In the course of conducting business, we collect and maintain certain non-public personal information about our former and current investors from different sources.  This Privacy Notice is designed to help our investors better understand how we collect, disclose and protect such personal information. Specifically, in connection with forming and operating our private investment funds (each a "Fund") for our limited partners ("Limited Partners") we collect such personal information from the following sources:

•    Information received from investors or their legal representatives in conversations, in voicemails, over our website, including cookies, through written correspondence, including email, submitted in subscription agreements, contracts and questionnaires or other forms or communications. This includes information such as name, address, telephone number and other contact information, occupation, bank account or other account numbers, tax identification number, Social Security number, government ID information, the types and amounts of investments, statements of net worth and other investor qualification information;

•    Information about investors’ transactions with us, our affiliates or others, such as participation in other investment opportunities, ownership of accounts and other account data; and

•    Information we receive from a consumer reporting agency, such as an individual’s creditworthiness and credit history.

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We do not disclose such personal information to third parties except as set forth below.  

•    In the normal course of serving our investors, we may share such personal information with our affiliates or with companies that perform various services for us such as our accountants, auditors, attorneys, fund administrators, consultants, transfer agents, placement agents and other agents, custodians, broker-dealers, service providers, lenders or financial institutions, and as permitted by law.  

•    We share certain information with the other investors in the Fund, such as the fact that the investor is a Limited Partner in the Fund, the investor’s contact information and the amount of the investor’s Commitment.  

•    We may also share personal information, with the consent or at the direction of investors, such as to the extent provided in the subscription agreement for a Fund  ("Subscription Agreement"), the partnership agreement of a fund ("Partnership Agreement") and/or other agreements.  

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We require third-party service providers and financial institutions with which we have relationships to confirm that they have implemented and maintain appropriate safeguards to protect the confidentiality of personal information and to use the information only for the purpose for which we disclose the information to them.

We store and process investors’ personal information on our computers in the U.S. To protect investors’ personal information from unauthorized use and access, we maintain physical, electronic and procedural safeguards designed to comply with applicable U.S. federal and state regulations, including computer safeguards and secured files.  Further we permit access only by our authorized employees, affiliates, agents or representatives (including, without limitation, those persons described in the foregoing paragraph) who need access to this information to provide services to us, Funds and Limited Partners or other investors.  We will adhere to the policies and practices described in this Privacy Notice in relation to your personal information regardless of whether you are a current or former investor. 

 

We reserve the right to change our privacy policies and this Privacy Notice at any time.  This Privacy Notice is intended to comply with the privacy provisions of applicable U.S. federal law, including Regulation S-P.  You may have additional rights under other foreign or domestic laws that may apply to you.  Should you have any questions regarding the above, please feel free to call (713) 337-7980 or email info@FICfund.com.

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California Notice

This section applies to you only if you are a California resident and we collect information about you that is subject to the California Consumer Privacy Act (“CCPA”). The CCPA, and this section, does not apply to information covered by other federal and state laws, including Regulation S-P. For purposes of this section, references to “personal information” shall include “sensitive personal information,” as defined under the CCPA.

We collect and have in the preceding 12 months collected the following categories of personal information: identifiers, personal information listed in the California Customer Records statute, commercial information, professional information, Social Security number and government ID information. We use and disclose (and have done so in the preceding 12 months) investor personal information to form and operate our investment funds, including to evaluate eligibility, facilitate your investment, create and maintain investor accounts, communicate with investors, or otherwise in connection with our business activities or as described above. We only use and disclose sensitive personal information for the purposes specified in the CCPA or otherwise with your consent. We do not “sell” or “share” (as those terms are defined under the CCPA) your personal information, nor have we done so in the preceding 12 months. We also do not have actual knowledge that we sell or share personal information about individuals under 16 years of age. 

We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to facilitate your investment, resolve a dispute, enforce our agreements, or comply with legal obligations that apply to us. 

You may have the right to request (a) access to personal information that we hold about you, including details relating to the ways in which we use and disclose your information, (b) that we delete personal information that we maintain about you and (c) to correct inaccurate information that we maintain about you. You may submit a request to exercise one of these rights by emailing us at info@FICfund.com.  We will not discriminate against you for exercising any of these rights. We may need further information to verify your identity before granting any of these rights, such as an email address or government issued ID. You may designate an authorized agent to make requests on your behalf, but before accepting such a request, we will require that the agent provide proof that you have authorized them to act on your behalf, and we may need you to verify your identity with us. 
 

 

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