Your California Privacy Rights
June 30, 2020
Light Street Capital Management, LLC (“we” or “Light Street”) provides this statement of its practices regarding any personal information (as defined below) that is processed by Light Street including by visiting our websites and personal information provided by email and/or telephone interactions with investors and potential investors who are California residents subject to the California Consumer Privacy Act or CCPA (such individuals, “You”). Where your details are provided to us as a consequence of your investment (or potential investment) in an Light Street-managed investment fund (a “Fund”) or your interest in Light Street (e.g., by contacting Light Street to request information about a Fund), then Light Street (or a third party service provider) may collect, use and share your personal information or, if you are an entity, that of your (i) beneficial owners, (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity.
CCPA. In 2018, California passed a new law called the California Consumer Privacy Act (CCPA). The contours of the law are still being sorted out and we are making our best attempt at interpreting it as of the date of this policy. If the CCPA is applicable to us and to you, you have the right to:
1. know the categories of personal information collected about you in the prior 12 months and its sources and business purpose;
2. know whether your personal information is sold or disclosed, and to whom, in prior 12 months;
3. access and then delete your personal information (subject to exceptions).
Sale; Non-Discrimination. We do not sell your personal information or discriminate in how we provide services based on your exercise of your privacy rights.
Definition. “Personal Information” is defined under CCPA to include information that identifies, relates to, describes, or is capable of being associated with a particular consumer or household.
Personal Information that we collect. In the year prior to the date of this notice, Light Street collected Personal Information from the following sources, as applicable:
1. Subscription documents and other information provided by the Investor in writing, in person, by telephone, electronically or by any other means (this information includes (i) name, address, income, financial and investment qualifications, and tax-related information and (ii) identification information that the Funds are required to obtain for anti-money laundering purposes, including, for example, in the case of individuals, birth date, nationality, passport or other identification number, and employment information, or in the case of entities, date and jurisdiction of formation, entity type, tax identification number, and business information);
2. Transactions within the Fund, including account balances, investments, redemptions and management fees and performance allocations;
3. Discussions and other communications with Light Street’s staff and information Light Street receives from third parties who refer Investors who may be interested in the Funds to Light Street; and
4. Technical information about your use of Light Street’s website, and the portals that the Fund’s administrators provide through Light Street’s website, such as Investors’ IP addresses, and other interactions with Light Street’s staff, representatives and service providers.
Light Street retains Personal Information for a minimum of 6 years or for so long as required for Light Street to perform services to Investors, to comply with legal or regulatory requirements or for other legitimate business purposes.
Personal information that we share. We share personal information with various service providers, and data that is subject to CCPA and that is shared will be subject to a CCPA service provider addendum, restricting the service providers from selling your personal information or using it for purposes other than as allowed under CCPA. These service providers include our data processing and data storage vendors and our electronic mail and website hosting vendor. We also share data that is protected under different laws, such as federal law, with the funds’ administrators such as Morgan Stanley Fund Services USA LLC, its affiliates and Standish Management, LLC (together, the “Administrators”).
Collecting and using Personal Information is necessary for Light Street and/or the Administrators to fulfill their legitimate business interests, which may include to satisfy contractual obligations to Fund Investors or otherwise perform the services described below, to investigate, defend against, or prosecute any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum, or otherwise protect their legal rights; and as necessary to comply with any applicable regulatory, judicial or other legal obligation.
Light Street and the Administrators acting at the request of Light Street use your Personal Information, and may share your Personal Information for the following purposes, as applicable:
1. To facilitate your investment in a Fund and the management and administration of your investment in such Fund on an ongoing basis (the “Services”) which are necessary to fulfill all contractual and regulatory obligations related to your investment in the Fund, including without limitation the acceptance and processing of subscription documents and redemption and transfer requests, and otherwise as needed to provide the services you request the us to provide;
2. To carry out anti-money laundering checks and related actions which Light Street and/or Administrators consider appropriate or necessary to fulfill any of their legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with Light Street’s and the Administrators’ anti-money laundering policies and procedures;
3. To comply with their legal obligations and, in particular, to report tax-related information to tax authorities;
4. To disclose information to other third parties such as service providers of Light Street and/or Administrators (including, for example, attorneys, accountants, auditors, other professionals, and communication, technology and data storage service providers), regulatory authorities, to comply with any legal obligation imposed on Light Street and/or Administrators or in order to pursue the legitimate interests of Light Street and/or Administrators;
5. To monitor, record and distribute communications related to Light Street (including registration with us or with a Fund Administrator for access to the specific portals of fund information available through Light Street’s website), your investment in a Fund or for any of the purposes specified herein; and/or
6. To otherwise pursue the legitimate interests of Light Street and/or Administrators relating to your investment or your potential investment in a Fund or your other interactions with us, and/or where the use of your Personal Information would be in the public interest.
Verification Process for Access or Deletion of your personal information. If you would like to access or delete your personal information, we must, where data is identifiable, verify your identity as the requester. Our verification process is to have you confirm data that is unique to you in our records, such as approximate full name, investment value, and zip code. In many instances, we will be required by law to keep your data, and in those cases you do not have a right under CCPA to have your data deleted.
Agents. If you would like to exercise your access or deletion rights through an agent, please (a) provide the agent legally sufficient power-of-attorney documentation establishing the agent’s rights to act on your behalf, or (b) (1) Provide the authorized agent signed permission to do so; (2) Verify your own identity directly with us as provided above; and (3) Directly confirm with us that you provided the authorized agent permission to submit the request.
Requests for Access or Deletion and Questions About this California Rights Statement. Contact us at firstname.lastname@example.org or call collect at +1 (650) 234-1640 if you have questions or concerns about this statement or would like to request access or deletion of your personal information.