Privacy Policy

Website Privacy Policy

Last Updated June 2023

Welcome to https://www.civitascapital.com/ (the “Site”), which is owned and operated by the Civitas Capital Group family of companies, including Civitas Capital Management, LLC, its subsidiaries and affiliates (together, “Civitas,” “we” or “us”). We have developed this website privacy policy (“Website Privacy Policy”) to provide you with information about the types of information we may collect from you when you visit our Site or otherwise contact us. We take precaution to maintain the privacy of personal information concerning our current clients and prospective investors. These precautions include the adoption of certain procedures designed to maintain and secure such client’s nonpublic personal information from inappropriate disclosure to third parties.

Please note that if you are an investor in our funds, you should review the privacy notice(s) provided with your investment documents for additional information on our data collection and use.

If you are a California resident and your personal information is subject to the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations, and as amended by the California Privacy Rights Act, and as further amended from time to time, “CCPA”), please review the Additional Information for California Residents section below for additional disclosures, our Notice at Collection, a description of your rights under the CCPA.

Information We Collect and How We Collect It

While using our Site or when you otherwise interact with us, we may collect certain information from or about you, including “Personal Information.” When we use the term “Personal Information” we mean information that can help us directly or indirectly identify you, such as your name, email address, home address, telephone number, Internet Protocol (“IP”) address, or other online identifiers, among other information. We may collect some of this information directly from you, automatically through your use of the Site, and from other sources.

Information Provided by You

We may collect personal information when you: (i) register on our Site; (ii) contact us through available forms on the Site, via email or phone; (iii) subscribe to our publications or request marketing communications; (iv) provide us with feedback; and (v) submit an application for employment via a website linked from our Site.

Depending on how you interact with us, we may collect certain categories of personal information from or about you including:

Identifiers such as, your name, address, date of birth, email address, or other similar identifiers.
Financial information, including, for example, your signature or bank account or other financial information.
Demographic information, including, your sex or gender, national origin, or marital status.
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies. For example, funds invested in the prior year, investments considered, or sources of wealth.
Audio, electronic, visual, or similar information.
Internet or other electronic network activity information, including, for example, information regarding your interaction with our website or use of certain online tools.
Professional or employment-related information, including your current or former employer or your current professional title.
Inferences drawn from any of the information identified above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. For example, information on your potential interest in investing in new funds or investment vehicles based on various information.
Sensitive personal information such as your passport number; driver’s license; Social Security Number; state identification card; log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin, religion, philosophical beliefs; and precise geolocation.

Information Collected Automatically

When you visit our Site or interact with us through other online media and advertisements, information about your visit and/or interaction is automatically logged though the use of various tracking tools like browser cookies and web beacons (collectively, “cookies”). Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and transferred to your device. We generally use cookies to collect information in order to improve our services for you. We may automatically collect Personal Information through our Site and these tools, including the following:

Log Data – This includes information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s IP address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, and other statistics. When you access the Site by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, your location information, and other statistics.
Website Browsing Data – This includes information gathered while you browse our Site, including technical, usage, and navigational data that shows what pages you have visited and how long various features are used.
Device Information – Such as information about the device you use to access our Site, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
We may use third-party web analytics services on the Site, including Google Analytics and Meta. We use Google Analytics to help us understand how people are using our Site. To find out more about how Google Analytics collects and processes data, please click here. Google Analytics has its own cookies that it uses to track and aggregate this information. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provides information on how to accept cookies, disable cookies, or to notify you when receiving a new cookie. You can also control cookies (i) through most browsers by changing your cookie settings, which are typically found in the “options” or “preferences” menu of your browser, and (ii) through various third-party tools, which can be found here.

Please note that if you do not accept cookies, you may not be able to use some features of our Site, and we recommend that you leave them turned on.

Information from Other Sources

We may collect personal information about you directly from you and/or your intermediaries through sources such as:

Account applications, subscription agreements, and other forms or related documentation.
Written, electronic, or verbal correspondence with us or our service providers.
Investor transactions.
From information captured on applicable websites.

In addition, we may collect personal information from different sources, such as:

Our affiliates, our service providers, or our affiliates’ service providers.
Public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities.
From credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

Purpose for Collecting and Using Personal Information

We may collect your personal information for the following purposes, including:

Performing services on behalf of a fund or investment vehicle, including, for example, maintaining or servicing accounts, providing customer service, processing transactions, verifying information, processing payments, or providing similar services on behalf of a fund or investment vehicle.
Communicating with you.
Performing our contractual obligations to a subscriber to a fund or investment vehicle, including, processing initial subscriptions and providing updates on a fund’s or investment vehicle’s performance and other operational matters.
Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks.
Enabling or effecting commercial transactions, including, using your bank account details to remit funds and process distributions.
Where permitted by applicable law, providing you with marketing or promotional materials.
Administering and improving our Site and services.
Complying with applicable laws, including information collection and retention requirements under certain securities laws.
Internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

How We May Disclose Information

We may disclose all of the personal information that we collect in the following ways:

To service providers, such as administrators, banks, auditors, law firms, consultants and placement agents.
Entities that provide technological services and functionality such as our operating systems and platforms, and internet services.
Advertising partners and data analytics providers.
At your request or direction or with your consent.
As otherwise permitted or required by law or regulation, including, but not limited to, governmental organizations and self-regulatory organizations.

Additionally, we may share personal information in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Security of Personal Information

We will take reasonable steps to use security measures appropriate to the nature of the information to protect personal information against unauthorized access, exfiltration, acquisition, theft, or disclosure. Given the nature of information security, there is no guarantee that such safeguards will always be successful.

How Long We Keep Information

How long we keep your personal information will vary depending on the type of personal information and our reasons for collecting it. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal information). In general, we will retain your personal information for as long as we require it to perform our contractual rights and obligations or for periods required by our legal and regulatory obligations.

Where We Process Your Information

We are based in the U.S. When you provide personal information to us from outside of the U.S., please be aware that we will receive and process it in the U.S. and that U.S. data protection laws may be different from those of your country of residence.

Children’s Information

This Site is not intended for use by those under 13. We do not knowingly solicit or collect personal information on the website from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personal information to us, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).

Links to External Websites

Our Site may contain links to third party websites. Any access to and use of such third-party websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third-party websites.

Your Rights

You may have certain rights with regard to your personal information, including: access your personal information; rectify the information we hold about you; erase your personal information (in certain circumstances); restrict our use of your personal information (in certain circumstances); object to our use of your personal information; receive your personal information in a usable electronic format and transmit it to a third-party (also known as the right of data portability); withdraw any consent you have given to uses of your personal information and lodge a complaint with your local data protection authority. If you wish to exercise any of these rights, please contact us using the information below in Contact for More Information. Please use the subject line “Data Rights Request” if emailing.

Additional Information for California Residents & Notice at Collection

As a business, California’s privacy law, the CCPA, requires us to provide additional disclosures with regard to our collection, use, disclosure, and sharing of personal information and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.

Notice at Collection and Use of Personal Information

Information We Collect

Depending on how you interact with us, we may collect the categories of personal information listed above in the section Information We Collect and How We Collect It.

Purpose for Collection and Use of Information

We may collect and use personal information from you for the purposes described above in the section Purpose for Collecting and Using Personal Information.

Sale or Sharing of Personal Information

We do not sell or share your personal information (as such terms are defined under the CCPA).

How Long We Keep Information

For more information about our privacy practices, please review our entire Privacy Policy, which is available starting at the top of this webpage.

Our Collection, Use, and Disclosure, of Personal Information and Sensitive Personal Information

What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information

In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information from all or some of the categories of sources listed above in the section, Information We Collect and How We Collect It. We may collect all or a few of these categories of personal information for the business or commercial purposes identified in the section, Purpose for Collecting and Using Personal Information.

Disclosure of Personal Information

We do not sell or share your personal information as defined under the CCPA (as those terms are defined under the CCPA). We do not knowingly sell or share the personal information of California residents under 16 years old.

In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as described in the following chart:

Category of Personal Information	Category of Third Party
Identifiers	Counterparties and intermediaries (e.g., broker-dealers) in connection with investments and transactions or for operational purposes Third parties as needed to complete a transaction, including financial institutions or advisors, entities that assist with fraud prevention, custodians or lenders to or creditors of a fund Professional services organizations, such as auditors. Operating systems and platforms
Additional information subject to Cal. Civ. Code § 1798.80(e)
Characteristics of protected classifications under certain federal or state laws	Counterparties and intermediaries (e.g., broker-dealers) in connection with investments and transactions or for operational purposes Third parties as needed to complete a transaction, including financial institutions or advisors, entities that assist with fraud prevention, custodians or lenders to or creditors of a fund Professional services organizations, such as auditors
Commercial Information	Counterparties and intermediaries (e.g., broker-dealers) in connection with investments and transactions or for operational purposes Third parties as needed to complete a transaction, including financial institutions or advisors, entities that assist with fraud prevention, custodians or lenders to or creditors of a fund Our affiliates Professional services organizations, such as auditors
Internet or Electronic Network Activity Information	Internet service providers Advertising partners

In addition, we may disclose, and, in the preceding 12 months, may have disclosed all of the categories of personal information identified in Information We Collect and How We Collect It. to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted or required by law. We may disclose personal information to all such third parties above to comply with our legal obligations or for the business and commercial purposes identified in Purpose for Collecting and Using Personal Information. Additionally, we may disclose your personal information to third parties upon your request, at your direction or with your consent.

We may disclose or make available your personal information with our service providers such as our administrator, IT providers, or CRM provider, consultants, email archiving services, and other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in. or as otherwise permitted by, the CCPA.

Use and Disclosure of Sensitive Personal Information

As noted above in Information We Collect and How We Collect It, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.

California Residents’ Rights under the CCPA

If your personal information is subject to the CCPA, you may have certain rights concerning your personal information, subject to applicable exemptions and limitations, including the below listed rights.

Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
Not be discriminated against because you exercise any of your rights under the CCPA.
Request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”).
Request that we correct inaccurate personal information (“Request to Correct”).
Request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”).
Opt-out of the “sale” of your personal information if a business sells your personal information to third parties (we do not).
Opt-out of the “sharing” of your personal information if a business shares your personal information with third parties (we do not).
Request that we limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.

How to Submit a Request under the CCPA

If your personal information is subject to the CCPA, you may submit Requests to Know, Requests to Correct or Requests to Delete (“Consumer Rights Request”) through the following methods: by telephone at 800-212-1329, or through our Site at the following link: https://www.civitascapital.com/contact-us/, via email to [email protected] or by mail to:

Civitas Capital Group
1722 Routh Street, Suite 800
Dallas, Texas 75201

We are only required to respond to verifiable Consumer Rights Requests made by you or your authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.

You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the provided methods. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

Changes to this Privacy Policy

We reserve the right to change this Website Privacy Policy from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the bottom of this Website Privacy Policy. However, if we make material changes to this Website Privacy Policy, we will notify you by means of a prominent notice on the Site prior to the change becoming effective. Please review this Website Privacy Policy periodically for updates.

Contact for More Information

This Website Privacy Policy is available in alternative formats upon request. If you have any questions or concerns about this Website Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or to request this Privacy Policy in an alternative format, please contact Civitas at (214) 572-2300.