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Client Privacy Notice

 
(Last updated 06/04/2018)


Your privacy is very important to us. This notice (this "Privacy Notice") is provided by Lone Pine Capital LLC ("Lone Pine"), the investment manager of several private investment funds (each, a "Fund", and together, the "Funds", "we", "us" or "our"), on behalf of the Funds, and sets forth the policies of each Fund with respect to the collection, sharing and protection of non-public personal information of each Fund's investors, prospective investors and former investors ("Investors" or "you"). For U.S. investors, these policies apply to individuals and Individual Retirement Accounts only.  This Privacy Notice also applies to Investors located in the European Economic Area (the "EEA") and/or in Switzerland whose personal data is subject to the EU General Data Protection Regulation 2016/679.  The Privacy Notice may be changed at any time without prior notice to you to reflect changes in our practices.  We will post the updated version on the Website and indicate at the top of this Privacy Notice when it was most recently updated.

Information that may be collected

We collect personal information with respect to Investors, such as your address, social security number, tax identification number, account balances, account numbers, account activity, assets, transaction and/or income information, for example, when you: (i) provide it to us in the Subscription Agreement and related documents; (ii) provide it to us in correspondence and conversations with a Fund's representatives; or (iii) make transactions with a Fund, such as when you purchase securities from us, tell us where to send money or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates (i.e., financial and non-financial companies related by common ownership or control).

Use of Investor Personal Information

We will use Investor personal information (i.e. information that identifies an individual or from which an individual is identifiable (directly or indirectly)) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal or regulatory requests or investigations. For example, it may be necessary, under anti-money laundering and similar laws, to disclose information about a Fund's investors in order to accept subscriptions from them. We may also use Investor personal information: (i) to communicate with Investors and respond to requests and enquiries; (ii) for business administration including statistical analysis; (iii) to offer produces and services to Investors; (iv) to provide an Investor with a requested service; (v) to personalize and assist in your visit to the website; (vi) to comply with applicable laws, regulations or codes of practice; (vii) for the performance of any contractual relationship with an Investor; or (viii) for any other purpose as set out in this Privacy Notice where in our legitimate interests.  

Disclosure to Certain Third Parties

We may disclose personal information about our Investors to: (i) our affiliates, advisers, service providers such as transfer agents, fund administrators, custodians, and broker-dealers; (ii) fraud prevention agencies and law enforcement agencies; (iii) courts, governmental and non-governmental regulators and ombudsmen; (iv) to any non-affiliate (i.e., financial or non-financial companies not related by common ownership or control) that acquires, or is interested in acquiring, all or part of our assets or shares, or that succeeds us in carrying on all or a part of its business, whether by merger, acquisition, reorganization, or otherwise; or (v) as required or permitted by law, including to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or we have a legitimate interest in making a disclosure, such as where necessary to protect our rights and property.

We will also disclose your personal information if you direct us to do so. We may disclose your personal information for our own marketing purposes, such as to offer our products and services to you. We may also disclose personal information about your transactions and experiences with us to our affiliates for their everyday business purposes.

We may also share your personal information with our affiliates to market to you. You may prevent this type of sharing by calling Investor Services at 203-618-1400 or by using the contact information under the ‘Contact Us’ section below.  If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. State laws may give you additional rights to limit sharing.

Security and Retention

To protect your personal information from loss or theft, as well as from unauthorized access, disclosure, copying, modification or use, we use security measures that comply with federal law and relevant data privacy laws. These measures include computer safeguards and secured files and buildings.  We will maintain your personal information for at least five to seven years and thereafter for so long as it is necessary to maintain your account, to service the institution you represent, and/or for the purpose for which the data was collected and in all cases for such time as may be required by applicable law or regulation.

Transfer of Personal Information Outside the EEA

Lone Pine is located in the United States and may disclose the personal information of Investors located in the EEA to other recipients also located in countries outside of the EEA which may not have data privacy laws equivalent to those in the EEA. By submitting your personal information to us, each Investor consents to the transfer of their personal information to LONE PINE and the other recipients described in this Privacy Notice that are located in countries outside of the EEA. Investors may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Rights of Investors in the EEA

Under applicable European Union data privacy laws, Investors that are located in the EEA may have a right to: (i) request access to, and rectification, or erasure of, their personal information; (ii) obtain restriction of processing or to object to processing of their personal information; and (iii) data portability. If you wish to exercise any of these rights you should contact investor@lpcap.com. Investors in the EEA also have the right to lodge a complaint about the processing of their personal information with their local data protection authority.

Cookies

Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

When you visit the website, we may place a “cookie” or other online tracking device (e.g. web beacons) in order to improve your experience by recognizing you when you visit the website, such as by assigning a session ID and to deliver content specific to your interests. The cookies we place may also collect information about your IP address, or click stream data within our website (i.e. the actions taken in connection with the website). This information helps us improve the functionality of the website.

Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the website.

Contact Us

If you have any questions about this Privacy Notice, call Investor Services at 203-618-1400 or email investor@lpcap.com. This Privacy Notice reflects the privacy policy that has been adopted by LONE PINE.

Revisions to this Privacy Notice

We may revise or supplement this Privacy Notice from time to time.  If we make any substantial changes in the way we use or share your personal information, we will notify you by posting a notice on our website, prior to the change becoming effective.  You may determine if this Privacy Notice has been revised since your last visit by referring to the "Effective Date of Current Policy" date noted at the top of this page.  We encourage you to refer to this policy on an ongoing basis so you understand our current Privacy Notice.