California Consumer Privacy Act Policy

Effective and last updated: April 5, 2024

INTRODUCTION

This California Consumer Privacy Act Policy (“CCPA Policy”) explains how Rice Park Capital Management LP (collectively, “Rice Park,” “we,” “our,” or “us”) may collect, use, disclose, or retain personal information subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its associated regulations (collectively, the “CCPA”). This CCPA Policy applies solely to California “consumers”, which generally means a natural person who is a California resident as defined under California law. Such persons may be referred to as “California consumer”, “you”, or “your” in this CCPA Policy. If you are not a California consumer, please review our Privacy Policy for information on our privacy practices.

Rice Park may collect, use, and disclose the personal information of its customers in accordance with the federal Gramm-Leach-Bliley Act (“GLBA”) and certain other state or federal laws and regulations. If you are a customer of Rice Park, more information on the personal information we may collect, use, or disclose under those laws and regulations, such as under the GLBA, can be found in the privacy notice most recently sent to you.

NOTICE AT COLLECTION OF PERSONAL INFORMATION

The CCPA defines “personal information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer. Personal information does not include public information that is made lawfully available, deidentified or aggregated information, or lawfully obtained, truthful information that is a matter of public concern.

This notice and the table below identifies the categories of personal information Rice Park may have collected from, used, or disclosed about a California consumer, the categories of sources that personal information may have been collected from, the business or commercial purpose(s) such personal information may have been collected, used, or disclosed, and the categories of third parties with whom a California consumer’s personal information may have been disclosed to in the last 12 months.

Please note: Rice Park does not sell or share the personal information of California consumers to third parties, and only discloses or uses the sensitive personal information of California consumers for the purposes permitted under the CCPA.

Categories of personal information that may be collected, used, and disclosed

Categories of sources that personal information may be collected from

Business or commercial purpose(s) personal information may be collected, used, or disclosed

Categories of third parties with whom personal information may be disclosed

Categories of third parties that personal information may be shared with or sold to

Identifiers

Examples: name, Internet Protocol address, email address, telephone number, a device identifier, or other similar identifiers.

From you directly if you provide this personal information to us.
From your device(s) when you visit our website.
From vendors and business partners.
From counterparties or other third-parties related to a transaction
From government or regulatory entities or agencies.
From government-sponsored entities, such as Fannie Mae or Freddie Mac.

To help ensure security and integrity, including to detect security incidents, protect against malicious, deceptive, or fraudulent activity, and prosecute persons responsible for malicious, deceptive, or fraudulent activity.
Short term, transient use.
To perform services for our business, including maintaining or servicing accounts, providing customer service, verifying customer information, or performing other services for our business.

Vendors and business partners.
Counterparties or other third-parties related to a transaction.
Government or regulatory entities or agencies, law enforcement, or other legal authorities.
Government-sponsored entities, such as Fannie Mae or Freddie Mac.

N/A – Rice Park does not sell or share the personal information of California consumers.

Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e))

Examples: name, address, telephone number, education, employment, or employment history.

From you directly if you provide this personal information to us.
From your device(s) when you visit our website.
From vendors and business partners.
From counterparties or other third-parties related to a transaction
From government or regulatory entities or agencies.
From government-sponsored entities, such as Fannie Mae or Freddie Mac.

To help ensure security and integrity, including to detect security incidents, protect against malicious, deceptive, or fraudulent activity, and prosecute persons responsible for malicious, deceptive, or fraudulent activity.
Short term, transient use.
To perform services for our business, including maintaining or servicing accounts, providing customer service, verifying customer information, or performing other services for our business.

Vendors and business partners.
Counterparties or other third-parties related to a transaction.
Government or regulatory entities or agencies, law enforcement, or other legal authorities.
Government-sponsored entities, such as Fannie Mae or Freddie Mac.

N/A – Rice Park does not sell or share the personal information of California consumers.

Protected classification characteristics under California or federal law

Examples: age, race or ethnicity, national origin, citizenship or immigration status, or marital status.

From you directly if you provide this personal information to us.
From vendors and business partners.
From government or regulatory entities or agencies.
From government-sponsored entities, such as Fannie Mae or Freddie Mac.

To help ensure security and integrity, including to detect security incidents, protect against malicious, deceptive, or fraudulent activity, and prosecute persons responsible for malicious, deceptive, or fraudulent activity.
Short term, transient use.
To perform services for our business, including maintaining or servicing accounts, providing customer service, verifying customer information, or performing other services for our business.

Vendors and business partners.
Government or regulatory entities or agencies, law enforcement, or other legal authorities.

N/A – Rice Park does not sell or share the personal information of California consumers.

Geolocation data

Example: Approximate geolocation of a website visitor.

From you directly if you provide this personal information to us.
From your device(s) when you visit our website.
From vendors and business partners.

To help ensure security and integrity, including to detect security incidents, protect against malicious, deceptive, or fraudulent activity, and prosecute persons responsible for malicious, deceptive, or fraudulent activity.
Short term, transient use.
To perform services for our business, including maintaining or servicing accounts, providing customer service, verifying customer information, or performing other services for our business.

Vendors and business partners.
Government or regulatory entities or agencies, law enforcement, or other legal authorities.

N/A – Rice Park does not sell or share the personal information of California consumers.

Internet or other electronic network activity information:

Example: Information regarding your interaction with our website.

From you directly if you provide this personal information to us.
From your device(s) when you visit our website.
From vendors and business partners.

To help ensure security and integrity, including to detect security incidents, protect against malicious, deceptive, or fraudulent activity, and prosecute persons responsible for malicious, deceptive, or fraudulent activity.
Short term, transient use.
To perform services for our business, including maintaining or servicing accounts, providing customer service, verifying customer information, or performing other services for our business.

Vendors and business partners.
Government or regulatory entities or agencies, law enforcement, or other legal authorities.

N/A – Rice Park does not sell or share the personal information of California consumers.

Audio, electronic, visual, or similar information

Example: Audio recordings of voicemails you leave us.

From you directly if you provide this personal information to us.
From vendors and business partners.

To help ensure security and integrity, including to detect security incidents, protect against malicious, deceptive, or fraudulent activity, and prosecute persons responsible for malicious, deceptive, or fraudulent activity.
Short term, transient use.
To perform services for our business, including maintaining or servicing accounts, providing customer service, verifying customer information, or performing other services for our business.

Vendors and business partners.
Government or regulatory entities or agencies, law enforcement, or other legal authorities.

N/A – Rice Park does not sell or share the personal information of California consumers.

Professional or employment-related information and history, and education information

Example: current employer and job title.

From you directly if you provide this personal information to us.
From vendors and business partners.

To help ensure security and integrity, including to detect security incidents, protect against malicious, deceptive, or fraudulent activity, and prosecute persons responsible for malicious, deceptive, or fraudulent activity.
Short term, transient use.
To perform services for our business, including maintaining or servicing accounts, providing customer service, verifying customer information, or performing other services for our business.

Vendors and business partners.
Government or regulatory entities or agencies, law enforcement, or other legal authorities.

N/A – Rice Park does not sell or share the personal information of California consumers.

Sensitive Personal Information:

Example: Personal information that reveals a consumer’s Social Security, driver’s license, state identification card, or passport number, or immigration or citizenship status.

From you directly if you provide this personal information to us.
From vendors and business partners.

To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
For short-term, transient use.
To perform services for our business, including maintaining or servicing accounts, providing customer service, verifying customer information, or performing other services for our business.

Vendors and business partners.
Government or regulatory entities or agencies, law enforcement, or other legal authorities.

N/A – Rice Park does not sell or share the personal information of California consumers.

Commercial Information

Example: Records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies

From you directly if you provide this personal information to us.
From vendors and business partners.
Counterparties or other third-parties related to a transaction.

To help ensure security and integrity, including to detect security incidents, protect against malicious, deceptive, or fraudulent activity, and prosecute persons responsible for malicious, deceptive, or fraudulent activity.
Short term, transient use.
To perform services for our business, including maintaining or servicing accounts, providing customer service, verifying customer information, or performing other services for our business.

Vendors and business partners.
Counterparties or other third-parties related to a transaction.
Government or regulatory entities or agencies, law enforcement, or other legal authorities.

N/A – Rice Park does not sell or share the personal information of California consumers.

RETENTION OF PERSONAL INFORMATION

Rice Park may retain personal information for different periods of time. The retention period is dependent on the reason why the personal information was collected and how it will be used. Unless applicable law requires otherwise, Rice Park will exercise commercially reasonable efforts to delete or deidentify personal information when it is no longer needed to fulfill the applicable business purpose(s) the information was collected for. If we are unable to fully delete or deidentify such personal information due to technical or operational reasons, Rice Park will take commercially reasonable measures to prevent further usage of such personal information.

CALIFORNIA CONSUMER RIGHTS

Subject to certain exceptions, California consumers have the following rights under the CCPA with respect to their personal information:

The right to know what personal information we have collected, used, or disclosed about you, including the categories of personal information, the categories of sources from which we collected personal information, the business or commercial purpose(s) for collecting, using, disclosing, selling, or sharing personal information (if applicable), the categories of third parties to whom we disclose personal information (if applicable), and the specific pieces of personal information we collected about you;
The right to delete personal information that we collected from you;
The right to correct inaccurate personal information that we maintain about you;
If we sell or share personal information, the right to opt out of the sale or sharing of such information;
If we use or disclose sensitive personal information for purposes other than those specified by the CCPA, the right to limit our use or disclosure of such information; and
The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

HOW TO SUBMIT A REQUEST TO KNOW, DELETE, AND/OR CORRECT

California consumers, and their authorized agents, may submit a request to know, delete, and/or correct by emailing us at businessadmin@riceparkcapital.com or by calling us toll free at (833) 981-5595.

When you submit a request to know, delete, and/or correct, we will attempt to verify your identity using reasonable measures. To do so, we will request for you to provide us with information and attempt to match that information with other sources of similar information we may possess. Depending on the sensitivity of the information that is the subject of your request, we may utilize more stringent identification measures to verify your identity. If an authorized agent submits the request on your behalf, we will also request the authorized agent to provide proof of their authority to act on your behalf.

We will attempt to process and respond to requests within 45 days after receipt. If we require additional time beyond 45 days, we will inform you of that and the extension period. If we determine that your request is subject to an exemption or exception, we will notify you in writing of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request following completion of the above-referenced identity verification process.

As mentioned above, Rice Park may collect, use, and disclose the personal information of its customers in accordance with the GLBA and certain other state or federal laws and regulations. If you are a customer of Rice Park, more information on the personal information we may collect, use, or disclose under those laws and regulations, such as under the GLBA, can be found in the privacy notice most recently sent to you.

RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION

California consumers have the right to direct businesses to stop selling or sharing their personal information with third parties. As stated above in the NOTICE AT COLLECTION OF PERSONAL INFORMATION section, we do not sell or share the personal information of California consumers to third parties.

RIGHT TO LIMIT USE OF SENSITIVE PERSONAL INFORMATION

California consumers have the right to limit the use or disclosure of sensitive personal information if a business uses it for purposes other than those permitted under the CCPA. We do not use or disclose sensitive personal information of California consumers for purposes other than those permitted by the CCPA, which are described in the NOTICE AT COLLECTION OF PERSONAL INFORMATION section above.

INFORMATION SECURITY

We maintain commercially reasonable security measures to protect the personal information we collect and store from loss, misuse, destruction, or unauthorized access, use, disclosure, or exposure. However, no security measure or data transmission over the Internet is 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control and (b) security, integrity, and privacy of any and all information and data exchanged between you and us cannot be guaranteed.

THIRD PARTY LINKS

This website may contain links that will let you leave the website and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.

CHILDREN’S PRIVACY

Our website is not intended for children under 16 years of age. We do not knowingly collect, use, sell, share, or otherwise disclose personal information from children under the age of 16. If you are under the age of 16, you must ask your parent(s) or guardian(s) for permission to use this website.

ACCESSIBILITY

We are committed to ensuring this CCPA Policy is accessible to individuals with disabilities. If you are using a screen reader or other auxiliary aid and are having problems viewing this CCPA Policy, please contact us via email at businessadmin@riceparkcapital.com.

CHANGES TO THIS CCPA POLICY

From time to time, we may update this CCPA Policy. If we do, we will note near the top of this page the date that any changes went into effect.

HOW TO CONTACT US

If you have questions or concerns regarding our privacy policies or practices, you may contact us by emailing us at businessadmin@riceparkcapital.com or by calling us toll free at (833) 981-5595.