Privacy Policy

This website is intended only for the use of a User; contains information that is privileged and/or confidential; and may not be disseminated or altered. Crystal Capital Partners, LLC (“Crystal,” “we,” or “us”) is an SEC registered investment adviser that provides customized hedge and private equity fund portfolio solutions (“Fund(s)”) to Portfolio Advisors and their clients. Crystal may only transact business or render personalized advice, and offers of service can only be made, in those states or international jurisdictions where Crystal is registered or where an exemption or exclusion from registration is available. Nothing herein is an offer of any service that is not legal or permissible in any particular jurisdiction given Crystal’s current licenses. Crystal is not registered as a securities broker-dealer with the SEC or with any state securities regulatory authority or with any foreign country. Neither the SEC nor any other government agency has endorsed the merits of Crystal’s website, products, services, educational materials, and/or any of the information contained therein. Please also refer to the Terms of Use Agreement and all disclosures on this website, the Fund's Offering Memorandum, LLC Agreement, Articles of Association, and/or the Subscription Agreement (collectively, as applicable, the ""Fund Documents""), including for all terms not defined herein. Crystal respects and values your privacy and wants you to be familiar with how we collect, use, protect, and disclose information from and about you. This Privacy Policy (“Policy”) describes our practices in connection with information collected through our website and other Crystal services. This Policy applies to our collection of personal information (i.e. information that may identify, relate to, describe, references, is capable of being associated with or could reasonably be linked, directly or indirectly, with you or your device). This privacy policy applies to all Users. This Privacy Policy describes how we collect, use, disclose and protect information from and about you through the Site, services, and any other transaction, engagement, or interaction (e.g., customer service and other communications) that you may have with or through Crystal (collectively, the “Services”). PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES. When providing our Services to United States residents, Crystal is considered a “financial institution” pursuant to the federal Gramm-Leach Bliley (GLB) Act, and in such circumstances Crystal shall collect, process, and retain personal information in accordance with the GLB Act and any and all implementing regulations thereto that are applicable to the Services. If you are a customer of Crystal that receives Services from Crystal residing in the United States, please see our Privacy Notice for U.S. Customers (Gramm-Leach Bliley Act (“GLBA”)) (the “Privacy Notice”) for more information about our privacy practices and your choices with respect to data governed by the GLBA.

How Do We Collect Personal Information
• From you. We may collect personal information and other information that you voluntarily provide when taking certain actions, such as when you use our Services, register with Crystal online, sign up for newsletters, or otherwise communicate with us.
• From devices you use when you interact with us online. This includes information collected through our Services and automatically from devices you use to connect to our Services. For more information about this, please see our “Cookies and similar technologies” section below.
• From third parties and publicly available sources. This includes personal information we collect from other public sources including, but not limited to, websites that enable social sharing, social media sites, and from our service providers, third parties, vendors and suppliers, our affiliates, or other individuals and businesses.
• From you in person. This includes information you may give us if you meet with us in person.

Types of Personal Information We May Collect From You
Depending on how you interact with us and our Services, we may collect the following information:
• Contact Information such as name, email address, zip code, phone number, and home address.
• Biographical and Identifying Information such as date of birth, location, and Social Security Number.
• Financial Information such as your income, investment preferences, accounts with us and other financial institutions, as well as other financial details.
• Internet Usage Information such as browsing history, search history, information regarding your interaction with our online services or advertisements, IP address, browser type, log files, recorded sessions, and clickstream data.
• Device information. Such as browser or device model and settings, operating system, and unique identifiers, and the version of the app you're using.
• Inferences such as inferences drawn from any of the personal information we collect to better understand your preferences.
• Account Information such as information you provide when you create an account, like username and password.
• Transaction and Trading Information such as trading activity, holdings information, and information needed to complete your transactions or otherwise provide our Services, such as your bank account information, and your transaction history.
If you submit any personal information relating to other people to us, such as information about other account holders or beneficiaries, you represent that you have the authority to do so and to permit us to use the information in accordance with this policy.

How We May Use Your Personal Information
We may use information you provide us through our online services to:
• Provide, market, and develop our Services. Crystal collects information to provide our Services, maintain our Site, and better understand the interests of our Users, clients and investors who use our Services.
• Process transactions and administer your account. We may use your information to process your transactions and requests, and offer our Services that may be of interest to you.
• Communicate with you. We may use your information to respond to your inquiries and send you communications regarding our Services.
• Develop new Services and quality assurance. We may use personal information to study, develop, and improve our Services. We may also aggregate, anonymize, and/or de-identify personal information we collect and use it for any purpose, including Service development and improvement activities.
• Security and fraud prevention. We may use personal information to monitor, detect, and prevent fraud and improper or illegal activity. It may also be used to investigate any suspected fraud, harassment, or other violations of any law, rule, or regulation, the terms, rules or policies of our online services, or the rights of third parties, or to investigate any suspected conduct which we deem improper. We may also use it to enforce our Terms of Use and any other agreements between you and Crystal.
• Verify your identity and verify our records. We may use personal information to verify your identity for the purposes of responding to a request regarding your personal information that you make. This information may also be used to verify our own records for accuracy.
• Debugging and performance of systems. We may use your personal information to secure our online services including our network and websites and to debug our online services. We may also use it to diagnose problems and ensure that our online services function properly, make our online services easier and more convenient to use, and otherwise administer our online services.
• Comply with law. We may use personal information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigation.
• Internal business purposes. We may use personal information for our internal business purposes, such as data analysis, audits, and enhancing our Services. We may also use inferences drawn from personal information to create a profile reflecting your preferences so we can tailor our Services.
• In accordance with our Services, Privacy Notice, and to enforce our Terms of Use and any other agreements. We may use your information in the ways indicated in our Privacy Notice and to enforce our Terms of Use and any other agreements.

How We Disclose Personal Information
We may disclose personal information in the following ways:
• Crystal Affiliates. Crystal may disclose personal information with Crystal Affiliates for the purposes described in this Privacy Policy.
• Service Providers. We may provide personal information to vendors, contractors, business and service partners, or other third parties who provide services to us including data storage firms, payment companies, technology suppliers, technology services, risk solution providers, and others.
• Government, regulatory, or law enforcement agencies. We reserve the right to disclose your information to respond to valid information requests from government authorities and judicial requests, to investigate potential fraud, or where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
• At your direction. We may disclose your personal information at your direction or with your consent.
• Aggregate Data. We may disclose your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you.
• In connection with a merger, acquisition, or business transfer. If Crystal sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a reorganization, merger, or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), Crystal may transfer or disclose your information to the party or parties involved in the transaction as part of that transaction.

Children's Privacy
You must be 18 years or older to use our Services. Our Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 18 years of age.

Links to Third Party Websites
We may provide links to websites and other third-party content (e.g., social media platforms) that are not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites. If you provide any personal information through a third-party site, your interaction and your personal information may be collected by and will be controlled by the privacy policy of that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.

Advertising and Opt-Out Disclosures
When you use our Services, our third-party advertising partners, social media providers and analytics providers may collect personal information about your online activity on our Services and on third party websites. These providers may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third party websites within their networks. If you would like more information about this practice and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt-out page or the Network Advertising Initiative’s opt-out page. Please note that you may continue to receive generic ads that are not based on your preferences.

Information Security
We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in our possession against loss, theft, unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.

Cookies and Similar Technology
We and our partners use various tools to collect data when you visit our sites and apps, including cookies, pixels, localStorage, and other similar technologies. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited, other content you viewed, and search history. Additionally, we may use these technologies to collect analytics and measure the use of our Services. We and our partners may also use these technologies to gather personal information about how you view and use our Services and content, and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Services. The use of these technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own similar tools. Your web browser can be set to allow you to control these technologies, such as whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting these technologies such as cookies. Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT, we do not currently respond to the DNT signal on our websites.

Your Marketing Preferences
We may periodically send promotional materials or notifications related to our Services. If you no longer wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email. You may unsubscribe from text messages you previously consented to by following the prompt provided on our messages. We will work to comply with your request promptly. There are certain service notifications and other non-promotional emails that you may not opt-out of, such as notifications of changes to our Services or policies.

Suspicious Email
It is our policy not to email you or send you electronic communications to request non-public personal information or account information (such as a username or password). If you receive an unsolicited email or other electronic communication that appears to be from Crystal but you suspect may be from another source and might be fraudulent, please email us at ir@crystalfunds.com or call (305) 868-1500.

Social Media
You may also find additional information on our Services through our social media sites such as Facebook and LinkedIn. Please keep in mind that any information you share is visible to all participants on these social media sites and you should never post any sensitive personal information (such as account number or tax identification). Please carefully review the Terms of Use and Privacy Policy on these social media sites as they may be different than our own policies.

Storage and Protection of Personal Information
Crystal has a dedicated group that designs, implements and provides oversight of information security. We also monitor our systems' infrastructure in order to detect weaknesses and potential intrusions. In order to help secure personal information collected from you as a User, including sensitive financial data, the information is protected by SSL encryption when it is exchanged between your web browser and the Site. However, the Internet is not a fully secure environment, and we cannot ensure or warrant the security of any information transmitted to or generated by Crystal in connection with its Services. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, physical, or other operational safeguards. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information. You agree that you are responsible for any additional verification procedures and security you deem necessary. By using our Services, you agree that the procedures provided for in this Privacy Policy and the procedures implemented on our Services to protect personal information and to verify the identity of Users including, but not limited to, those procedures described in the foregoing paragraph, constitute commercially reasonable website security and User verification procedures.

Notice to Persons Accessing the Site Outside the United States
If you access the Site outside the United States, any information you provide to us through the Site will be transferred out of that jurisdiction and into the United States. If you do not want your personally identifiable information to leave that jurisdiction, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to the United States. Changes to the Policy We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, or advances in technology. We will make the revised Privacy Policy accessible on the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Last Updated” date at the beginning of the document. If we make a material change to the Privacy Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

Updating and Correcting Your Personal Information
Keeping your information accurate and up to date is very important. If your personal or account information is incomplete, inaccurate or not current, please feel free to update your profile accordingly online or contact us at (305) 868-1500.