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FrontRange Capital Advisers, LLC Privacy Policy

Commitment to Privacy

FrontRange Capital Advisers, LLC, its advisory affiliates, and their related persons (collectively, “FrontRange,” “we,” “us” or “our”) endeavor to responsibly handle personal information that we collect or otherwise process regarding our investors (including, for the purposes hereof, a potential investor or former investor) and individuals who visit our website (the “Website”) or otherwise communicate or engage with us (“you” or “your”).

Our intention with this privacy policy (this “Privacy Policy”) is to provide you with clear, transparent, and easily understandable information about how FrontRange uses your personal information and certain rights you may have relating to such use. We reserve the right to change this Privacy Policy at any time as circumstances or requirements change. All updates are effective immediately when we post them here and apply on a go-forward basis. For this reason, we encourage you to review this Privacy Policy whenever you visit the Website so you are aware of any updates, as they will be applicable to you and your personal information. Your access and use of the Services is subject to this Privacy Policy.

Collection of Personal Information

The types of personal information collected by or on behalf of FrontRange about you varies based on FrontRange’s interactions with you (for example, whether you are an investor or another person visiting the Website).

Personal information collected by or on behalf of FrontRange about people visiting the Website is obtained directly from you or certain third parties. For purposes of this Privacy Policy, “personal information” means any information that identifies, could be used to identify, or is otherwise related to a person, device, or household. The personal information we collect about you in the course of your interaction and correspondence with us via the Website includes, but is not limited to, the following:

  • IP address and other online identifiers/web beacons;
  • details of your online browsing activities on the Website, including, but not limited to, the full Uniform Resource Locators (URL), clickstream to, through and from the site (including, but not limited to, date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
  • your browser type and version, relevant plug-ins, operating system, and platform;
  • your time zone settings; and
  • in relation to any personal account you create on the Website:
    • user names, passwords, and other log-in information;
    • your account settings, including, but not limited to, any default preferences;
    • a log of your browsing activities during your visit to the Website; and
    • any preferences we have observed, such as the types of products that interest you, or the areas of the Website that you visit.

Please see the section entitled “Cookies” below for a discussion of our use of cookies on the Website.

The Website is not intended for children and we do not knowingly collect data relating to children (including any minors under the age of 16).

Do Not Track 

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.

Data Security

We acknowledge that the personal information you provide may be confidential.  Unfortunately, the storage and transmission of electronic information is not completely secure. We cannot guarantee the security of information stored on our or our vendors’ servers or transmitted via email or through the Website; you transmit personal information to us at your own risk. In addition, links on the Website may take you to third-party websites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.

Cookies

What are Cookies?

Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit a website. A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e., how long it will remain on your device) and a value, which is usually a randomly generated unique number.

How we use Cookies

When you visit the Website, one or more “cookies” are generated and deployed with your consent (if required) using Google Analytics, Piwik, WordPress Stats, or similar programs. We use cookies to make the Website easier to use and to better tailor our web presence and products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on the Website. We may also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our web properties and to help us improve web structure and content.

Two types of cookies may be used on the Website – “session cookies” and “persistent cookies.” Session cookies are temporary cookies that remain on your device until you leave the Website. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings).

Our Website uses “performance” and “analytical” cookies, that help us understand how visitors interact with our web properties by providing information about the areas visited, the time spent on the Website, and any issues encountered, such as error messages. They help us improve the performance of the Website, alert of any concerns and more. Squarespace may also use some “necessary cookies,” because they allow visitors to navigate and use key features on the Website.

Your choices with respect to Cookies

If you do not agree to our use of cookies, you should set your browser settings accordingly or not use the Website. Most internet browsers are initially set up to automatically accept cookies. You can change the settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies.

Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.

If you disable the cookies that we use, this may impact your experience while using the Website. For example, you may not be able to visit certain areas of the Website.

If you use different devices to view and access the Website (e.g., your computer, smartphone, tablet), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.

Additional Information for Individuals Whose Personal Data is Subject to the GDPR or the UK GDPR

Residents of the European Economic Area (“EEA”) and the United Kingdom (“UK” and such residents of either, “EEA/UK Residents”) have certain rights with respect to their personal data[1] pursuant to the General Data Protection Regulation (EU) 2016/679 (“GDPR”) or the UK General Data Protection Regulation (i.e., the GDPR as implemented into UK law, the “UK GDPR”), as applicable and as further described in this section. If you are an EEA/UK Resident and do not agree with FrontRange’s use of your personal data as set forth in this Privacy Policy, you should not submit your personal data to FrontRange. However, if you do not submit certain personal data to FrontRange, or if you exercise your rights to prevent FrontRange from using such personal data, you should be aware that FrontRange may not be able to do business with you.

For the purposes of applicable data privacy legislation, FrontRange is a “controller” of EEA/UK Residents’ personal data. We transfer, use, store and/or otherwise process your personal data outside of the EEA or the UK, primarily in the U.S. (and may do so in certain other countries), and the laws of the U.S. and certain other destination countries may not offer the same standard of protection for personal data as countries within the EEA or UK. EEA/UK Residents’ personal data also may be processed by staff operating outside the EEA or UK who work for us or for one of our vendors (for example, those who supply support services to us).

In cases of cross-border transfers to countries outside of the EEA or UK, as applicable, if your personal data will be processed in a country with laws that may not be equivalent to, or as protective as, the laws of your home country, FrontRange will take appropriate steps, in accordance with applicable laws, to request or maintain an adequate level of protection and security for your personal data. For additional information regarding such steps, please contact us using the details set forth at the end of this Privacy Policy.

  1. Our bases for collecting and using personal data

We are entitled to use your personal data in the ways set out in this Privacy Policy on the following bases:

  • the use of personal data is necessary for the performance of a contract with you for provision of our products and/or services (including, for example, fund subscription agreements and fund limited partnership agreements) or to take steps at your request prior to entering into such a contract;
  • we have legal obligations that we are required to discharge (including, for example, legal obligations set forth in fund limited partnership agreements, investment advisory agreements and other operative documents);
  • the use of your personal data is necessary for our legitimate interests (including, for example, in marketing to prospective investors for the fund in which you are invested, successor funds thereto or other FrontRange-sponsored funds);
  • you have consented to such use; and/or
  • to establish, exercise or defend our legal rights for the purposes of legal proceedings.

We do not expect to process “sensitive” or “special” categories of personal data under the GDPR or UK GDPR;[2] however, if we were to process such personal data, we would do so only where we have asked for your explicit consent, or otherwise where  necessary for the establishment, exercise or defense of legal claims, or as otherwise may be permitted under applicable laws.

Provision of certain of your personal data is a legal and contractual requirement to becoming an investor in any FrontRange-sponsored fund or other pooled vehicle. If you choose not to provide such personal data, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you. If you choose to provide your consent with respect to certain processing of your personal data, you can withdraw such consent at any time by contacting us.

  1. Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

  • request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully;
  • request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected;
  • object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also may have the right to object where we are processing your personal data for direct marketing purposes;
  • request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see above);
  • request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and/or
  • request the transfer of your personal data to another party in a machine-readable, commonly used and structured format.

If you want to exercise any of these rights, please contact us using the details set forth at the end of this Privacy Policy. The various rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your personal data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.

We will respond to your request within one month of receipt of your request. In some cases, we may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.

  1. Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your working relationship with us.

  1. Fees

You will not have to pay a fee to access your personal data (or to exercise any of the other above-listed rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the relevant information. Alternatively, we may refuse to comply with the request in such circumstances.

  1. What we may need from you

To access your personal data (or to exercise any of the other above-listed rights), we may need to request specific information from you to help us confirm your identity and ensure your right to access the personal data (or to exercise any of your other above-listed rights). This is another appropriate security measure designed to ensure that personal data is not disclosed to any person who is not entitled to receive it.

  1. Right to complain

If you wish to request further information about any of the above-listed rights, or if you are unhappy with how we have handled your personal data, please contact us using the details set forth at the end of this Privacy Policy. If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with the GDPR, UK GDPR or other applicable data privacy legislation, you can make a complaint to the supervisory authority in your country. For example, in the UK you should contact the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/ or 0303 123 1113.

Additional Information for Individuals Whose Personal Information is Subject to the CCPA/CPRA

Residents of the state of California have certain rights with respect to their personal information[3] pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”) and as further described in this section. Please note that the rights under the CCPA and the CPRA do not apply to personal information collected, processed, sold or disclosed subject to the Gramm-Leach-Bliley Act (Public Law 106-102), the Fair Credit Reporting Act (12 CFR 1022) and/or the California Financial Information Privacy Act.

Under certain circumstances, under the CCPA and the CPRA you may have the right to:

  • request that we disclose, free of charge, the categories and specific pieces of personal information we collect about you (and, if applicable, sell or otherwise disclose to a third party and the categories of such third parties), the sources from which such personal information was collected, and the business purpose for collecting, selling or disclosing such personal information;
  • opt out of the sale of your personal information. As noted above, we do not currently sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising; and
  • request that we delete the personal information we have collected about you; and
  • request that we correct any inaccurate personal information we have collected about you.

We will not discriminate against any California resident who exercises the rights set forth in this section.

You have the right to appoint an authorized agent to exercise these rights on your behalf. If you want to exercise any of these rights, or have your authorized agent exercise any of these rights on your behalf, then please contact us using the details set forth at the end of this Privacy Policy. To exercise any of these rights, we may need to request specific information from you or your authorized agent to help us confirm your identity and ensure your right to exercise these rights.

These rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you are currently an investor in one of our funds and you request that we delete the personal information we have collected about you, the CCPA and the CPRA permit us to deny such request and retain your personal information to the extent necessary to manage the applicable fund and our business relationship with you in connection with that fund.

For consumers with disabilities who need to access this Privacy Policy in an alternative format, please contact us using the details set forth at the end of this Privacy Policy.

Contact Us

Should you have any questions or concerns relating to this Privacy Policy or the processing of personal information we hold about you, please contact Brian Roland – Managing Director, Co-Head of Capital Markets – via email at investors@frontrangecap.com or via phone at 720-598-7803, or Alli Wells – Associate, Capital Markets via email at  investors@frontrangecap.com  or via phone at 720-758-7900, with any questions or comments regarding this policy, or any related matter.

Footnotes

[1] For the purposes of this section, “personal data” has the meaning given to such term in the GDPR or UK GDPR, as applicable.

[2] “Special” or “sensitive” categories of personal data include, among other things, data concerning your health, revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or concerning your sexual orientation.

[3] For the purposes of this section, “personal information” has the meaning given to such term in the CCPA and the CPRA.