U.S. Privacy Notice
Sheridan CP, LP
Sheridan Capital Partners Fund II GP, LP
Sheridan Capital Partners Fund II, LP
Sheridan Capital Partners Fund II-A, LP
Sheridan Capital Partners Fund III GP, LP
Sheridan Capital Partners Fund III, LP
Sheridan Capital Partners Fund III-A, LP
Sheridan Capital Partners DOCS SPV GP, LP
Sheridan Capital Partners DOCS SPV, LP
Sheridan Capital Partners DOCS SPV-A LP
August 2023
Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our individual limited partners. We have a policy of protecting the confidentiality and security of information we collect about you. We are providing you with this 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.
Sources of Non-Public Information: In connection with forming and operating our private investment funds for our limited partners, we collect and maintain non-public personal information from the following sources:
- Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail and other electronic communications or in subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification and verification documentation),
- Information about your transactions with us or others, and
- Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms and any information captured via “cookies.”
Disclosure of Information: We do not disclose any non-public personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
Former Limited Partners: We maintain non-public personal information of our former limited partners and apply the same policies that apply to current limited partners.
Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards, which seek to protect your non-public personal information in our possession or under our control.
Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time. The examples contained within this notice are illustrations only and are not intended to be exclusive. This Privacy Notice is intended to comply 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 state or non-U.S. laws that apply to you, including as set forth in our additional privacy notices.
PRIVACY NOTICE SUPPLEMENT FOR CALIFORNIA RESIDENTS
This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (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 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.
Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:
| 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 average consumer 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 may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes:
- performing services for you, including but not limited to:
- the administrative processes (and related communication) in preparing for the admission of investors to the fund(s), including administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase interests in the fund(s);
- ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund and the execution of all relevant agreements;
- the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, know your customer (KYC) and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
- ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
- keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
- facilitating the execution, continuation or termination of the contractual relationship between an investor and the general partner or managing member, the investment adviser and/or the fund(s);
- facilitating the transfer of fund interests, and administering and facilitating any other transaction, between an investor, the general partner or managing member, the investment adviser and/or the fund(s);
- auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
- maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
- enabling any actual or proposed assignee or transferee of the fund(s), to evaluate proposed transactions;
- facilitating business asset transactions involving the funds; and
- complying with U.S., state, local and non-U.S. laws, rules and regulations.
We collect personal information from the sources set forth in [“Sources of Non-Public Information”] in the Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this Privacy Notice Supplement only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.
Disclosure of Information: We do not share for the purpose of cross-context behavioral advertising or sell3 (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, tax providers, 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, tax providers, 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, tax providers, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| D. Commercial information | Administrators, lenders, banks, tax providers, 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, tax providers, 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, tax providers, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
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 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 with 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 notice in an alternative format, please submit a request on your behalf using any of the methods set forth below.
- Submit a request online using the following online form: https://www.sheridancp.com/contact
- Email us at the following email address: info@sheridancp.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 request. 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 Jessica Morris, Chief Compliance Officer of Sheridan CP, LP at jessica.d.morris@sheridancp.com with any questions or concerns about this Privacy Notice.