Last Updated: March 31, 2023
Stone Point Capital LLC and Stone Point Credit Adviser LLC consider 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 non-public 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 to 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 and sensitive 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 (including name, physical address, e-mail address, phone number, Social Security number, passport number, driver’s license information)
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
Demographic, protected classification, and association information, such as date of birth, information relating to politically exposed persons and foreign political figures
Professional Information, such as occupation, employment history, and educational information
Internet or network activity information, such as user authentication information
Commercial information, including your financial transaction information and credit worthiness
Inferences drawn from personal information (e.g., preferences, creditworthiness)
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, sex (including gender), and contents of mail, email, and text messages
SOURCES OF INFORMATION
We obtain the categories of personal information listed above from the following sources:
DISCLOSURE OF INFORMATION
We may disclose the categories of personal information described above, as needed to achieve the stated business purposes above, to:
ADDITIONAL USES OF INFORMATION
We will only process your personal information in pursuance of our legitimate interests where we have considered that 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 do not take action on “do not track” signals.
In addition to the disclosures 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 disclose or use this information for any other purpose.
In the preceding 12 months, we have neither sold personal information nor shared personal your information to a third party for cross-context behavioral advertising. We do not knowingly sell personal information of minors under the age of 16.
We do not use sensitive personal information to infer characteristics about you and only use sensitive personal information for the uses outlined above.
We retain 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. 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.
HOW WE PROTECT YOUR INFORMATION
To protect your non-public personal information, we permit access only to authorized employees who need access to that information to provide services to you or in connection with the administration of the Funds. We maintain physical, electronic, and procedural safeguards pursuant to applicable law which are designed to guard your non-public personal information. An individual limited partner’s rights under this policy extend to all forms of contact with us, including telephone, written correspondence, and electronic media, such as the Internet.
This provision supplements the information contained above and applies solely to residents of California.
Much of the personal information that we collect 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 with the scope of these exemptions or to which the CCPA’s relevant provisions do not apply.
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.
We take reasonable steps to ensure that information we hold about you is accurate and complete. However, you have the right to request that we correct any inaccurate personal information that we have about you.
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.
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 that is 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 us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. We will also require that you verify your identity directly with us or confirm with us 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.
We endeavor to respond to a verifiable consumer request within the time periods provided by the CCPA.
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 in a Fund organized under the laws of the Cayman Islands, that Fund is the data controller for the purposes of the Data Protection Act (2021 Revision) (“DPA”).
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 DPA 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 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 DPA.
For further information related to the DPA, 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 DPA to your investment in one of our Cayman Islands Funds.
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
Effective Date: April 1, 2023