CLIENT PORTAL
1833 South Coast Highway, Suite 210
Laguna Beach, CA 92651
(949) 482-2121
Last Update: January 11, 2021
This Notice to California Residents (“CCPA Notice”), provided by North Reef Capital Management LP (“Company,” “we,” “us,” or “our”) pursuant to the California Consumer Privacy Act (“CCPA”) applies to natural persons who reside in the State of California (“consumers” or “you”) who engage or interact with us or on the funds and accounts managed by us, including, without limitation, visiting our website and purchasing our products or services. Any terms used herein but not defined shall have the meaning assigned in the CCPA.
In the event of any conflict or inconsistency between this CCPA Notice and any of our other privacy policies, this CCPA Notice shall control only with respect to the Personal Information (as defined in CCPA) of consumers, their households or devices. Additionally, if you are located outside of the State of California this CCPA Notice does not apply to you.
Categories of Personal Information. Company has or may have collected and/or received the Categories of Personal Information identified below (with examples) from or about consumers, their households or devices, within the twelve (12) months preceding the Last Update of this CCPA Notice (“Last Update”). Personal Information does not include (i) publicly available information from government records; (ii) deidentified or aggregated Personal Information; or (iii) information excluded from the CCPA including information regulated by certain sector-specific data protection laws including the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, the Gramm-Leach-Bliley Act of 1999, and the California Financial Information Privacy Act.
Categories of Sources. We may collect the Categories of Personal Information listed above from the following Categories of Sources: (i) directly from consumers, or consumers’ agents or employers (e.g., forms, surveys, responses, or other interactions from or with consumers), and (ii) indirectly from consumers (e.g., consumer activity online, interactions with our Website and other sites).
Use of Personal Information. We may use or disclose the Personal Information we collect for one or more of the following commercial or business purposes (each, a “Business Purpose”): (i) to investigate and to manage enquiries, disputes and legal proceedings, (ii) comply with court orders, mandatory dispute resolution determinations, mandatory government authority or law enforcement orders or directions, or applicable regulatory requirements (iii) as described to you when collecting your Personal Information or as otherwise permissible under the CCPA, (iv) to evaluate or consummate a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information is among the assets transferred, (v) where applicable, to assist us in verifying your identity, and to provide support, personalize, and develop our products and services, (vi) to fulfill and respond to your inquiries and requests, including providing you with support, investigating and addressing your concerns, monitoring and improving our responses, and to otherwise carry out the purposes for which you provided the information, (vii) to receive products or services from you and (viii) to otherwise conduct our business, including providing our products and services.
Categories of Third Party Recipients. We may only share your Personal Information with Service Providers, which include IT and cloud hosting companies, payment providers, transactions reporting providers, customer relationship management, and providers of administrative services for our Business Purposes or as otherwise required by applicable law.
Disclosures of Personal Information for a Business Purpose. In the twelve (12) months preceding the Last Update, we may have disclosed the Categories of Personal Information for a Business Purpose to the Categories of Third Parties set forth in Table I.
| Table I: Categories of Personal Information Collected | Categories of Third Party Recipients |
|---|---|
| Identifiers | Service Providers |
| Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e)) | Service Providers |
| Protected classification characteristics under California or federal law | Service Providers |
| Commercial Information | Service Providers |
| Biometric information | Service Providers |
| Internet or other similar network activity | Service Providers |
| Geolocation data | Service Providers |
| Audio, electronic, visual, thermal, olfactory, or similar information | Service Providers |
| Professional or employment-related information | Service Providers |
| Non-public education information | Service Providers |
| Inferences | Service Providers |
Sales of Personal Information. In the twelve (12) months preceding the Last Update, we have not sold Personal Information.
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes such rights and explains how to exercise them.
Right to Know About Personal Information. You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your Personal Information. Once we receive and verify your request, we will disclose to you the following (to the extent applicable to your request):
Right to Request Deletion. You have the right to request that we delete any of Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
Exercising Rights to Know or Request Deletion. To exercise the rights to know or request deletion described above, please submit a verifiable consumer request to us by either: (a) calling us at (800) 420-3780, or (b) submitting your request by email to compliance@northreefcapital.com
You may only make a verifiable consumer request under the right to know twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information related to you.
Making a verifiable consumer request does not require you to create an account with us.
Verification Process. To submit a verifiable consumer request, the consumer may be required to provide up to three data points, which may include additional Personal Information, to enable us to verify the consumer’s identity with the degree of certainty required by the CCPA.
We will use Personal Information provided in a verifiable consumer request solely for the purpose of verifying the requestor’s identity or authority to make the request. We or a third party on our behalf may follow up with you to determine whether a request is a verifiable consumer request under applicable law.
If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, we will deny the consumer request in whole or in part and will not to disclose the information requested or, as applicable, will not delete the information requested. We will respond to any such consumer request with a denial and will also explain why it has no reasonable method by which it can verify the identity of the requestor.
Response Timing and Format. We will confirm receipt of a verifiable consumer request within then (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. If you do not have an account with us, and you do not indicate a preference for delivery, we will use its discretion in choosing the method of delivery of the information.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.
Right to Opt-Out of the Sale of Personal Information. We do not sell the Personal Information of consumers (including minors under 16 years of age). However, if you are 16 years of age or older, you have the right, at any time, to direct us to not sell your Personal Information (the “right to opt-out”) and if you are under 16 years of age you have the right to opt-in to the sale of your Personal Information.
Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. We will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties, (iii) provide you a different level or quality of products or services, and (iv) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.
If you submit a request to know or delete your Personal Information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization.
Pursuant to California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties.
To make such a request, please send an email to compliance@northreefcapital.com
This CCPA Notice is effective as of the date of the Last Update stated at the top of this CCPA Notice. We may change this CCPA Notice from time to time with or without notice to you. By visiting or accessing the Website or the Services, purchasing products or services from us, or otherwise engaging or interacting with us after we make any such changes to this CCPA Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CCPA Notice in current effect. Please refer back to this CCPA Notice on a regular basis.
If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in the CCPA Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
compliance@northreefcapital.com
North Reef Capital Management LP
1833 South Coast Highway, Suite 210
Laguna Beach, CA 92651
ATTN: Compliance
Please read the following terms and conditions (“Terms of Use”) before using the website (the “Site”) of North Reef Capital Management (“North Reef ”). Your access to and use of the Site is subject to these Terms of Use and all applicable laws and regulations. The Terms of Use constitute a legal agreement between you and North Reef. The Site is available only to, and may only be used by, individuals who can form legally binding contracts under applicable law. By accessing and using the Site, you accept, without qualification, these Terms of Use. If you do not approve and accept these Terms of Use without qualification, you should exit the Site immediately.
North Reef may only transact business in those states and international jurisdictions where North Reef is registered, has filed notice status or is otherwise excluded or exempted from notice or registration requirements. The purpose of the Site is only to provide information regarding North Reef and its services. Any communications with prospective clients residing in states or international jurisdictions where North Reef is not registered or licensed shall be limited so as to not trigger registration or licensing requirements. Nothing on the Site should be construed as investment advice, which can be provided only in one-on-one communications.
If you are assigned a user name and password to access or use certain parts of the Site, you may not allow others to use them. If your password has been compromised for any reason, you must contact us immediately for a new password. If you provide your password to any third party, you will be solely responsible for any actions taken by such third party using your password. All information on any non-public (i.e., password-restricted) areas of the Site is confidential and private. You may not disclose or distribute it to any other person for any purpose; it is made available solely for your personal use in connection with your investment activities.
The Site is for your personal and non-commercial use, and North Reef grants you a non-exclusive, non-transferable and limited personal license to access and use the Site, conditioned on your continued compliance with these Terms of Use. You may not modify, copy (except as set forth below), distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any information, products or services obtained from the Site. You may not link other websites to the Site without North Reef’s prior written permission. You may print one hardcopy of the information and download one temporary copy of the information into one single computer’s memory solely for your own personal, non-commercial use and not for distribution, provided that all relevant copyright, trademark and other proprietary notices are kept intact. You are prohibited from using the Site to advertise or perform any commercial solicitation. You may not use any robot, spider, scraper or other automated means to access the Site for any purpose without the prior written permission of North Reef. You may not take any action that imposes, or may impose, in North Reef’s sole discretion, an unreasonable or disproportionately large load on North Reef’s infrastructure, interfere or attempt to interfere with the proper working of the Site or any activities conducted on the Site, or bypass any measures North Reef may use to prevent or restrict access to the Site. Any rights not expressly granted herein are reserved.
The information on the Site is intended to provide an overview of North Reef to enable investors to understand the nature of North Reef’s services. It is not intended as and does not constitute investment advice or legal or tax advice or an offer to sell any securities to any person or a solicitation of any person of any offer to purchase any securities. The information in the Site should not be construed as any endorsement, recommendation or sponsorship of any company or security by North Reef or any of its affiliates. You should evaluate the information made available through the Site, and you should seek the advice of professionals, as appropriate, to evaluate any opinion, advice, product, service or other information. You agree that North Reef is not liable for any action you take or decision you make in reliance on any information on the Site.
North Reef’s and its affiliates’ services are designed to integrate with the services provided by its clients’ other legal and tax advisers, not to replace their services.
You acknowledge that any requests for information are unsolicited and any information provided shall neither constitute nor be construed as investment advice by North Reef or any of its affiliates to you or constitute the formation of an investment advisory relationship, or any other client relationship. North Reef and its affiliates do not guarantee the suitability or potential value of any particular investment or information source. North Reef may invest or otherwise hold an interest in companies or securities that may be discussed on the Site.
As a condition to your use of the Site, you represent and warrant to, and agree with North Reef that, all of the information that you provide is truthful, accurate and complete.
THE INFORMATION AND SERVICES PUBLISHED ON THIS WEBSITE MAY INCLUDE INACCURACIES OR TYPOGRAPHICAL ERRORS. THE ACCURACY, COMPLETENESS, TIMELINESS AND CORRECT SEQUENCING OF SUCH INFORMATION AND SERVICES AND THE RESULTS OBTAINED FROM THEIR USE ARE NOT GUARANTEED BY NORTH REEF OR ANY PERSONS CREATING OR TRANSMITTING SUCH INFORMATION AND SERVICES.
NORTH REEF AND/OR ITS AFFILIATES MAY MAKE IMPROVEMENTS AND/OR CHANGES IN THE CONTENT AND OPERATION OF THE SITE AT ANY TIME WITHOUT NOTICE. THE SITE MAY BE TEMPORARILY UNAVAILABLE FROM TIME TO TIME.
NORTH REEF AND/OR ITS AFFILIATES MAKE NO REPRESENTATIONS ABOUT THE SUITABILITY OF THE INFORMATION AND SERVICES CONTAINED ON THE SITE FOR ANY PURPOSE. ALL SUCH INFORMATION AND SERVICES ARE PROVIDED “AS IS” WITHOUT WARRANTY OF ANY KIND. NORTH REEF AND/OR ITS AFFILIATES HEREBY DISCLAIM ALL WARRANTIES AND CONDITIONS WITH REGARD TO ALL INFORMATION AND SERVICES ON THE SITE, INCLUDING ALL IMPLIED WARRANTIES AND CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT AND AVAILABILITY. BECAUSE SOME STATES/JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES, THE ABOVE EXCLUSION MAY NOT APPLY TO YOU.
YOUR USE OF THE SITE IS AT YOUR OWN RISK. YOU ARE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM, LOSS OF DATA OR ANY OTHER DAMAGE OR LOSS THAT RESULTS, DIRECTLY OR INDIRECTLY, FROM THE USE OF ANY INFORMATION OR SERVICES ON THE SITE. IN NO EVENT SHALL NORTH REEF AND/OR ITS AFFILIATES BE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES ARISING OUT OF, OR IN ANY WAY CONNECTED WITH OR RELATING TO, THE USE OF OR ACCESS TO THE SITE OR WITH ANY DELAY OR INABILITY TO USE THE SITE, OR FOR ANY INFORMATION OR SERVICES OBTAINED THROUGH THE SITE, WHETHER BASED ON CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE, EVEN IF NORTH REEF OR ANY OF ITS AFFILIATES HAS BEEN ADVISED OF THE POSSIBILITY OF DAMAGES. BECAUSE SOME STATES/JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU.
NORTH REEF AND ITS AFFILIATES SHALL NOT BE LIABLE FOR ANY INFECTION BY VIRUSES OF OR DAMAGE TO ANY COMPUTER THAT RESULTS FROM YOUR USE OF, ACCESS TO OR DOWNLOADING OF ANY INFORMATION FROM OR ON THE SITE. IF YOU ARE DISSATISFIED WITH THE INFORMATION OR SERVICES OFFERED ON THE SITE OR WITH THE TERMS AND CONDITIONS OF THESE TERMS OF USE, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USE OF AND ACCESS TO THE SITE.
The Site and all of its content, including but not limited to all text, graphics, charts, audio, logos, images, data compilations, icons, code and software (“Content”), are the property of North Reef or its affiliates and are protected by U.S. and international copyright laws, with all rights reserved unless otherwise noted. All trademarks, service marks, trade names and other product and service names and logos displayed on the Site are proprietary to North Reef or its affiliates, including all registered and unregistered trademarks and service marks of North Reef and its affiliates. If the Site includes any trademarks, service marks, trade names or logos of any third parties, such items are the proprietary marks and names of their respective owners, and are protected by applicable trademark and intellectual property laws. Your use of any Content, whether owned by North Reef, its affiliates or any third party, without the express written permission of North Reef, is strictly prohibited except as otherwise expressly permitted in these Terms of Use. Without limiting the foregoing, you are prohibited from using any of North Reef’s or its affiliates’ copyrighted material or trademarks for any purpose, including, but not limited to, use as metatags, links or otherwise on any website, without the prior written permission of North Reef.
If North Reef collects any information from users of the Site, the collection and use of such information is governed by the Website Privacy Policy of North Reef, which you should read prior to providing any information to North Reef.
As a condition to your use of the Site, you represent and warrant to, and agree with, North Reef that you will not use the Site for any purpose that is unlawful or prohibited by these Terms of Use.
References to any publication or any other company in the Site are for reference and informational purposes only and are not intended to suggest that any of such companies endorse, recommend or approve of the services, analysis or recommendations of North Reef or its affiliates or that North Reef or its affiliates endorses, recommends or approves the services or products of such companies. News stories reflect only the author’s opinion and not necessarily that of North Reef or its affiliates.
The Site may contain hyperlinks to websites operated by parties other than North Reef, which may not have been screened or reviewed by North Reef and which may contain inaccurate, inappropriate or offensive material, products or services. North Reef does not control such websites, and North Reef assumes no responsibility or liability with regard to the accuracy, reliability, legality or decency of such third-party websites, content, products or services. Such hyperlinks are provided for your convenience only. North Reef’s inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators.
North Reef reserves the right, at its discretion, to change, modify, add or remove portions of these Terms of Use at any time without notice to you. We suggest that you check these Terms of Use periodically for changes. These Terms of Use can be accessed from the link at the bottom of the Site. If you use the Site after we post changes to these Terms of Use, you accept the changed Terms of Use. If the modified Terms of Use are not acceptable to you, your only recourse is to cease using the Site. Notwithstanding the preceding sentences of this paragraph, no revisions to these Terms of Use will apply to any dispute between you and North Reef that arose prior to the date of such revision. These Terms of Use may only be modified in writing as set forth in this paragraph, and may not be modified orally. North Reef expressly reserves the right to monitor any and all use of the Site.
North Reef reserves the right to modify or terminate the Site and to terminate your access to the Site, without notice at any time and for any reason.
You agree to indemnify, defend and hold harmless, at your own expense, North Reef, its parents, subsidiaries and affiliates, and their officers, partners, managers, members, employees, agents, distributors and licensees, from and against any judgments, losses, deficiencies, damages, liabilities, costs, claims, demands, suits, and expenses (including, without limitation, reasonable attorneys’ fees and expenses) incurred in, arising out of or in any way related to your breach of these Terms of Use or the Privacy Policy, your use of the Site or any product or service related thereto, or any of your other acts or omissions.
Unless otherwise specified, North Reef controls and operates the Site from its offices within the State of California, United States of America.
North Reef does not claim that materials in the Site are appropriate or available for use in locations other than California. If you choose to access the Site from other locations, you do so on your own initiative, and you are responsible for compliance with any applicable local laws.
These Terms of Use are governed by the laws of the State of California, without regard to its choice of law provisions. You hereby consent to the exclusive and personal jurisdiction and venue of courts in Orange County, California, which shall have exclusive jurisdiction over any and all disputes arising out of or relating to these Terms of Use, the use of the Site or any product or service related thereto. Use of the Site is unauthorized in any jurisdiction that does not give effect to all provisions of these terms and conditions, including without limitation this paragraph.
You agree that no joint venture, partnership, employment or agency relationship exists between you and North Reef or any of its affiliates as a result of these Terms of Use or use of the Site.
North Reef’s performance of these Terms of Use is subject to existing laws and legal process, and nothing contained in these Terms of Use is in derogation of North Reef’s right to comply with law enforcement requests or requirements relating to your use of the Site or information provided to or gathered by North Reef with respect to such use.
If any part of these Terms of Use is determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the warranty disclaimers and liability limitations set forth above, then the invalid or unenforceable provision shall be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of these Terms of Use shall continue in effect.
By reviewing or using the information on the Site after accessing the Site, you represent and warrant that (a) you have the authority to enter into these Terms of Use and create a binding contractual obligation, (b) you understand and intend these Terms of Use to be the legal equivalent of a signed, written contract equally binding, and (c) you will use the information on the Site in a manner consistent with applicable laws and regulations in accordance with these Terms of Use, as the same may be amended by North Reef online or otherwise from time to time. A printed version of these Terms of Use and any notice given in electronic form shall be admissible in judicial or administrative proceedings based on or relating to these Terms of Use to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.
These Terms of Use constitute the entire agreement between you and North Reef with respect to the Site and they supersede all prior or contemporaneous communications and proposals, whether electronic, oral or written, between you and North Reef with respect to the Site.
You agree to be bound by these Term of Use by accessing the Site and that your agreement shall be legally binding and enforceable and a legal equivalent of your handwritten signature.