Privacy Policy

GenNx360 Management Company LLC (together with its affiliates, “GenNx360”, “we”, “our” and “us”) takes seriously the privacy of visitors to our website (www.gennx360.com) (the “Site”).  This policy statement (”Policy”) tells you how we collect information from you when you access the Site, and how we use it.  Your use of the Site constitutes your acceptance of the terms of this Policy.   IF YOU DO NOT ACCEPT THESE TERMS, DO NOT USE THE SITE.

If you are an investor or representative of an investor in one or more of the private funds we manage, please see the privacy notice available in our investor portal which sets forth our policies with respect to the collection, sharing and protection of non-public personal information of the funds’ investors.  In addition, service providers to our investor portal (which may be accessed via a link on this Site) have polices that also apply to the information collected or transmitted via the investor portal.  Such service provider policies are available in the investor portal.  The statements in this Policy refer to the portions of the Site that are accessible by the general public, and not the investor portal.  We may in the future adopt additional privacy notices or similar disclosures related to specific categories of individuals with which we interact in connection with our business.

When using this Site, you may be afforded the option to furnish us directly with your name, company and e-mail address for purposes of joining a mailing list.  We do not currently allow users of the Site to directly provide us with other personal information via the Site.   Unless disclosed otherwise at the time of collection, the information we collect is used for our internal purposes only and is not intentionally shared with other organizations other than as may be required for our everyday business purposes if we engage or transact (or are considering engaging or transacting) with you in connection with such purposes, such as to process transactions, to maintain any account or relationship you have with us or to enable us to comply with legal or regulatory obligations.  We do not sell your personal information to non-affiliates for them to market to you.  We may, however, share personal information you provide to us to companies that perform marketing services on our behalf, such as any placement agent that one of our funds may retain.  In such instance, we enter into arrangements to require such third parties to treat your private information confidentiality.  When you provide any personally identifying information to us, you affirm that you are knowingly and voluntarily providing us the information.  If you wish to change or update any personal information previously provided to us, or to be removed from any mailing list or limit emails received from us, you should send us an e-mail addressed to crojas@gennex360.com with the changes or request.  Applicable state laws may give you additional rights.

When individuals access the Site, we may also automatically collect certain other information about the computer or device used by such visitors, such as the IP address, location information, unique device indicators and other information about the computer or device used, browser type, mobile network information, information related to referring and exiting web pages and URLs, pages and content viewed on the Site, statistical information about the use of the Site, error logs and other information.  Such information collected is used to help improve the features, information and services we may choose to make available through the Site, for research and analytical purposes, to administer and improve the performance and security of the Site and for other internal business purposes.  We may use third-party analytics providers and technologies (such as those provided via Google Analytics), including cookies and similar tools, to assist in collecting this information.  A cookie is a small text file that is placed on your computer or device when you visit a website.  A cookie allows us to know that a specific computer or device has accessed the Site, understand web pages that the visitor to the Site visited, perform analytics related to visitors to the Site and assist with security administrative functions for the Site.  You may be able to change the settings on your computer or device to notify you when a cookie is being set or updated or to block cookies.  To do so, you should consult the help section of the particular browser you use.  You may also be able to restrict Google Analytics from using your information via a browser add-on available from Google.
   
Our Site is not intended for users under the age of 18.  Furthermore, we have no intention of collecting personally identifiable information from children under the age of 13.  If a child has furnished personally identifiable information to us via this Site, that child's parent or legal guardian should contact us at crojas@gennex360.com if they would like the information submitted by the child to be deleted from our records.  We will use all reasonable efforts to delete any such information from our records. 

As noted above and in our Terms of Use, users of our Site should be aware that there may be references or links to other websites or services maintained by third parties (including providers utilized by us to maintain the investor portal) that we do not or are beyond our control.  These other sites or services may collect data or solicit personal information and have their own separate policies relating to such activities.  You should review the privacy policies and other applicable terms and conditions of any third-party websites or services that may be referenced or linked to via the Site.  Without limiting the foregoing, you should not assume that GenNx360 controls, endorses or has reviewed any third-party website, resource, service, information or content even if referenced or linked to via the Site. 

Please also note that we reserve the right to access and/or disclose personal and non-personal information we gather as required by law and to the extent required to permit us to investigate any suspected conduct which we may deem improper. 

To protect your personal information from unauthorized access and use, we use certain administrative, technical and physical security measures.  These measures may vary based on the sensitivity of the information that we collect and store.  GenNx360 cannot and does not guarantee that these measures will prevent every unauthorized attempt to access, use or disclose your information, as dispute our efforts, no internet and/or electronic transmissions can be completely secure. 

We may evaluate and change our policies with respect to how we collect and use your personal information as described herein.  Any changes will be posted on the Site and you should check this page periodically for any updates.  

If you have any questions regarding this Policy, please contact us at crojas@gennx360.com.  

This Policy was last updated October __, 2020.

 

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