Privacy Policy

Welcome to https://ipipartners.com/ (“Website”), which is owned and operated IPI Partners, LLC and our advisory affiliates and subsidiaries (collectively, “IPI”, “we”, “our” or “us”). Maintaining the trust and confidence of our clients is a high priority therefore privacy is one of the central tenets of IPI Partners, LLC’s (collectively with its affiliates, “IPI” or “we”) value proposition. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. This US Privacy Policy (“Privacy Policy”) applies generally to all members and partners of private investment funds advised by IPI as well as information we collect from Website visitors and individuals that otherwise interact with us.

If you are located in the EU or UK please review our EU and UK Privacy Notice. If you are a California resident, please review our California-Specific Privacy Policy.

1. Information We Collect

We may collect nonpublic personal information and other personal information about you, including information that can help us directly or indirectly identify you (“personal information”), in connection with operating our Website, providing our services, as well as providing investment products, financial advice, or other services. Depending on how you interact with us, such personal information may include:

• Identifying and contact information, such as your name, date of birth, tax identification number, copies of your government-issued IDs (e.g., passport or driver’s license), Social Security Numbers, physical and mailing addresses, phone number, email, and other types of contact information.
• Information related to your finances and financial accounts, for example your net worth, gross assets, investment sophistication and goals, financial account information, asset/investment-specific information, income, trust and estate information, tax status and other relevant tax information, and transaction-specific information.
• Information related to your various activities and relationships, such as information related to your businesses and professional engagements, professional relationships, familial relationships, charitable activities, personal undertakings, and service providers.
• Information related to your affiliations, for example, information related to your business(es) or professional engagements, and information related to your relationship with any of our clients or investors.
• Information related to your interactions with us, such as written communications between you and us, notes related to in-person meetings or telephone calls between you and us, and information related to your IP address or other device identifiers when using our Website or electronic delivery portals.
• Information related to the provision of our services for you, for example fees and billing information, records related to acts we take on your behalf, notes regarding your service preferences, and transaction-specific information.

We may collect this information directly from you through your interactions with us and our website, as wells as from account applications and subscription agreements. We may also receive information about you from our services providers and other entities such as credit bureaus.

2. Our Security Policy

We restrict access to personal information about you to those individuals who need to know that information to perform their respective duties. We maintain physical, technical, and administrative security measures to safeguard confidential client information.

3. Employee Confidentiality

All employees of IPI and its affiliates are required to sign a confidentiality agreement which strictly governs their employment status with IPI or such affiliate.

4. Disclosing Information

Depending on how you interact with us, we may disclose the personal information that we collect in accordance with this Privacy Policy, however we will not disclose information regarding you or your account except under the following circumstances:

• To entities that perform services for us or you, or function on your behalf, including, but not limited to: financial service providers, such as a custodian, broker-dealer, investment company, portfolio manager, portfolio reporting vendor, insurance company, lenders, fund administrators and audit and tax preparation firms;
• To consumer reporting agencies;
• To the extent reasonably necessary to prevent fraud, unauthorized transactions or liability; a
• In connection with a change of ownership or control by or of us or any affiliated entity (in each case whether in whole or in part); and
• With your approval or consent, to your attorney, accountant, trustee or anyone else who represents you in a fiduciary capacity, and other entities.

We may share your information with affiliates under common control with IPI in order to provide services or offer additional products and services (e.g., the opportunity to invest in products managed by affiliates). We may also share your information as required by law or to comply with regulatory inquiries to government entities or other third parties in response to subpoenas or other legal process.

5. Closed or Inactive Accounts

If you cease to be a limited partner of an investment vehicle managed by IPI, our Privacy Policy will continue to apply to you, and we may continue to share your nonpublic personal information as described in this Privacy Policy.

6. Right to Limit Sharing

You may have the right to opt-out of the disclosure of your non-public personal information to nonaffiliated third parties or of the disclosure to affiliated parties about your creditworthiness, unless otherwise permitted by law. To exercise such right, please contact us at (202) 396-1907 or compliance@ipipartners.com.

7. Complaint Notification

Please direct complaints to: Alan Chen, Chief Compliance Officer at IPI Partners, LLC, 300 N. LaSalle St., Chicago, IL, 60654, Ph (312) 796-2200, or via email at achen@ipipartners.com.

8. Links to External Websites

Our Website 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, and we are not responsible for the information practices of such third party websites.

9. Do Not Track

Our Website does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

10. Changes to This Privacy Policy

If we make any substantial changes in the way we use or disseminate confidential information, we will notify you. If you have any questions concerning this Privacy Policy, please contact us at: IPI Partners, LLC, 300 N. LaSalle St., Chicago, IL, 60654, Ph (312) 796-2200 or via email at compliance@ipipartners.com.

The California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time, “CCPA”) imposes certain obligations on IPI Partners, LLC and its advisory affiliates (together, “we,” “our,” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review this California-Specific Privacy Policy (“Privacy Policy”) for information about how and why we collect, use, and disclose your personal information, our Notice at Collection 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.

Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.”

Notice at Collection and Use of Personal Information

Information We Collect

In connection with providing investment products, financial advice, or other services, we may collect non-public personal information from or about you. The categories of information we collect may depend on how you interact with us, and may include:

• Identifiers and similar information such as, name, address, date of birth, email address, social security number, driver’s license number, tax identification number, passport number, online identifiers or other similar identifiers.
• Additional information subject to California Civil Code Section 1798.80(e), such as a signature, education information, state identification number, credit card, bank account, assets, account balances, wire instructions, or other financial information.
• Characteristics of protected classifications under certain federal or state laws, including gender, national origin, or marital status.
• Information received from credit or service bureaus or other third parties, such as your credit history or employment status.
• Information about your holdings and transactions with us, our affiliates, or others (including lenders, auditors, service providers, and fund administrators), such as information regarding investments and credit facilities.
• Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds in which you are invested, investments considered, or sources of wealth.
• Audio, electronic, visual, or similar information.
• Professional or employment-related information, including investment experience, occupation, compensation, employer, and title.
• Internet or other electronic network activity information, including interactions with our website or use of certain online tools, and IP addresses.
• Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds.
• Sensitive personal information under the CCPA such as your passport number, driver’s license, and state identification card as well as your account 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.

Purposes for Collecting and Using Personal Information

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

• Performing services on behalf of a fund, including maintaining or servicing accounts, providing investor relations services, processing subscriptions, withdrawals, verifying information, processing payments or providing similar services.
• Communicating with you.
• Performing our contractual obligations to a California Resident as a subscriber to a fund, including providing updates on a fund’s performance, providing tax reporting 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 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 website.
• Internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

How Long We Keep Information

How long we keep your personal information will vary primarily depending on:

• The purpose for which we are using your personal information – we will keep your personal information for as long as is necessary to provide the relevant services, and
• Our legal obligations – laws or regulation set a minimum period for which we are required to keep certain of your personal information.

We only store data that identifies you so long as it is necessary to carry out the purposes described in this Privacy Policy.

Sale or Sharing of Personal Information

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

For more information about our privacy practices, please review our entire Privacy Policy which is also located on the first page of this Privacy Policy.

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

Information We Have Collected and Our Purpose for Collecting It

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

Sources of Personal Information

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;
• an investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or
• from information captured on applicable websites.
• 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; and/or
• from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

Disclosing 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 (for example your name, address, DOB, SSN, driver’s license, passport number and online 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 Social networks, recruiting agencies and other similar third-party websites Affiliated entities Operating systems and platforms
Additional information subject to Cal. Civ. Code § 1798.80(e) (for example, a signature, state identification card number, financial information, or bank account information)
Characteristics of protected classifications under certain federal or state laws (for example gender, age, national origin, citizenship or marital status)	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 Affiliated entities
Commercial Information (for example records of products or services purchased, obtained or considered or purchasing histories or tendencies including funds in which you are invested, investments considered or sources of wealth)	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 Social networks, recruiting agencies and other similar third-party websites Affiliated entities Operating systems and platforms

In addition, we may disclose and, in the preceding 12 months, we may have disclosed all of the categories of personal information identified in “Personal Information We Collect” above, 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 by law. We may also transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in “Purposes 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 fund administrator, IT providers, or, 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 “Personal Information We Collect”, under the CCPA, 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 that information, subject to applicable exemptions and limitations, including the right to: (i) 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; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); (v) opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (vi) 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); (vii) correct inaccurate personal information (“Request to Correct”); and (viii) 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”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting the personal information; (d) the categories of third parties with which we disclose personal information about you; and (e) the specific pieces of personal information we have collected about you.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. 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

You may submit a Request to Know, Request to Correct or a Request to Delete (“Consumer Rights Request”), as described above, through the following toll-free telephone number 888-859-2668, by emailing the use at ccpainquiries@ipipartners.com with “CCPA Rights Request” in the subject line, or through our website at the following link https://ipipartners.com/contact/.

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 may update this Privacy Policy from time-to-time at our sole discretion. If you do not agree to any changes we make to this Privacy Policy, you must not continue to use our services.

Contact for More Information

This Privacy Policy is available in alternative formats upon request. If you have any questions or concerns about this Privacy Policy, or to request this Privacy Policy in an alternative format, please contact us at: compliance@ipipartners.com or by calling (312) 796-2200. You can also reach us at 300 LaSalle Street, Suite 1500, Chicago, IL 60654.

This Privacy Policy was last updated: September 2024.

IPI Partners, LLC and our advisory affiliates and subsidiaries (collectively, “IPI”, “we”, “our” or “us”) recognize the importance of protecting personal information. This European Union (EU) and United Kingdom (UK) Privacy Notice (“Privacy Notice”) applies to personal information that we collect, as a data controller, regarding data subjects. It also explains who we are and how you can exercise your privacy rights.

This Privacy Notice contains information on our use of your personal information in accordance with relevant laws and regulations, including, where applicable, the EU General Data Protection Regulation (2016/679) (“EU GDPR”), Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (the “UK GDPR”, the EU GDPR, the “GDPR”).

1. What personal information do we collect?

Depending on how you interact with us, we may collect personal information from or about you. When we use the term “personal information,” we mean information that can help us directly or indirectly identify you. We may collect this information directly from you, from other third-party sources, and automatically from your use of our Site. We may also collect some information that could be considered “special category” information the GDPR.  More details about what information we collect and how we collect it is provided below.

1.1 Information we collect directly from you

Depending on how you interact with us, for example if you are (or are prospectively) our client or an investor in one of our affiliated financial vehicles, during or before the provision of our services we will ask you to provide personal information voluntarily. To the extent applicable for the provision of our services, you may provide us with the following personal information:

• Identifying and contact information, such as your name, date of birth, tax identification number, copies of your government-issued IDs (e.g., passport or driver’s license), Social Security Numbers, physical and mailing addresses, phone number, email, and other types of contact information.
• Information related to your finances and financial accounts, for example your net worth, gross assets, investment sophistication and goals, financial account information, asset/investment-specific information, income, trust and estate information, tax status and other relevant tax information, and transaction-specific information.
• Information related to your various activities and relationships, such as information related to your businesses and professional engagements, professional relationships, familial relationships, charitable activities, personal undertakings, and service providers.
• Information related to your affiliations, for example, information related to your business(es) or professional engagements, and information related to your relationship with any of our clients or investors.
• Information related to your interactions with us, such as written communications between you and us, notes related to in-person meetings or telephone calls between you and us, and information related to your IP address or other device identifiers when using our website or electronic delivery portals.
• Information related to the provision of our services for you, for example fees and billing information, records related to acts we take on your behalf, notes regarding your service preferences, and transaction-specific information.

1.2 Information that we obtain from third party sources

Depending on how you interact with us, such as if you are our client or an investor in one of our affiliated financial vehicles or interact as with us in another capacity, we may collect certain information about you from third parties, including:

• Identifying and contact information, such as your name, mailing address, phone number, email and other types of contact information.
• Information related to your affiliations, for example, information related to your business(es) or professional engagements, and information related to your relationship with any IPI client or investor in IPI’s affiliated financial vehicles, but not including special categories of information as described in Section 1.4.
• Information related to your finances and financial accounts, such as financial account information, transaction-specific information, information regarding the value of your portfolio and assets, tax information, and trust and estate information.
• Information related to your various activities and relationships, for example, information related to your businesses and professional engagements, your professional relationships, your familial relationships, your charitable activities, and your personal undertakings.

1.3 Information we collect automatically and use of Cookies

We may gather information about you automatically through your use of certain services like our website such as your IP address and how you navigate our website. We may collect information about you by using cookies, tracking pixels and other technologies (collectively, “Cookies”).

For information on our use of cookies please see Section 4, below.

2. How do we use your personal information?

Depending on how you interact with us, we may use your information for the following purposes:

• To provide investment and financial services, including recommendations or products, open financial accounts or assist in the opening of financial accounts, and facilitate transactions with third parties.
• To support our interactions with you, including responding to your communications with us.
• To open financial accounts or assist in the opening of financial accounts.
• To facilitate transactions with third parties.
• To refer third party service providers.
• To comply with our legal and regulatory obligations, including the retention of records required by the U.S. Securities and Exchange Commission’s rules promulgated under the U.S. Investment Advisers Act of 1940, to participate in required audits and regulatory examinations, to detect and prevent fraud and fraudulent behavior, and applicable anti-moneylaundering laws and regulations.
• Administer the Website, including to understand and improve your navigation and interaction with the Website.
• To exercise, establish or defend our legal rights, or to protect your vital interest or those of any other person.
• To detect potential conflicts of interest in the provision of our services and operation of our business.
• To provide any other specific services for which you have engaged us.

3. What is our legal basis for processing your personal information?

Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. If you are our client or an investor in one of our affiliated financial vehicles, we collect and use personal information as necessary for the performance of the contract between you and us. If you are not our client or an investor in one of our affiliated financial vehicles, we collect and use personal information where such processing is in our legitimate interest and is not overridden by your rights. We might also your personal information to comply with certain legal or regulatory requirements. Our legitimate interests in processing your personal information include detecting potential conflicts of interest in the provision of our services and the operation of our business, as well as supporting our interactions with you.

4. Our Website’s Use of Cookies and Similar Technologies

Our website uses Cookies for various purposes, including to distinguish you from other users of our website and collect certain information about your interactions with our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

We may use third-party web analytics services on the website, including Google Analytics. We use Google Analytics to help us understand how people are using our website. 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 website by downloading and installing the browser plugin available here.

You can control our uses of cookies through your internet browser or through third party tools:

• Internet Browser. You can also control cookies through most browsers by changing your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser.
• Third Party Tools. Various third party tools exist that can help you manage cookies. For additional information you can also visit http://www.allaboutcookies.org/ where you will find information on cookie management and blocking.
• Cookie Management Tool. You can customize or change your cookie preferences at any time by accessing our cookie management system, available here, including, where applicable, withdrawing any consent you provided at any time.

5. Who do we share your personal information with?

We may share personal information to the following categories of recipients:

• With our employees, officers, directors, partners, affiliates, advisors, independent contractors and service providers; provided that within such categories, we restrict access (time and entry) to personal information to those who access the personal information to provide our services. Service providers include accountants, administrators, attorneys, auditors, compliance and IT consultants, custodians, SAAS (software as a service) providers, and other third parties engaged by us to assist with or support our provision of services.
• As part of a transaction, with third parties that require the personal information to execute the contemplated transactions.
• With the U.S. Securities and Exchange Commission and other competent law enforcement bodies, government agencies, courts or third parties where we reasonably believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
• As anonymized data, to third parties under obligations of confidentiality who request such information as part of our services or as part of a business transaction with us.
• With any other person with your consent to the disclosure.
• 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.

6. Where do we transfer your personal information?

In performing our services, we may have to transfer your personal information outside of the European Economic Area (“EEA”) and UK, or to countries other than the country in which you are resident. The countries to which your personal information is transferred may not afford the same protections as the country your personal information is transferred from. Specifically, our servers are in the United States. This means that when we process your personal information, we process it in either of these countries. Additionally, we may transfer data to service providers for processing in these countries or other countries, for the purposes described in this policy.

In circumstances where we transfer personal information outside the EEA or the UK, we will seek to ensure a similar degree of protection is afforded to it by ensuring that, where possible, personal information is generally transferred only to persons in countries outside the EEA or the UK in one of the following circumstances:

• to persons and undertakings in countries that have been deemed to provide an adequate level of protection for personal information by the European Commission or the relevant Secretary of State in the UK;
• to persons and undertakings to whom the transfer of such personal information is made pursuant to a contract that is compliant with the model contracts for the transfer of personal information to third countries from time to time approved by the European Commission or the relevant Secretary of State in the UK (as supplemented where and if required);
• to persons and undertakings outside of the EEA or the UK pursuant to other appropriate safeguards for the transfer of personal information;
  only on one of the conditions allowed under the GDPR in the absence of (i) a decision by the European Commission or relevant Secretary of State in the UK that has deemed a country
• to provide an adequate level of protection for personal information (i.e. an adequacy decision) or (ii) appropriate safeguards such as a contract that is compliant with the model contracts for the transfer of personal information to third countries approved by the European Commission or the relevant Secretary of State in the UK.

7. How do we secure and safely store your personal information?

We use reasonable and appropriate technical and organizational measures designed to protect your personal information. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Any transmission of personal information is at your own risk.

8. How long do we keep your personal information?

How long we keep your personal information will vary primarily depending on:

• The purpose for which we are using your personal information – we will keep your personal information for as long as is necessary to provide the relevant services, and
• Our legal obligations – laws or regulation set a minimum period for which we are required to keep certain of your personal information.

9. Your data protection rights and how to exercise them

You may have the following data protection rights:

• To access, correct, update, port or request deletion of your personal information that we process. Due to applicable regulatory requirements, there may be instances in which we cannot completely delete your personal information, although we will delete personal information to the extent consistent with our worldwide regulatory obligations.
• To object to or restrict processing of your personal information (so long as we are processing such personal information on the legal basis of pursuing our legitimate interest).
• To complain to a data protection authority about our collection and use of your personal information.
• Withdraw your consent to our processing of your personal information.

You can exercise these rights by contacting us using the information in Section 12 (How can we be contacted?). Please include “Data Protection Rights Request” in the subject line.

10. How do we notify you regarding changes to this Privacy Notice?

If we make changes to this Privacy Notice, we may notify you by updating the Privacy Notice with a “Last Updated” date at the top. We may also provide additional notice in some cases, such as by providing a statement on our website, or by sending an email notification. The most current version of our Privacy Notice will be available on our website.

11. Links to third party websites

This Website may contain links to third-party websites. Any access to and use of such third-party websites is not governed by this Privacy Notice, 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

12. How can we be contacted?

For questions about this Privacy Notice or to exercise your privacy rights, please contact us at: compliance@ipipartners.com or by calling (312) 796-2200. You can also reach us at 300 LaSalle Street, Suite 1500, Chicago, IL 60654.