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Privacy Notice

As required under the privacy notice and disclosure regulations promulgated by the U.S. Securities and Exchange Commission under Regulation S-P, the Gramm-Leach-Bliley Act, and other applicable data privacy laws and regulations, we are providing this notice to our investors in order to inform you of our privacy policies and practices with respect to your personal information, and, in the case of institutions, that of your beneficial owners, employees, or consultants (“personal data”). By becoming a Limited Partner, you are permitting us to collect and process the personal data that you provide to us in the Subscription Agreement, or that you otherwise provide to us, in accordance with this Privacy Notice in connection with our providing a financial product or service to you. Your use of other services or products offered by us may be subject to other terms and conditions. For purposes of this Privacy Notice, processing means and includes any operation or set of operations that are performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, erasure or destruction. Unless otherwise specifically provided, all capitalized terms herein shall have the meanings ascribed to such terms in the Subscription Agreement to which it is attached.

Information Collection and Use

In connection with the formation and ongoing activities of our private investment funds, we collect and maintain certain personal data about our investors, such as name, address, phone number, email address, tax identification number, financial account information, commercial information, and/or professional and employment information, from the following sources:

  1. information we receive from you on subscription agreements, investor questionnaires, other forms, or that you otherwise submit to us or contracts that you enter into with us;
  2. information about your transactions with us, our affiliates,1 and nonaffiliated third parties;2 and
  3. information obtained from meetings and telephone conversations with you.

We collect and process such personal data in connection with the following:

  1. the acceptance of your subscription for Partnership Interests;
  2. the issuance of Partnership Interests to you;
  3. the processing and management of the Partnership Interests, including processing payments and distributions, accounting, auditing, reporting to you, as well as reporting to other investors, third party service providers and appropriate government entities, including tax authorities and other governmental and regulatory agencies;
  4. acting in compliance with our legal obligations, rights, and interests and with the terms of the Partnership Agreement, including with respect to anti-money laundering and sanctions checks;
  5. sending marketing or promotional communications relating to our business, products or services to you; and
  6. preventing fraud, responding to judicial process and subpoenas, and complying with federal, state, and local laws, as well as other applicable laws and regulatory requirements.

Information Sharing and Disclosure

We may disclose such personal data to our affiliates and nonaffiliated third parties as permitted by law and in accordance with the agreements governing your investment in our funds, including:

  1. other service providers to our investment funds, such as accounting, legal, and tax preparation services;
  2. transfer agents, portfolio companies, brokerage firms, and the like in connection with distributions to our limited partners;
  3. other third-party service providers we may engage to provide services such as marketing, advertising, communications, customer service, infrastructure and information technology services, and others as appropriate; and
  4. for purposes of preventing fraud, responding to judicial process and subpoenas, and complying with federal, state, and local laws, as well as other applicable laws and regulatory requirements.

If one of the foregoing service providers needs to access personal data to perform services on our and your behalf, they are only authorized to collect, use, disclose, and store the personal data as described in our contract with them, including requirements to maintain reasonable security procedures.

We do not sell your personal data to third parties, and we do not sell, rent, or share your personal data with third parties for such third parties’ direct marketing.

Security

To protect your personal data from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We restrict access to personal data to those employees, affiliates, and agents who have a need to know the information to enable us to provide our services to you. We maintain physical, electronic, and procedural safeguards reasonably designed to protect the personal data while it is within our control.

Retention and Disposal

The personal data may be stored in our technology systems or those of our service providers, or in paper files. We will delete the personal data ten (10) years after liquidation of the applicable investment fund, or when you withdraw your consent or request erasure, to the extent that we are not legally required or otherwise permitted to continue to hold such data. We may retain such personal data for an additional period to the extent deletion would require us to overwrite our automated disaster recovery backup systems or to the extent we deem it necessary to assert or defend legal claims during any relevant retention period.

How to Access and Control Your Personal Information

Where appropriate and where required by applicable law, we will provide individuals with the following rights with respect to such individual’s personal data: (1) the right to access such personal data, (2) the right to correct or erase such personal data, (3) the right to restrict the processing of such personal data, (4) the right to object to the processing of such personal data, (5) the right to portability of such personal data, (6) the right to not be subject to discrimination for exercising your rights with respect to your personal data, and (7) the right to lodge a complaint with your local data protection authorities regarding the processing of such personal data.

You can exercise your rights with respect to your personal data by contacting privacy@jamestownlp.com. To the extent we are processing the personal data based on your consent, you may withdraw such consent at any time, provided that such personal data is not required in connection with your investment in the Partnership Interests. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link in such email communications.

If you do not wish to provide us with the personal data as required by the Subscription Documents, Partnership Agreement, and applicable legal obligations and requirements, we will not be able to accept you as a Limited Partner in the Fund. If you are an existing investor and you object to the further processing of the already shared personal data or request erasure of such personal data, we may be required to redeem your Partnership Interests or to hold in escrow all distributions that would otherwise be made to you.

European Economic Area (EEA) Data Subjects

If you are an individual in the European Economic Area (EEA), we collect and process your personal data only where we have legal basis for doing so under applicable European Union (EU) laws. This means we collect and use your personal data only where: (i) we need to in connection with your investment in our private investment funds; (ii) it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, marketing and promotions, and to protect our legal rights and interests; (iii) you give us consent to do so for a specific purpose; or (iv) we need to process your personal data to comply with a legal obligation. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third-party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer being a Limited Partner in the private investment fund.

International Data Transfers

Jamestown transfers certain EU personal information to the United States and Colombia. For such transfers, Jamestown relies on your explicit consent, our legitimate interest in performing a contract between us, or standard contractual clauses.

Changes to This Policy

We may periodically modify this Privacy Notice and will promptly provide such updates to you in a manner consistent with other communications with you, for example, via electronic means such as making it available to you through the investor portal. By communicating and conducting transactions with us via the investor portal, you acknowledge and agree to receive the privacy notice updates by this method as a necessary part of obtaining our products and service. We will keep prior versions of this notice which you may request via email to privacy@jamestownlp.com.

Contact Us

Your information is controlled by Jamestown, L.P. If you have any questions about this Privacy Notice, please direct your inquiry to Jamestown, L.P., 675 Ponce de Leon Avenue NE, 7th Floor, Atlanta, Georgia, Attention: General Counsel, or via email to privacy@jamestownlp.com. If you are a resident of the European Economic Area, please contact our EU Representative, Jamestown US-Immobilien GmbH, at Marienburger Str. 17, 50968, Köln-Marienburg, Germany, or via email to privacy@jamestown.de.

1 Affiliates are companies related by common ownership or control; they can be financial and non-financial companies.
2 Non-affiliates are companies not related by common ownership or control; they can be financial and non-financial companies.