Introduction

Thackeray Partners (“we,” “our,” or “us”) is committed to protecting the confidentiality and security of the nonpublic personal information (“NPI”) we collect about our investors. This Privacy Notice explains the types of information we collect, how we use and share that information, and the steps we take to safeguard it, as required by federal law, including the Gramm–Leach–Bliley Act (“GLBA”) and Securities and Exchange Commission (“SEC”) Regulation S-P. 

We provide this notice to you upon establishing an investment relationship and annually thereafter. 

Information We Collect 

We collect NPI about you in the course of providing advisory services and processing your investment in a private fund that we manage. This information may include: 

• Name, address, email address, and telephone number Social Security number or taxpayer identification number 

• Date of birth 

• Net worth, income, total assets, investment experience, and risk tolerance 

• Source of funds and wire instructions 

• Employment and background information 

• Information contained in subscription documents, investor questionnaires, and other materials you provide 

We collect this information from discussions with you, from documents you provide, and from your transactions and interactions with us or our service providers. 

How We Use and Share Your Information 

We use NPI only for business purposes, including: 

• Processing your subscription and transactions 

• Maintaining your account 

• Administering and operating the private funds we advise 

• Responding to regulatory inquiries, court orders, or other legal obligations 

• Facilitating audits, tax reporting, and compliance functions 

Third Parties With Whom We May Share Information 

We may disclose NPI to nonaffiliated third parties that assist us in providing services, such as: 

• Fund administrators 

• Accountants and auditors 

• Attorneys and legal advisors 

• Regulatory compliance consultants 

• Information technology and cybersecurity providers 

These service providers are required to maintain the confidentiality of your information and to use it only for the purposes for which it is provided to them. 

No Sharing That Requires an Opt-Out 

We do not: 

• Share your NPI with affiliates for marketing purposes 

• Allow nonaffiliates to use your information to market their products or services 

• Share information about your creditworthiness with affiliates 

Because we do not share NPI in ways that would give you the right to “opt out” under GLBA or Regulation S-P, no opt-out is required or offered. 

Affiliates 

We currently do not share NPI with any affiliates for any purpose other than as permitted by law. 

(If this changes, we will provide an updated notice.) 

How We Protect Your Information 

We maintain physical, electronic, and procedural safeguards designed to protect your NPI and ensure its secure handling. These measures include: 

• Restricting access to personnel who need the information to perform their duties 

• Confidentiality obligations in employee and service-provider agreements 

• Secure information-technology systems, encryption tools, and cybersecurity protocols 

• Compliance policies and periodic reviews of our safeguarding controls 

We continue to adhere to these practices even after you cease to be an investor. 

Former Investors 

If you cease to be an investor in a private fund we manage, we will continue to safeguard your information and will not share it except as permitted or required by law. 

Questions 

If you have any questions about this Privacy Notice or our privacy practices, please contact: 

Rob Bennett 

Phone: 214-360-7864 

Email: rob.bennett@thackeraypartners.com