Privacy Policy

Last updated: April 2025

SDC Investor and Website Privacy Notice

This investor and website privacy notice (“privacy notice”) describes the types of personal data that SDC Capital Partners, LLC and its subsidiaries (“SDC” , “we” or “our”) collects about individuals who are limited partners or clients (or potential limited partners or clients) of SDC or who visit SDC’s website (“you” or “investors”), and how SDC uses, shares, protects and otherwise processes your personal data. Please read the following carefully to understand SDC’s data practices.

Who does this notice apply to?

This privacy notice applies to all investors of SDC.
Additional details on our processing of European Economic Area (“EEA”) or United Kingdom (“UK”) individuals’ personal data are set out in Annex 1.
Additional details on our processing of Californian individuals’ personal data are set out in Annex 2.

What Data Do We Collect About You and Why?

The personal data we collect about you, and the purposes for which we process it, in connection with the operation of our website and the formation and operation of our private investment funds (“funds”) are:

Data Category	Purpose of Processing
Business contact information: name, address, email, telephone number.	● Administrative processes (and related communication) in preparing for the admission of investors to the fund(s), including administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase interests in the fund(s). ● Performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
Identification information: signature, date of birth, place of birth, citizenship, location of residence, social security number, taxpayer identification number, driver’s license, passport or other government identification and numbers.	● Performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund.
Personal contact details: name, home address, telephone number and email address.	● Performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund.
Tax information: W-8/W-9 tax forms or similar tax classification documentation.	● Compliance with applicable tax laws.
Financial information: assets, income, net worth, amounts and types of investments, risk tolerance, capital account balances, capital commitments, capital contributions, account data, other investment participation information, funds transfer information, beneficiaries, positions, percentages of fund, share or option numbers and values, vesting information, investment history, transaction information, tax status and information.	● Auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance. ● Facilitating the transfer of fund interests, and administering and facilitating any other transaction, between an investor, the general partner or managing member, the investment adviser and/or the fund(s).
Investment information: information about your interest in the relevant investment, including ownership percentage, capital investment, income and losses.	● Auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance. ● Facilitating the transfer of fund interests, and administering and facilitating any other transaction, between an investor, the general partner or managing member, the investment adviser and/or the fund(s).
Technical or account information: electronic device and usage information (for example, from cookies and similar technology as described in our cookies policy), registration information and online account data.	● Maintaining the safety, security and integrity of our website and other products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; ● The administrative processes (and related communication) in preparing for the admission of investors to the fund(s), including administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase interests in the fund(s);
Correspondence information: Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via email and other electronic communications.	● Responding to correspondence from you.

We also process personal data where necessary to respond to and comply with requests and legal demands from regulators, courts, or other authorities in the jurisdictions in which SDC operates.

To Whom Do We Disclose Personal Data?

We do not disclose your personal data to other organizations, except:

Compliance with laws, regulators, authorities and related to legal proceedings. We share personal data with regulators, courts and other authorities (e.g. tax and law enforcement authorities), for legal, protection, and safety purposes, including compliance with applicable laws and regulations, requests from regulators or other authorities, and court orders, as well as to prepare for and participate in legal proceedings and investigations.
Professional advisors. We share personal data with our professional advisers such as lawyers and accountants who need your personal data to provide products and services to us.
Service providers. We share personal data with IT service providers such as Microsoft Office 365 (file storage), Dropsuite (backup and recovery), and eFront Cloud (investor portal).
For business transfers. We may share or transfer your personal data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
With affiliates. From time to time, we share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates may include other companies that we control or that are under common control with us.

What Security is Provided for Your Personal Data?

We employ appropriate administrative, technical and operational safeguards designed to protect the security of personal data submitted to us. These measures are aimed at providing ongoing security, integrity and confidentiality of personal data.

Where Do We Transfer Your Personal Data?

SDC is a global company and as such your personal data may be transferred outside of your country of residence to other countries, including the United States of America, where privacy laws may not be the same as those in your jurisdiction.

How Long Is Your Personal Data Retained?

We retain your personal data only for as long as is necessary for the purposes set out in this privacy notice and to the extent permitted by applicable legal requirements. In general, this will be for the duration of your involvement in any SDC fund and 7 years thereafter.

What Are Your Rights?

To the extent applicable under data protection or privacy laws of your jurisdiction, you may have specific rights in relation to the personal data we hold about you and how that personal data is processed by SDC. If you would like to exercise any rights afforded to you under applicable data protection or privacy laws, please use the contact details set out below.

If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us using the contact details set out below.

Contacting us about this notice.

You can contact us with any questions about this notice through the following addresses:

vrebeiz@sdccapitalpartners.com
jwelling@sdccapitalpartners.com

Changes To This Policy

We will update this privacy notice when necessary to reflect changes in our data processing. When we post material changes to this privacy notice, we will inform you in advance of the changes coming into effect. The most recent version of this policy is available at https://sdccapitalpartners.com/privacy-policy.

Annex 1 – UK and EEA Terms

Scope of this Annex

This Annex applies only to investors or potential investors located in the UK or EEA. The data controller in relation to your personal data is SDC Services Lux S.à r.l.

If you have any questions about our processing of personal data, you can send your question using the contact details set out at the end of this notice.

Legal Basis for Processing

Our legal bases for processing your data are set out in the following table:

*Data Category*	*Legal Basis for Processing*
Business contact information: name, address, email, telephone number.	● Our legitimate interests in administering our funds. ● Our legal obligations in relation to anti-money laundering and know-your-customer requirements.
Identification information: signature, date of birth, place of birth, citizenship, location of residence, social security number, taxpayer identification number, driver’s license, passport, other government identification and numbers.	● Our legal obligations in relation to anti-money laundering and know-your-customer requirements.
Personal contact details: name, home address, telephone number and email address.	● Our legal obligations in relation to anti-money laundering and know-your-customer requirements.
Tax information: W-8/W-9 tax forms or similar tax classification documentation.	● Our legal obligations in relation to tax laws.
Financial information: assets, income, net worth, amounts and types of investments, risk tolerance, capital account balances, capital commitments, capital contributions, account data, other investment participation information, funds transfer information, beneficiaries, positions, percentages of fund, share or option numbers and values, vesting information, investment history, transaction information, tax status and information.	● Our legitimate interests in administering our funds.
Investment information: information about your interest in the relevant investment, including ownership percentage, capital investment, income and losses.	● Our legitimate interests in administering our funds.
Technical or account information: electronic device and usage information (for example, from cookies and similar technology), registration information and online account data.	● Our legitimate interests in operating our website and investor portal.
Correspondence information: Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via email and other electronic communications.	● Our legitimate interests in responding to your queries.

International Transfers

SDC is a global company and as such your personal data may be transferred outside of the European Economic Area (‘EEA’), or United Kingdom (‘UK’), where privacy laws may not be as protective as those in your jurisdiction.

When transferring data outside the EEA or UK, we will take steps that are reasonably necessary so that your personal data is treated securely and appropriately safeguarded in accordance with this privacy notice and applicable data protection or privacy laws. This includes entering the UK or EU’s controller-to-processor or controller-to-controller standard contractual clauses as applicable.

Your Rights

You have the right (subject to certain limitations) to (a) confirm that SDC is processing your personal data, and how; (b) to access or rectify the personal data we keep about you; (c) to request the restriction of, or object to, our processing of your personal data; (d) to request the deletion of your personal data; and (e) in some circumstances, transfer/port any information we hold about you to a specified third party. Where we rely on your consent, you have the right to withdraw it anytime by contacting us using the details below (though this will not affect the lawfulness of any processing undertaken before your withdrawal). You can exercise these rights by contacting us using the address below.

Lodging a complaint

If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us using the contact details set out above. You also have the right to lodge a complaint with the appropriate regulatory body/supervisory authority in the country in which you reside. Contact details are available for EEA data protection authorities are available here, and for the UK here.

Annex 2 – California Terms

This notice supplements the Privacy Notice the (“California Privacy Notice”) set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth above in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers	Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets).	YES
C. Protected classification characteristics under California or federal law	Date of birth, citizenship and birthplace.	YES
D. Commercial information	Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).	YES
E. Biometric information	Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.	NO
F. Internet or other similar network activity	Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries	YES
G. Geolocation data	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. Sensitive Personal Information (see further information on use of sensitive personal information below)	Social security, driver’s license, state identification card, or passport numbers; 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; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.	YES, as to the following types of information: social security, driver’s license, state identification care, or passport numbers, account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only.

We do not collect or use sensitive personal information other than:

To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
To perform services on behalf of our business;
To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

We collect personal information for the business or commercial purposes from the sources set forth in the “What Data Do We Collect About You and Why?” sections in the Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this California Privacy Notice only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.

Disclosure of Information: We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we may have disclosed personal information collected from you for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category	Category of Third-Party Recipients
A. Identifiers	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal law	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
D. Commercial information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
E. Biometric information	N/A
F. Internet or other similar network activity	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
G. Geolocation data	N/A
H. Sensory data	N/A
I. Professional or employment-related information	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	N/A
K. Inferences drawn from other personal information	N/A
L. Sensitive Personal Information	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:

The categories of personal information we collected about you;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting such personal information;
Categories of third parties with whom we disclose the personal information;
The specific pieces of personal information we have collected about you; and
Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request using any of the methods set forth below.

Call us using the following number: (212) 813-6700.

Email us at the following address:

IR@sdccapitalpartners.com

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request your investor portal access credentials in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.