Stone Point’s Privacy Policy and Practices

Last Updated and Effective as of: March 18, 2022

Stone Point Capital LLC and Stone Point Credit Adviser LLC considers privacy to be fundamental to our relationship with you. We are committed to maintaining the confidentiality, integrity, and security of your non-public personal information. Accordingly, we have developed internal policies and practices to protect the confidentiality of your non­public personal information while still meeting your needs. We are providing this policy to you so that you know what kinds of information we collect about you, how we use that information, 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 us, as a visitor or our offices, or as a prospective, current, or former investor, we collect certain non-public personal information about you. The below chart describes the categories of non-public personal information that we collect, and have collected within the past 12 months and the business purposes for which we use that personal information:

Categories of Personal Information Collected

Identifiers (e.g., name, address, email address, telephone number, date of birth, and Social Security number)

  • Operational purposes (including setting up and managing your investor accounts and transactions, detection, and prevention of fraud, and making distributions)
  • Marketing (including to communicate with you and provide you with information we believe may be of interest to you)
  • Customer service (including sending communications with you in connection with your investment)
  • Compliance with Know Your Client (KYC) and anti-money laundering (AML) laws and regulations, and 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 our employees and visitors

Other personal information (e.g., passport number, driver’s license information, bank account number, and medical information (e.g., vaccination status))

  • Operational purposes (including setting up and managing your investor accounts and transactions, detection, and prevention of fraud, and making distributions)
  • Compliance with Know Your Client (KYC) and anti-money laundering (AML) laws and regulations, and legal compliance with any other applicable laws or regulations
  • Ensuring a safe and healthy office environment for our employees and visitors

Sensitive or demographic information (e.g., gender, citizenship, country of origin/nationality, country of domicile/tax residence)

  • Operational purposes (including setting up and managing your investor accounts and transactions, detection, and prevention of fraud, and making distributions)
  • Compliance with Know Your Client (KYC) and anti-money laundering (AML) laws and regulations, and legal compliance with any other applicable laws or regulations

Commercial information (e.g., financial transaction history and creditworthiness)

  • Operational purposes (including setting up and managing your investor accounts and transactions, detection, and prevention of fraud, and making distributions)
  • Compliance with Know Your Client (KYC) and anti-money laundering (AML) laws and regulations, and legal compliance with any other applicable laws or regulations

Professional or employment related information (e.g., employment history, educational information)

  • Operational purposes (including setting up and managing your investor accounts and transactions, detection, and prevention of fraud, and making distributions)
  • Compliance with Know Your Client (KYC) and anti-money laundering (AML) laws and regulations, and legal compliance with any other applicable laws or regulations

Inferences drawn from personal information (e.g., preferences, creditworthiness)

  • Operational purposes (including setting up and managing your investor accounts and transactions, detection, and prevention of fraud, and making distributions)
  • Compliance with Know Your Client (KYC) and anti-money laundering (AML) laws and regulations, and legal compliance with any other applicable laws or regulations

We will only process your personal data in pursuance of our legitimate interests where we have considered that the processing is necessary and, on balance, our legitimate interests are not overridden by yours.  We do not collect information from you, including through cookies, on our website and do not permit third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different Web sites.  We currently are unable to respond to “do not track” signals.

SOURCES OF INFORMATION
We obtain the categories of personal information listed above from the following sources:

DISCLOSURE OF INFORMATION
We disclose the categories of personal information described above:

We 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 of a fund’s 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 we sell or transfer (or are in negotiations to sell or transfer) all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation); or (iv) when you direct us to do so.

Any third party that receives non-public personal information is required to use your information only for the purposes for which we disclose the information to them and as allowed by applicable law or regulation. Such third party is not permitted to share or use this information for any other purpose.

We do not sell your personal information.

CHANGES TO PRIVACY POLICY
This Privacy Policy went into effect, and was last revised, on the date noted at the top of this webpage.  If we make material changes to the Privacy Policy, we will post the updated Privacy Policy on this page and change the date at the top of this Privacy Policy.

California Residents
This provision supplements the information contained above and applies solely to residents of California. You have the right to request that we disclose the following information to you about our collection, disclosure, and use of your personal information over the 12 months prior to the date of your request:

You have the right to request that we delete any of your personal information that we collected and retained. We will, however, not delete your information if we need it (i) to fulfill our obligations to you, (ii) to comply with legal and regulatory obligations, (iii) to protect the security or functionality of our operations, or (iv) for certain other reasons in accordance with applicable law or regulation.

To exercise the rights described above, you may submit a verifiable consumer request to us by either e-mailing us at SPCprivacyrequests@stonepoint.com or calling us at 1 (833)–786-7682. The request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information and it must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will not deny services, charge different prices, offer a different quality of service, or otherwise discriminate against you for exercising these rights.

Cayman Island Fund Investors
Where you have invested into a Fund organized under the laws of the Cayman Islands, that Fund is the data controller for the purposes of the Data Protection Law, 2017 (“DPL”).

The personal data that you provide for the purposes of the subscription into the Fund registered in the Cayman Islands shall be processed in accordance with the provisions of the DPL and is used in connection with the discharge of legal and regulatory obligations. We will only use your personal data in pursuance of our legitimate interests where we have considered that the processing is necessary and, on balance, our legitimate interests are not overridden by your legitimate interests, rights or freedoms.

You have certain data protection rights, including the right to:

The Fund will not take decisions producing legal effects concerning you based solely on automated processing of your personal data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the applicable requirements under the DPL.

 

For further information related to the DPL, or for further details in relation to complaints, please see www.ombudsman.ky. Please contact us at SPCprivacyrequests@stonepoint.com or at 1 (833)–786-7682 should you have a query related to the application of the DPL to your investment in one of our Cayman Islands Funds.

 

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To the extent you have any questions about our privacy practices, please contact:

Chief Compliance Officer, 20 Horseneck Lane, Greenwich, CT 06830
SPCprivacyrequests@stonepoint.com or 1 (833)–786-7682