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Shamrock Capital Privacy Policy

Shamrock Capital Advisors, LLC (“Shamrock”, “we”, “us”, or “our”) is committed to protecting the privacy of personal information (“PI”) of identifiable individuals who visit https://shamrockcap.com/ (the “Website” or “Site”) and inquire about or use services associated with our business available through our Site (the “Service/s”), or express interest in our business. The privacy of your PI is important to us at Shamrock. This Privacy Policy discloses the privacy practices for Shamrock and for its Site, and localized versions of that site, including the type of PI collected and tracked, how the information is used, and with whom the information is shared.

This Privacy Policy explains our PI policies and practices. It includes, but is not limited to, explanations of the types of PI we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, your rights regarding your PI, and the way to contact us to exercise those rights.

Amendments to this Privacy Policy will be posted to the Site and/or Services and will be effective when posted. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendments. By visiting our Site or using our Services you agree that PI will be handed as described in this Policy.

Quick Reference Guide:

1. Types of Information We Collect
2. Purposes for Collecting Your Personal Information
3. Retention & End-of-Life of Personal Information
4. Lawful Basis
5. Receiving, Disclosing & Sharing Your PI
6. Protection of Personal Information
7. Restricted Use Regarding Minors
8. Transfers of PI
9. Our Site and Use of Cookies
10. Data Subject Rights
    • Your EU Data Subject Rights
    • Information Rights for California Residents
    • Non-Discrimination for Exercising your PI Rights
11. Exercising Your Rights
    • Verifying Your Identity
    • Authorized Agent
    • Accessibility Information
    • Changes to this Privacy Notice
    • Contacting Us

1. Types Of Information We Collect

This section explains the PI that may be collected when using our Services, and the other information we may receive from other sources. Various laws and regulations use different terms and definitions for information about individuals that is personal and should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories. At Shamrock, we have chosen to adopt a broad approach to what information must be protected and kept as private as possible. In this notice, “Personal Information” (PI) refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household. Examples of types of information we collect and use are listed below:

Category of Information Collected	Examples
A. Identifiers.	A real name, alias, postal address, email address, account name or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, telephone number, education, employment, employment history, or other financial information,. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, national origin or citizenship.
D. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
E. Professional or employment-related information.	Current or past job history.

Sensitive Personal Information:

Subject to the relevant jurisdictional regulatory requirements, Shamrock may process sensitive personal information. Unless we request it, we ask that you not send us, or disclose, any sensitive personal information. To the extent you have provided it to us, Shamrock may process:

• Information related to racial or ethnic origin or other demographic information to open and manage your account, facilitate financial transactions related to your account, and carry out ongoing administrative tasks, such as reporting as well as other processes and communication required to operate the business in accordance with the agreements and other applicable documentation.
• A social security, driver’s license, state identification card, or passport number to open and manage your account, facilitate financial transactions related to your account, and carry out ongoing administrative tasks, such as reporting as well as other processes and communication required to operate the business in accordance with the agreements and other applicable documentation, as well as to verify your identity when you communicate with us and to secure your personal information. In each case, we may also use such information to exercise our legal rights as provided to us by applicable law and where it is in our interests and necessary to do so, for example, to fulfill our obligations under any applicable agreement, to detect, prevent, and respond to fraud claims, intellectual property infringement claims, or violations of law or misuse of our information or our Site.

2. Purposes For Collecting Your Personal Information

You may provide your PI to Shamrock in order to fulfill a Service. You are then entering a business relationship with Shamrock and are agreeing to the use of that data by Shamrock and its applicable affiliated companies, as stated in this Privacy Notice. Shamrock does not sell personal information or share personal information for the purposes of cross-context behavioral advertising and has not done so within the past twelve (12) months. Additionally, Shamrock will only use and disclose Sensitive Personal Information for a purpose for which it was originally collected.

We request PI for a variety of purposes throughout your interaction with Shamrock, including:

• Identification and Authentication: We may use your information to verify your identity when you communicate with us and to secure your personal information.
• Improving our Website: We analyze information about how you use our Website to provide an improved experience for all of our Website users. This helps us understand any issues with our Website and improve them.
• Providing Services: We may use your personal information to open and manage your account, facilitate financial transactions related to your account, and carry out ongoing administrative tasks, such as reporting as well as other processes and communication required to operate the business in accordance with the agreements and other applicable documentation.
• Communicating with You or Your Designated Contacts: We may use your personal information when we communicate with you—for example if you contact us with questions. We also may contact you to share information about our Services including investment research and provide marketing communications.
• Fulfilling our Legal and Regulatory Obligations and Exercising our Rights: We may use your personal information to exercise our legal rights as provided to us by applicable law and where it is in our interests and necessary to do so, for example, to fulfill our obligations under any applicable agreement, to detect, prevent, and respond to fraud claims, intellectual property infringement claims, or violations of law or misuse of our information or our Website.

A failure to provide the PI requested to fulfill the purposes described in this Privacy Policy may result in Shamrock being unable to provide the services in connection with the terms of your subscription agreement.

3. Retention & End-of-Life of Personal Information

The length of time that we hold your personal information will vary. The retention period will be determined by the following criteria:

• The purpose for which we are using your Personal Information – we will need to keep the data for as long as is necessary for that purpose; and
• Legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Information.

4. Lawful Basis

Shamrock has a need to process PI for the purposes set out in this privacy policy as a matter of contractual necessity under or in connection with applicable agreements, and in the legitimate interests of Shamrock to operate its business. From time to time, Shamrock may need to process the PI on other legal bases, including: to comply with a legal obligation; if it is necessary to protect the vital interests of an investor or other data subjects; or if it is necessary for a task carried out in the public interest. For the purposes listed above, Shamrock is relying on performance of a contract necessity and legitimate interests.

5. Receiving, Disclosing & Sharing Your PI

Your PI may be combined with information we receive from other sources, or it may be provided to other organizations we work with. This section details that sharing of your PI.

1. Receiving PI from Third Parties

We may receive information about you from other sources and combine that information with the PI we collect directly from you. For example, we may receive payment information from the organization you use to pay us in order to correct our records. Additionally, to promote protection of your identity, we also may collect credit or identity information which we use to help prevent and detect fraud.

2. Sharing PI with Third Parties

We will not sell your PI. If we share your PI with third parties performing services for us, or acting on our behalf, we will not allow them to use your information for other purposes, and we will contractually require them to protect your information.

We may share your PI with our affiliates, business partners, and other third parties. We may do so for the purposes of operating our business, delivering and improving the Services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business.

We may disclose your Personal Information to third parties to the extent necessary for the stated business purposes, including but not limited to:

• Within Shamrock and our affiliates and subsidiaries for data processing or storage purposes;

• With business partners, service providers and suppliers to provide Services and help facilitate transactions (including processing orders, event registrations, data storage, infrastructure and IT service providers, marketing communications, customer support, external auditors, and professional advisors (such as accountants, lawyers or other consultants));

• To a third party in connection with the sale of all or part of our business, a sale or transfer of assets, or if we are otherwise involved in a merger, restructuring or business transfer, provided that the receiving party agrees to treat your personal data in a manner consistent with this Privacy Policy; or

• In response to a request from law enforcement, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements.

In the past twelve months we have disclosed the following categories of your personal information: Identifiers, Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), Protected classification characteristics under California or federal law, Commercial information, Internet or other Similar network activity, and Professional or employment-related information. Where we do disclose your Personal Information, we will ensure that appropriate measures are in place to safeguard that Personal Information.

6. Protection of Personal Information

We maintain physical, electronic, and procedural security measures that comply with applicable legal and regulatory standards to safeguard your PI. Access to such information is restricted to those employees who have a legitimate business need to access that information. We follow generally accepted standards to protect the PI you submit to us, whether that information is in transit or at rest. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

7. Restricted Use Regarding Minors

This Site is not intended or designed to be used by children under the age of 13. We do not collect Personal Information (or PII under COPPA) from any person we know to be under the age of 13 and instruct children under 13 not to send us any information.

8. Transfers of PI

Your PI may be transferred, processed and/or stored in a country other than the one in which your PI is collected. When transferring your PI to the US or other countries, we have implemented procedures to ensure that appropriate safeguards are in place to protect the PI regardless of where it is being transferred to.

In addition to disclosing PI amongst themselves, Shamrock may disclose PI, where permitted by law, to other service providers, prospective or current investors in applicable funds, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfill the purposes described in this Privacy Notice. In addition, Shamrock may share PI with regulatory bodies having competent jurisdiction over them, as well as with tax authorities, auditors and tax advisors (where necessary or required by law, rule or regulation).

Shamrock may transfer PI to a non-equivalent country (a country or territory other than (i) a member state of the EEA; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU law to ensure an adequate level of protection for PI), in order to fulfill the purposes described in this Privacy Notice and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer agreements, and to implement requested pre-contractual measures.

In each case, these countries may not be regarded as providing the same level of protection for your information as your country of residence, or where applicable, the Cayman Islands. For a full list of countries covered by an EEA adequacy decision, see this webpage.

In order to provide additional protection for your information, in certain circumstances, we have put in place appropriate safeguards, such as standard contractual clauses for transfers of data to countries not considered adequate by the relevant data protection regulator. Depending on the laws applicable to your personal information, you may have a right to request information on these safeguards and to obtain a copy of them. If you would like to do so, please immediately notify us in accordance with the Contact Information section below.

9. Our Site and Use of Cookies

We use various technologies to collect other types of information, including PI, automatically. For example, in order to measure the usefulness and efficiency of our Sites, we automatically track certain information from all visitors to our Sites. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information.

Additionally, like most interactive web sites, we use “cookies” on certain pages of our Sites. “Cookies” are small data files that are stored on your hard drive that store certain information, including certain PI, accessible to our Sites, such as your password and any information content preferences you may voluntarily set at our Sites. These technologies help us recognize you, customize your experience on the Sites and analyze your use of the Sites to make them more useful to you. By visiting our Sites, you agree to our use of cookies. You can refuse the use of cookies by selecting the appropriate browser setting. If you opt-out, please note that your experience using the Sites may not be optimal, and you may not be able to use certain features on our Sites. For more details, please refer to our Cookie Policy.

10. Data Subject Rights

1. Your EU Data Subject Rights

The European Union’s General Data Protection Regulation (“GDPR”) is a sweeping piece of legislation that grants EU residents increased control over their personal information. The GDPR allows consumers to access their personal information and find out details of how that data is processed, to rectify inaccurate personal information, to have their data erased (when certain conditions are met), to restrict processing of their data, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to ensure that personal information is secured.

Specifically, the GDPR and other national privacy laws provide data subjects with certain rights regarding their PI. If you are an individual who resides in the EU and whose PI is collected and processed by Shamrock, you have:

• The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you.
• The right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so.
• In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or to request that we transmit the data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us.
• The right to request that we rectify your personal data if it is inaccurate or incomplete.
• The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it.
• The right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and/or to refuse that request.
• The right to lodge a complaint with the data protection regulator if you think that any of your rights have been infringed on by us.

You can exercise your rights by contacting using the details set out in the “Contacting Us” section below.

2. Information Rights for California Residents

The California Consumer Privacy Act (CCPA) as amended and expanded by the California Privacy Rights Act of 2020 (the “CPRA”) is a sweeping piece of legislation that grants California residents increased control over their Personal Information.

The CCPA allows consumers to find out what personal information of theirs has been gathered, to request that businesses delete their data, to opt out of having their information sold, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to assure that their vendors comply as well.

If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what Shamrock will do in response. Additional information about our Collection and Use of your Personal Information can also be found in the corresponding section of this notice.

Please note that the rights under the CCPA do not apply to PI collected, processed, sold or disclosed pursuant to Gramm-Leach-Bliley Act (Public Law 106-102) and Fair Credit Reporting Act (12 CFR 1022).

If you are an individual who resides in California and whose Personal Information is collected and processed by Shamrock, you may have the right to:

• Request that we disclose to you, free of charge, the categories of the PI we collect, specific to you over the last twelve (12) months, including the categories of sources from which the PI was collected (and/or, if applicable, sold, shared or otherwise disclosed to a third party), and the business purpose for collecting PI.
• Request the correction of any inaccurate PI maintained by us about you.
• Request that we limit the use of your Sensitive Personal Information.
• Choose to opt-out of the sale or sharing of Personal Information. Under the CPRA, sharing is defined as the disclosure of personal information to third parties for purposes of “cross-context behavioral advertising.” Cal Civil Code Section 798140 (ah) (1). Shamrock does not sell or share the personal information or sensitive personal information of our consumers and has not done so within the past twelve (12) months.
• Request that we delete the PI we have collected about you. Following our verification of the request, we will comply with the request and delete any or all the PI in our possession that we collected from you and/or any or all such PI in the possession of our service providers, unless otherwise restricted by law or regulation.

3. Non-Discrimination for Exercising Your PI Rights

We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.

11. Exercising Your Rights

To exercise any of your rights set forth in this privacy notice, please contact the toll free number (888) 973-1007, email contact@shamrockcap.com, or contact: Shamrock Capital Advisors, LLC, 1100 Glendon Ave #1600, Los Angeles, CA 90024. Please include a description of which right you want to exercise and the information to which your request relates.

1. Verifying Your Identity

If you choose to contact us with a request, you will need to provide us with identifying information that matches the PI we currently have about you. For example, we may require identifying documents that will be used to verify the identity of the requestor.

2. Authorized Agent

You have the right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please call our toll free number (888) 973-1007, email contact@shamrockcap.com, or contact: Shamrock Capital Advisors, LLC, 1100 Glendon Ave #1600, Los Angeles, CA 90024.

3. Accessibility Information

For consumers with disabilities who need to access this policy in an alternative format, please call our toll free number (888) 973-1007, email contact@shamrockcap.com, or contact: Shamrock Capital Advisors, LLC, 1100 Glendon Ave #1600, Los Angeles, CA 90024.

12. Changes to This Privacy Notice

From time to time we may update this privacy notice. If revisions are made to the privacy notice, we will update the statement with a new revision date.

13. Contacting Us

If you have any questions or concerns regarding the information in this privacy notice, or would like to exercise any of your rights set forth in this privacy notice, please contact the toll free number (888) 973-1007, email contact@shamrockcap.com, or contact: Shamrock Capital Advisors, LLC, 1100 Glendon Ave #1600, Los Angeles, CA 90024. Please include a description of what right you want to exercise and the information to which your request relates.