzi@paineschwartz.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Contact us
If you have any questions or concerns about this EEA-UK Website Privacy Notice, please contact rmalavazzi@paineschwartz.com.
Complaints
Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.
CAYMAN ISLANDS PRIVACY NOTICE
Introduction
The purpose of this Cayman Islands Privacy Notice is to provide you with information on our use of your personal data in accordance with the Data Protection Act (As Revised) of the Cayman Islands (the “DPA”).
Unless otherwise defined herein, capitalized terms used in this Cayman Islands Privacy Notice will have the meanings ascribed to such terms in the Agreement of Exempted Limited Partnership (as amended, restated, supplemented, waived and/or otherwise modified from time, the “Partnership Agreement”) of Paine Schwartz Food Chain FundVI, L.P. and/or Paine Schwartz Food Chain Fund VI-A, L.P., as applicable (the “Partnership”). In this document, “we”, “us” and “our” refers to the Partnership, Paine Schwartz Food Chain Fund VI GP, L.P. (the “General Partner”), Paine Schwartz Partners, LLC (the “Management Company”) and their affiliates and/or delegates.
Investor Data
By virtue of making an investment in the Partnership (and indirectly, any alternative investment vehicles established by the Partnership) and your associated interactions with us (including any subscription, capital commitment and/or capital contribution, whether past, present of future) or by virtue of you otherwise providing us with personal information on individuals connected with you as an investor (for example your directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents), you will provide us with certain personal information which constitutes personal data within the meaning of the DPA (collectively, “Investor Data”). We may also obtain Investor Data from other public sources. Investor Data includes, without limitation, the following information relating to you and/or any individuals connected with you as an investor: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your investment activity.
In our use of Investor Data, the Partnership (acting through the General Partner) will be characterized as a “data controller” for the purposes of the DPA. The Partnership’s and/or the General Partner’s affiliates, delegates and service providers may act as “data processors” for the purposes of the DPA.
Who this Affects
If you are a natural person, this will affect you directly. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts, partnerships or limited partnerships) that provides us with Investor Data on individuals connected to you for any reason in relation to your investment with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.
How We May Use Your Personal Data
The Partnership, as the data controller, may collect, store and use Investor Data for lawful purposes, including, in particular:
(i) where this is necessary for the performance of our rights and obligations under the constitutional and operational documents of the Partnership (together with any subscription agreements or other contracts to which you and we are a party);
(ii) where this is necessary for compliance with a legal or regulatory obligation to which the Partnership and/or the General Partner are subject (such as compliance with anti-money laundering, counter-terrorist or proliferation financing, sanctions-compliance or FATCA/CRS requirements); and/or
(iii) where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.
Additionally, any of the Partnership’s affiliates and/or delegates and/or appointed service providers (the “Delegates”), may use Investor Data, for example to provide its services to the Partnership, the General Partner and/or their respective affiliates to discharge the legal or regulatory requirements that apply directly to them or in respect of which the Partnership and/or the General Partner relies upon the Delegates, but such use of Investor Data by a Delegate will always be compatible with at least one of the aforementioned purposes for which we process Investor Data.
Should we wish to use Investor Data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.
Why We May Transfer Your Personal Data
In certain circumstances we and/or our Delegates may be legally obliged to share Investor Data and other information with respect to your interest in the Partnership with the relevant regulatory authorities such as the Cayman Islands Monetary Authority or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities.
We may disclose Investor Data to carry out and implement any and all purposes and objects of the Partnership, including: (i) to our Delegates, custodians, banks, financing parties, broker-dealers, accountants, auditors and lawyers, who will either process Investor Data on our behalf or may be data controllers in their own right; (ii) to regulatory, administrative, law enforcement agencies, ombudsmen or other oversight bodies; (iii) to any third party that acquires, or is interested in acquiring, all or a substantial part of the our assets or equity interests, or that succeeds the Management Company or the General Partner in carrying on all or a part of our business; (iv) as required or permitted by law or regulation, including to comply with a subpoena or similar legal process; (v) when we believe in good faith that disclosure is legally required; or (vi) when we have a legitimate interest in making a disclosure and such interests are not overridden by your interests, fundamental rights or freedoms, such as where necessary to protect the Management Company’s, the General Partner’s or the Partnership’s rights and property. This may include certain entities located outside the Cayman Islands or the European Economic Area.
The Data Protection Measures We Take
Any transfer of Investor Data by us or our duly authorized Delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPA.
We and our duly authorized Delegates shall apply appropriate technical and organizational information security measures designed to protect against unauthorized or unlawful processing of Investor Data, and against accidental loss or destruction of, or damage to, Investor Data.
We shall notify you of if we have actual knowledge of any Investor Data breach that we believe is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant Investor Data relates.
Getting In Touch
Should you have any queries or wish to discuss your data protection rights with us, please contact the Partnership, the Management Company or the General Partner.
