Privacy Policy - arclight

ArcLight Capital Partners, LLC and its affiliates (together, “ArcLight,” “our,” “us” or “we”) recognizes and respects the privacy expectations of our customers. We provide this notice (the “Privacy Notice”) to you so that you will know what kinds of information we collect about our customers and the circumstances in which that information may be disclosed to third parties who are not affiliated with our private investment funds (or “funds”).

Collection of Customer Information

We collect personal information about our customers from the following sources:

Subscription Agreements, Investor Questionnaires and other forms, which may include a limited partner’s name, address, social security number and personal financial information;
Account History, including information about the limited partner’s capital account, such as capital contributions, profit and loss allocations and distributions and withdrawals;
Transactions with the Funds, including information we receive and maintain relating to new issues and other securities transactions with and through the funds and their respective affiliates; and
Correspondence, written, telephonic or electronic, between a customer and a fund or service providers to such fund.

Among other sources, we may also collect this information through our website.

Disclosure of Customer Information

We may disclose all of the information that we collect, as described above, to our affiliates in order to service your account or provide you with information about other products and services that may be of interest to you. In addition, we may disclose all of the information that we collect to certain third parties who are not affiliated with our funds under one or more of the following circumstances:

As Authorized – if you request or authorize disclosure of the information.
As Required by Law – for example, to cooperate with regulators or law enforcement authorities.
As Permitted by Law – for example, disclosing information to companies that maintain, process or service customer accounts or financial products and services or effect, administer or enforce customer transactions is permitted. Among other activities, we may disclose information to our funds’ prime broker in order to execute customer trades or to custodians that hold securities on behalf of customers. We may also disclose this information to persons acting in a representative or fiduciary capacity on behalf of a customer. We believe that disclosure of information for these purposes is essential to providing customers with necessary or useful services with respect to their accounts.
Under Joint Agreements – we may also disclose information to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.

Security of Customer Information

ArcLight will:

maintain policies and procedures designed to assure only appropriate access to information about customers of our funds;
limit the use of information about our funds’ customers to the purposes for which the information was disclosed, or as otherwise permitted by law; and
maintain physical, electronic and procedural safeguards that comply with federal standards to guard personal information about our customers.

Except as permitted by law, we require all nonaffiliated third-party service providers to whom we disclose personal information about our funds’ customers to enter into confidentiality agreements with us. In addition, we limit the information we provide them to only what is necessary to process transactions and perform other services related to your account.

Former Customers of our Funds

We will adhere to the policies and practices described in this Privacy Notice regardless of whether you are a current or former customer of one or more of our funds.

If you have questions regarding these policies, please contact us by writing to ArcLight Capital Partners, LLC, 200 Clarendon Street, 55th Floor, Boston MA 02117, Attention: Christina Kenny, or by calling 617-531-6300.

California Privacy Notice

This notice (the “California Privacy Notice”) supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018 (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	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 card, 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.

Use of Sensitive Personal Information

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.

Purposes for Collecting Personal Information

We may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes:

Performing services to you and our other investors, including:
- the administrative processes (and related communication) in preparing for the admission of investors to the fund(s);
- ongoing communication with investors and potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting investors to the fund;
- the performance of obligations under the governing documents of the funds and regulatory requirements (including all applicable anti-money laundering, know-your-customer and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
- ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of ArcLight and the funds (including their portfolio companies) in accordance with its policies, governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
- keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including at the request of an investor or offering opportunities to make investments other than to the applicable fund and related advertising;
auditing and verifications related to investor interactions, including verifying the quality and effectiveness of services and compliance;
investigating any complaints, or pursuing or defending any claims, proceedings or disputes against ArcLight or the funds (including their portfolio companies);
monitoring communications to/from ArcLight and its funds (to the extent permitted by law);
creating, improving and developing ArcLight’s website and other products and systems;
detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
seeking other professional advice or services; and
complying with ArcLight’s internal policies as well as with U.S., state, local and non-U.S. laws, rules and regulations applicable to us, our funds, our portfolio companies and our counterparties.

Retention of Personal Information

We collect personal information from the sources set forth in “Collection of Customer Information” 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.

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))
C. Protected classification characteristics under California or federal law
D. Commercial information
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	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.

Rights under the CCPA

Deletion Rights

You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

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 over the last twelve (12) months. 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 to 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 Rights

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. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

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.

Email us at: compliance@arclightcapital.com
If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at the email address above, and we will call you between 9 a.m. and 6 p.m. Eastern Time.

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. Please contact the Chief Compliance Officer of ArcLight Capital Partners, LLC at 617-531-6300 with any questions about this California Privacy Notice.

EEA-UK Privacy Notice

This EEA-UK Privacy Notice (this “EEA-UK Privacy Notice”) applies if, and to the extent that, EEA-UK Data Protection Legislation (as defined below) applies to the processing of personal data by an Authorized Entity (as defined below). If this EEA-UK Privacy Notice applies, the data subject has certain rights with respect to such personal data, as outlined below. For this EEA-UK Privacy Notice, “EEA-UK Data Protection Legislation” means all applicable legislation and regulations relating to the protection of personal data in force from time to time in the European Union (the “EU”), the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), including (without limitation): the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and the GDPR as it forms part of the laws of England & Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union Withdrawal Act 2018 (UK) (“UK GDPR”), and any other national implementing or successor legislation and any amendment or re-enactment of the foregoing. The terms “data controller”, “data processor”, “data subject”, “personal data”, and “processing” in this EEA-UK Privacy Notice shall be interpreted in accordance with the applicable EEA-UK Data Protection Legislation. Unless the context otherwise requires, as used herein the words “include,” “includes” and “including” shall be deemed to be followed by the phrase “without limitation.” All references to “investor(s)” in this EEA-UK Privacy Notice shall be to such actual or potential investor(s) and, as applicable, any of such investor(s)’ partners, officers, directors, employees, shareholders, members, managers, ultimate beneficial owners and affiliates. Please contact the Chief Compliance Officer of ArcLight at compliance@arclight.com with any queries arising out of this EEA-UK Privacy Notice.

Sources of Personal Data

In connection with offering, forming and operating private investment funds for potential investors, the applicable fund, its general partner (the “General Partner”), ArcLight, their affiliates and, in each case, their respective administrators, legal and other advisors and agents (the “Authorized Entities”) collect, record, store, adapt and otherwise process and use personal data, either relating to potential investors or to their partners, officers, directors, employees, shareholders, ultimate beneficial owners or affiliates or to any other data subjects, including from the following sources (and all references to “potential investor(s)” in this EEA-UK Privacy Notice shall be to such potential investor(s) and, as applicable, any of these other persons as relate to such potential investor(s)):

information received in telephone conversations, during video or audio conferences (which may be recorded or transcribed) in voicemails, through written correspondence, via email or on subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification and verification documentation);
information about transactions with any Authorized Entity or others;
information captured on any Authorized Entity’s website, fund data room and/or investor reporting portal (as applicable) including registration information and any information provided through online forms and any information captured via “cookies” (or similar technology);
information containing photographic images and/or specimen handwriting; and
information from available public sources, including from:
- publicly available and accessible directories and sources;
- bankruptcy registers;
- tax authorities, including those that are based outside the UK and/or the EEA if you are subject to tax in another jurisdiction;
- governmental and competent regulatory authorities to whom any Authorized Entity has regulatory obligations;
- credit agencies; and
- fraud prevention and detection agencies and organizations.

Categories of Personal Data Collected

The Authorized Entities may process the following categories of personal data:

names, date of birth, birth place, gender, citizenship and marital status;
contact details including tax, residential and professional addresses (such as physical address, email address, telephone and fax number);
account data and other information contained in any document provided by potential investors to the Authorized Entities (whether directly or indirectly), including IBAN and BIC Codes and bank account information;
information regarding your use of our website, fund data room and/or investor reporting portal (e.g., cookies, browsing history and/or search history);
risk tolerance, transaction history, assets, liabilities, net worth, investment experience and investment activity;
association with other entities, including in particular association with publicly traded companies;
information regarding a potential investor’s status under various laws and regulations, including their national insurance, social security or similar number, tax status, income and assets;
accounts and transactions with other institutions;
information regarding a potential investor’s interest in the applicable fund(s), including ownership percentage, capital investment, income and losses and any other confidential information relating to a potential investor;
details relating to immediate family members or senior political figures to whom potential investors may be connected;
tax forms such as the W-8-IMY and accompanying withholding statements;
source of funds used to make the investment in the applicable fund(s);
client communications via electronic or other means, telephone conversation recordings, video and audio conferences; and
anti-money laundering, know-your-customer, identification (including identity card, passport and drivers’ license and in certain cases, utility bill) and verification documentation, PEP status and power of attorney.

As part of its compliance with legal obligations such as anti-money laundering requirements, the Authorized Entities may be required to process special categories of personal data (as defined in the EEA-UK Data Protection Legislation), including personal data relating to political opinions as well as criminal convictions and offences data. Any Authorized Entity may, in certain circumstances, combine personal data it receives from a potential investor with other information that it collects from, or about, such potential investor. This will include information collected in an online or offline context. In addition, personal data of investors could be processed and controlled irrespective of whether such investor is admitted to any fund as a limited partner. One or more of the Authorized Entities are “data controllers” of personal data collected in connection with the applicable fund(s). In simple terms, this means such Authorized Entities: (i) “control” the personal data that they or other Authorized Entities collect from potential investors or other sources; and (ii) make certain decisions on how to use and protect such personal data.

Purpose of Processing and Lawful Bases for Processing

Purpose for Processing	Legal Basis for Processing
(a) The performance of obligations under and/or in connection with the Fund Agreement, side letter (if any) and/or the subscription agreement for such fund (the “Subscription Agreement”) (and all applicable anti-money laundering, know-your-customer and other related laws and regulations), including in connection with assessing suitability of potential investors in the applicable fund.	The processing is necessary: pursuant to applicable legal obligations; and/or as a matter of contractual necessity.
(b) The administrative processes (and related communication) carried out between the Authorized Entities in preparing for the admission of potential investors to the applicable fund.	The processing is necessary as a matter of contractual necessity.
(c) Ongoing communication with potential investors (including in relation to the negotiation, preparation and execution of documentation) during the process of admitting potential investors to the applicable fund.	The processing is necessary: as a matter of contractual necessity; and/or for the purposes of the Authorized Entities’ legitimate interests.
(d) The ongoing administrative, accounting, reporting and other processes and communications required to operate the business of the Authorized Entities (including any website, data rooms and/or portals) and including in accordance with the Fund Agreement and other applicable documentation between the parties.	The processing is necessary: pursuant to applicable legal obligations; as a matter of contractual necessity; and/or for the purposes of the Authorized Entities’ legitimate interests.
(e) Any legal or regulatory requirement.	The processing is necessary: pursuant to applicable legal obligations; and/or for the purposes of the Authorized Entities’ legitimate interests.
(f) Keeping potential investors informed about the business of the General Partner and its affiliates generally, including offering opportunities to make investments other than to the applicable fund.	The processing is necessary for the purposes of the Authorized Entities’ legitimate interests.
(g) Monitoring communications between potential investors and the Authorized Entities, where required to do so, to comply with regulatory rules and practices and, where permitted to do so, to protect the Authorized Entities’ respective businesses and the security of their respective systems.	The processing is necessary: pursuant to applicable legal obligations; and/or for the purposes of the Authorized Entities’ legitimate interests; and/or where the data subject has given consent to the processing of their personal data for the specific purpose.
(h) Audio and video recordings and transcripts (including AI powered transcripts) of telephone calls, video conferences and meetings.	The processing is necessary: pursuant to applicable legal obligations; and/or for the purposes of the Authorized Entities’ legitimate interests.
(i) Any other purpose for which notice has been provided, or has been agreed to, in writing.	The processing is necessary: pursuant to applicable legal obligations; and/or as a matter of contractual necessity; and/or for the purposes of the Authorized Entities’ legitimate interests; and/or where the data subject has given consent to the processing of their personal data for the specific purpose.

From time to time, an Authorized Entity may need to process personal data on other legal bases, including: if it is necessary to protect the vital interests of a potential investor or other data subjects; or if it is necessary for a task carried out in the public interest. To the extent that an Authorized Entity processes personal data relating to political opinions of data subjects having a public political exposure, such personal data is processed on the basis that it is personal data which has manifestly been made public by the data subject and/or is necessary for reasons of substantial public interest. A failure to provide the personal data requested to fulfill the purposes described in this EEA-UK Privacy Notice above may result in the applicable Authorized Entities being unable to provide the services in connection with the terms of the Fund Agreement and/or the Subscription Agreement.

Sharing and Transfers of Personal Data

In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where permitted by EEA-UK Data Protection Legislation, to other actual or potential investors, service providers (such as administrators, depositaries, etc.), portfolio companies, custodians, administrators, transfer agents, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfill the purposes described in this EEA-UK Privacy Notice, as well as any third party that acquires, or is interested in acquiring or securitizing, all or part of the Authorized Entities’ assets or shares, or that succeeds to it in carrying on all or a part of its businesses, or services provided to it, whether by merger, acquisition, reorganization or otherwise. In addition, any Authorized Entity may share personal data with regulatory bodies having competent jurisdiction over them, as well as with judicial bodies, national registers, tax authorities, auditors and tax advisers (where necessary or required to comply with law). Any Authorized Entity may transfer personal data to the United States or any Non-Equivalent Country (as defined below), in order to fulfill the purposes described in this EEA-UK Privacy Notice and in accordance with EEA-UK Data Protection Legislation, including where such transfer is a matter of contractual necessity to enter into, perform and administer the Subscription Agreement and Fund Agreement, and to implement requested pre-contractual measures. Such transfer of personal data may be made further to applicable adequacy decisions (such as the adequacy decisions issued by the European Commission and UK Government), on the basis of legitimizing measures permitted under EEA-UK Data Protection Legislation (including Article 46 of the GDPR/UK GDPR (as applicable)) such as entering into standard contractual clauses approved by the European Commission or the UK Government from time to time, binding corporate rules or permitted derogations under Article 49 of the GDPR/UK GDPR (as applicable). For information on the safeguards applied to such transfers, please contact the General Partner. For the purposes of this EEA-UK Privacy Notice, “Non-Equivalent Country” shall mean a country or territory other than (i) a member state of the EEA; or (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the UK Government and/or the UK Information Commissioner’s Office (as applicable) in accordance with EEA-UK Data Protection Legislation to ensure an adequate level of protection for personal data.

Retention and Security of Personal Data

The Authorized Entities consider the protection of personal data to be a sound business practice, and to that end, employ appropriate technical and organizational measures taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity of the potential investor’s rights, including robust physical, electronic and procedural safeguards to protect personal data in their possession or under their control (such as pseudonymization and encryption of personal data, imposing appropriate confidentiality obligations, ensuring the integrity and resiliency of systems, carrying out regular testing, etc.). Personal data may be kept for no longer than is necessary with regard to the purposes described in this EEA-UK Privacy Notice or as long as is required to comply with applicable legal or regulatory obligations or where necessary to defend or pursue legal claims. Personal data will be retained throughout the life cycle of any investment in a fund managed by ArcLight. However, some personal data will be retained after a data subject ceases to be an investor in such fund.

Data Subject Rights

It is acknowledged that, subject to applicable EEA-UK Data Protection Legislation, the data subjects to which personal data relates may have the following rights under EEA-UK Data Protection Legislation:

Right to withdraw consent: if the lawful bases for the processing of personal data is the data subject’s consent, the data subject has the right to withdraw consent given in relation to the processing of their personal data at any time. This will not affect the lawfulness of processing based on consent before its withdrawal;
Right of access: if the data subject requires, the Authorized Entities will confirm whether they are processing personal data and, if so, will provide the data subject with a copy of their personal data;
Right to rectification: if personal data of the data subject is inaccurate or incomplete, the data subject is entitled to ask for correction or completion of their personal data;
Right to erasure: the data subject has the right to require the deletion of their personal data, such as when personal data is no longer necessary for the purpose or the data subject withdraws consent (if applicable). Please note that the right to erasure is not absolute, and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation.
Right to object: the data subject has the right to (i) object at any time, on grounds relating to the data subject’s particular situation, to the processing of personal data when the processing is based on the legitimate interest basis in the circumstances described above, unless the controllers demonstrate compelling legitimate grounds for the processing, and (ii) object to the processing of personal data for direct marketing (if applicable).
Right to data portability: in certain circumstances, the data subject has the right to obtain personal data that the data subject consented to provide or that is necessary to perform the Fund Agreement and that is processed by automated means, in a structured, commonly used machine-readable format;
Right not to be subject to automated decision-making: the data subject has the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the investor or similarly affects the data subject; and
Right to lodge a complaint with a data protection authority: if the data subject has a concern about processing of personal data under this EEA-UK Privacy Notice, the data subject has the right to report it to the data protection authority that is authorized to hear those concerns, including in the EU and the UK.

A data subject may raise any request relating to the processing of his or her personal data with ArcLight at the contact information provided above.

Changes to the EEA-UK Privacy Notice

The Authorized Entities reserve the right to update this EEA-UK Privacy Notice from time to time and an updated version will be made available.