Privacy Policy

Updated: 6/9/2025

Eagle Rock Advisors LLC (“Company,” “us,” our” or “we”) welcomes its users and respects their privacy. This Privacy Policy informs you of our policies and practices regarding the collection, use, access, storage and disclosure of any Personal Information (as defined below) you submit to us and/or we collect about you online through your use of the Services, why we collect it, how we use it, and when we share it with third parties. This Privacy Policy also describes the choices you can make about how we collect and use certain of that information. The Personal Information provided by you is not used for any purpose other than as outlined in this Privacy Policy. Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use1. This Privacy Policy is part of, and incorporated into, the Terms of Use.\

By accessing and using the Services you consent to our collection, storage, use and disclosure of your Personal Information and other information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not provide any Personal Information to us. If you choose not to provide any Personal Information that is necessary for us to provide you with specific products or service, we may not be able to provide those products or services to you. In addition, for certain products or services, we may further confirm your consent by asking you to expressly consent to the collection, processing, storage and use of your personal information according to this Privacy Policy.\

This Privacy Policy applies to visitors and users of our website (the “Website”), and any other features, content, or services offered from time to time by us in connection with the Website (collectively, the “Services”), and set forth the legally binding terms for your use of our Services. This Privacy Policy applies only to information collected on or through our Website and Services and does not include information collected through any other means, including, without limitation, information collected offline, in person, and/or by mail. Because we use Google Maps API, you also agree to Google’s Privacy Policy.

This Website is primarily intended to provide information to and collect inquiries from prospective investors. While we may collect certain personal and financial information in connection with evaluating or onboarding investors, this generally occurs outside of the Website through secure data rooms or third-party platforms, such as our fund administrator.

1. Types of Information We Collect

a. Personal Information that we collect about you. We collect Personal Information about our users. “Personal Information” is information relating to an individual that can be used to contact or identify you or other individuals associated with your investment inquiry or participation, including: name, email address, phone number, address, date of birth, Social Security number, tax ID, employment and financial information, bank account details, wire instructions, and information related to identity verification. Such information may be collected directly from you or via our third-party fund administrator (e.g., Alter Domus) or other secure channels. We do not collect this information through public browsing of the Website.

b. “Aggregated Information”. After stripping out any information that directly identifies you, or directly relates to you, from the Personal Information that we collect about you, we may combine that information with information we collect about other users.

c. Cookies. We use first-party cookies that are strictly necessary for the operation of our Website, as well as performance and analytics cookies to understand how visitors interact with the Website. We do not use functionality or advertising/targeting cookies. All analytics are anonymized and processed through Google Analytics 4. No third-party cookies are used on the Website.

d. Unique Device Identifiers. Like most website providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system.

e. User-Provided Information. We collect information you provide through forms on the Website, email, or phone communications, such as when you inquire about investment opportunities, request information, or submit documentation to assess investment eligibility. Additional sensitive information, including financial data and SSNs, may be requested via secure channels when required to comply with legal obligations or to complete onboarding and verification processes.

We may correlate this information with other Personal Information we have about you. We collect e-mail lists and information related to marketing services. When you use the Website, you may be given the option to subscribe to our subscription or e-mail list. Whether or not you select this option, your Personal Information may be shared with third parties consistent with this Privacy Policy. You may opt-out or unsubscribe from these e- mail lists.

f. Information Collected via Technology.

Information Collected by Our Servers. To make our Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
Information About Your Mobile Device. If you use our Services on your mobile device, we may collect your Sensor’s battery level, the version of iOS used by your device, the serial number and firmware version of your Sensor, the signal strength of your mobile device, notifications regarding errors related to your Sensor or mobile device, your test results, and other relevant diagnostics that come from syncing the sensor with your mobile device, such as temperature and time of readings.
Log Files. As is true of most websites and applications, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp.
Geolocation. If you access the Services through a desktop or mobile device, we will collect, monitor and/or remotely store geo-location data.
Our Website includes an embedded Google Maps feature to display location information. Your use of this feature may result in limited data being collected by Google. Please refer to Google’s Privacy Policy for more information.\

g. Third-Parties. We may also obtain information from other sources and combine that with information we collect directly. For example:

We may also collect information about you from third parties, including but not limited to identity verification services, fraud detection service providers, credit bureaus, publicly available sources, and other third-party service providers.
We use third-party services, such as Google Analytics to track and analyze online behavior of our Users. We do this to better understand how you use the Website and Service, with a view to offering improvements for all Users, and to tailor our business and marketing activities accordingly.
When you interact with us through social media networks, such as when you follow us, share content or contact us through social media platforms (e.g. Facebook, Twitter, Instagram, YouTube, and Snapchat) or other websites, we may receive information about you, including your profile information, picture, user ID associated with the social media account, friends list, and any other information you permit the social media network to share with third parties. The data we receive is dependent upon your privacy settings with the social network or website in question.

h. Third-Party Fund Administration. We may collect or receive Personal Information in connection with your investment activity, including through third-party fund administration platforms such as Alter Domus. This information may include your Social Security number or tax identification number, financial account details, capital contribution amounts, and identity verification materials. These providers act on our behalf and are subject to appropriate confidentiality and data protection obligations. Where you interact directly with third-party platforms (e.g., fund administrators or investor portals), those parties may maintain separate privacy policies governing your use of their services. We encourage you to review such policies carefully.

2. How We Use Your Information

a. Personal Information. We may use your Personal Information for the following representative purposes:

Send communications and administrative e-mails
Verify investor eligibility and accredited investor status
Satisfy regulatory obligations, including anti-money laundering (AML) and Know Your Customer (KYC) requirements
Process capital commitments, distributions, and other financial transactions
Prepare tax documents and compliance reports
Confirm wire instructions and prevent fraudulent transfers
Process information uploaded by you to and through the Services
Satisfy our contractual obligations to you
Provide the materials, goods and/or services that you request
Send you promotional/marketing information, newsletters, events information, offers or other information from us or on behalf of our sponsors or partners
Prepare reports on rental activity, availability and property performance
Personalize and tailor the features, performance and support of the Services
Analyze, benchmark and conduct research on user data and interactions with the Services
Analyze the use of our products and services and information about users of the Services to enhance our marketing efforts
Communicate with you by e-mail, video conferencing, telephone, text message or other means about our company, our products, events, collaborations, or other information that we believe may be of interest to you
Provide others with your Personal Information for the limited purposes described in this privacy policy
Send you notices of a transactional, administrative or relationship nature, or as required by law

b. Aggregated Information. We may use Aggregated Information for the following representative purposes:

Perform internal operations on the Services
Improve the Website and customize the user experience
Aggregate the information collected via Cookies to use in statistical analysis to help us track trends and analyze patterns

3. Lawful Processing; Legitimate Interests

Our processing of your Personal Information for the purposes set out in this Privacy Policy is necessary for one or more of the following:

Performing a contract with you, or to take steps at your request prior to contracting with you
Protecting your vital interests or the interests of another person
Complying with our legal obligations
Complying with securities laws, tax reporting obligations, anti-money laundering (AML) and Know Your Customer (KYC) requirements under applicable federal and state laws, including the Bank Secrecy Act and Internal Revenue Code.
Pursuing our legitimate interests, including without limitation:
- Providing, improving and customizing our Services;
- Administration of our operations;
- Exploring ways to develop and grow our business;
- Ensuring the safety and security of our employees and others;
- Cybersecurity;
- Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
- Meeting our obligations and enforcing our legal rights

4. How We Share and Disclose Personal Information

a. We will not rent, sell or share your Personal Information with third parties except as described herein. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to use the Services or provide your Personal Information at any time. If you choose not to provide any Personal Information that is necessary for us to accept you into our programs or to provide you with specific products or services, we may not be able to provide those programs, products or services to you.

b. We may disclose your Personal Information to outside individuals and/or companies that help us bring you the services and products we offer, and to create, operate, and maintain the Services. For example, we may work with third-parties to: (a) manage a database of investors and investor information; (b) manage your investment agreement(s); (c) as necessary to comply with applicable laws (e.g., Americans with Disabilities Act and applicable data privacy and security laws and regulations); (d) assist us in distributing e- mails; (e) assist with direct marketing and data collection; (f) process payments, (g) provide data storage and analysis; (h) provide fraud prevention; (i) provide customer service; and (j) provide other services designed to assist us in developing and running our Website and/or Services and maximizing our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us. However, we do not control these third parties’ data usage and security and our use thereof is subject to the applicable third parties’ terms of use and privacy policies.

c. We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Use, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

d. Information we collect from our users, including Personal Information, may be shared or transferred (subject to standard confidentiality arrangements) with or to outside individuals and/or companies in connection with the operation of our business (e.g., with lenders, appraisers, investors, advisers, consultants, etc.) and/or in connection with a business transaction, such as an acquisition, sale, merger, asset sale, bankruptcy, dissolution, reorganization, sale of some or all of the Company’s assets or stock, financing, or other business transaction of the Company.

e. We may share all or some of your Personal Information with any of our subsidiaries, investors, joint venturers, or other companies under common control, in which case we will require them to honor this Privacy Policy. Additionally, in the event we undergo a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any entity that acquires us, is merged with us or that acquires our assets may continue to process your Personal Information as set forth in this Privacy Policy. We may share your Personal Information with our parent entities, subsidiaries, affiliated investment funds, and related operating entities for purposes such as investment administration, compliance, and internal reporting.

5. Use of Aggregated Information

a. We use Aggregated Information to maintain and administer the Website, analyze trends, gather demographic information and comply with applicable law. We may share Aggregated Information with third-parties. We may share this information with others without express notice to you or consent from you, and we may, subject to applicable laws, exploit, use and disclose Aggregated Information without limitation of any kind. We authorize certain service providers to utilize Aggregated Information for their business purposes and in accordance with their privacy policies, such as to report on usage or industry trends to their customer base.

b. We use Google Analytics 4 to collect anonymized information about how users interact with our Website. This helps us improve site performance and user experience. We do not use cookies for behavioral advertising, retargeting, or cross-site tracking, and no user data is shared with ad platforms. Our implementation includes IP anonymization and honors applicable browser privacy signals via Google’s Consent Mode. The Services may contain links to and/or enable certain third-party functionalities to enhance your experience on or with the Services, including social plug-ins, tools and APIs. Prior to using any third-party functionalities (e.g., Facebook “Like” button) on the Website, you should consult the privacy notices of the third-party providers of such functionalities (e.g., Facebook). The privacy policies and data practices of such third parties may significantly differ from ours, and we make no representation or warranty whatsoever about their policies and practices in respect of their own processing of your Personal Information. Your communications and interactions with such third parties in respect of their own processing of your Personal Information are solely between you and them and are at your own risk.

We do not currently use a cookie banner; however, Google’s Consent Mode is enabled and respects “Do Not Track” and other browser privacy settings.

6. Data Retention

We retain information submitted via the Website contact form only as long as necessary to respond to your inquiry. It is stored in our internal email inbox and not retained in any backend databases or third-party systems through the Website.

7. Opting-Out

Since we do not use advertising or retargeting cookies, there is no need for most users to opt out. However, you may choose to disable cookies through your browser settings. You can also opt out of Google Analytics by visiting Google’s Opt-Out Tool.

8. BASIS FOR CONTINUED USE OF YOUR PERSONAL INFORMATION

Please note that, in certain cases, we may continue to process your Personal Information after you have withdrawn consent and requested that we delete your Personal Information, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure. Furthermore, if we have already disclosed your Personal Information to third-parties pursuant to the terms of this Privacy Policy, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.

9. Notice to Californian Users Regarding Your Privacy Rights

a. Shine the Light. Pursuant to California Civil Code Section 1798.83, also known as the "Shine The Light" law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third-parties. We do not share Personal Information with third parties for those parties’ direct marketing. To request the above information, California residents can e-mail us at contact us via e-mail at privacy@eaglerockmanagement.com or by writing to us at Eagle Rock Advisors LLC, Attn: Privacy Office, 1670 Old Country Road Suite 227 Plainview, New York 11803. Please note that, under California law, a business is only required to respond to such a request twice in any calendar year.

b. Access To Specific Information and Data Portability Rights. You have the right, subject to certain exceptions defined in the California Consumer Privacy Act, Cal. Civ. Code §1798.100 et. seq. (“CCPA”), and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your personal information over the past 12 months. This right to know includes information about:

the categories of personal information we collected about you;
the categories of sources for the personal information we collected about you;
our business or commercial purpose for collecting that personal information;
the categories of third parties with whom we share that personal information;
the categories of personal information that each recipient received; and
the specific pieces of personal information we collected about you.

c. Deletion Request Rights. You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your personal information that it has collected from you and retained, subject to certain exceptions.

d. Exercising Access, Data Portability, And Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by e-mailing us at privacy@eaglerockmanagement.com.

The verifiable consumer request must:

Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected personal information. This may include requesting that you provide us with at least two or more pieces of personal information to match against personal information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

e. Do Not Sell Rights. You have the right to opt out of the sale or sharing of your personal information. We do not sell your personal information in exchange for money. We do not currently share personal information including identifiers and commercial data with advertising platforms (e.g., Google, Meta) for the purposes of targeted advertising and audience creation. This may be considered a 'share' under California and other state privacy laws. While we don’t engage in this type of data sharing, you may opt out of this type of data sharing by following the instructions in Section 7 and this Section 9, using recognized browser signals (e.g., Global Privacy Control), or by contacting us at privacy@eaglerockmanagement.com.

We may deny a Do Not Sell request if we have a good-faith, reasonable, and documented belief that the request is fraudulent.

f. Authorized Agent. Only you, or a person you have designated in writing as your authorized agent, or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465, (“Authorized Agent”), may make a verifiable consumer request or do not sell request related to your personal information. You may also make a verifiable consumer request or do not sell request on behalf of your minor child.

If you wish to have an Authorized Agent make a request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

g. Non-Discrimination. You have the right not to receive discriminatory treatment for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

deny you services;
charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
provide you a different level or quality of services; or
suggest that you may receive a different price or rate for services or a different levelor quality of services.

To the extent required by applicable law, California residents may ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may contact us as specified in the Contact Us section of this Online Privacy Notice.

h. Do Not Track. Some web browsers may let you enable a "do not track" feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a "do not track" feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to "do not track" signals, although one may develop in the future. While we do not respond to browser initiated “Do Not Track” signals, we do recognize Global Policy Control (GPC) signals as a valid opt-out request where required by law.

10. Additional U.S. State Privacy Rights

A. As with California residents, residents of Colorado, Connecticut, Florida, Montana, Oregon, Utah, and Virginia may have certain rights under their respective state privacy laws. These may include:

Right to access personal information
Right to correct inaccuracies
Right to delete personal information
Right to opt out of targeted advertising
Right to data portability
Right to appeal a denied request

To exercise these rights, please email us at privacy@eaglerockmanagement.com. You may also authorize an agent to submit a request on your behalf. We will take reasonable steps to verify your identity before processing your request. If we deny your request, you have the right to appeal our decision. You may do so by contacting us at privacy@eaglerockmanagement.com with the subject line “Appeal of Privacy Rights Request.”

For information about your rights under California law, please refer to Section 9 above.

B. Notice to Nevada Users. Nevada law allows Nevada consumers to “opt out” of the sale of their personal data (referred to as “covered information” under the Nevada law) to third parties. “Covered information” includes your name, address, social security number, and online service activity. A “sale” is defined as the exchange of covered information for monetary consideration by the website operator to a person for that person to then license or sell the covered information to additional persons. We do not sell this information to third parties, so no opt-out is required. If you are a Nevada consumer and wish to request additional information, please e-mail us at privacy@eaglerockmanagement.com or by writing to us at Eagle Rock Advisors LLC, Attn: Privacy Office, 1670 Old Country Road Suite 227 Plainview, New York 11803.

11. NOTICE TO NON-U.S. DATA SUBJECTS

If you are a non-U.S. user of the Services and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less or more stringent than the laws in your country. By providing your data, you consent to such transfer.

12. Children

The Services are not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Services are targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a User is under 13 years of age we will take steps to remove that User’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at contact us via e-mail at privacy@eaglerockmanagement.com or by writing to us at Eagle Rock Advisors LLC, Attn: Privacy Office, 1670 Old Country Road Suite 227 Plainview, New York 11803 so that we may delete and remove such information from our system.

13. Security

We strive to keep your Personal Information private and safe. We employ all reasonable administrative, physical and electronic measures designed to protect your information from unauthorized access. Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Website, any transmission of Personal Information by you is at your own risk. We cannot guarantee that such information will not be intercepted by third-parties and we shall not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for circumvention of any privacy settings or security measures contained on the Website. Where we collect or process sensitive financial information such as Social Security numbers or banking details, we do so through encrypted channels and secure platforms, and only for legitimate purposes associated with investment management and regulatory compliance. We require our vendors and service providers to implement security measures consistent with industry standards for handling such data.

The Website uses HTTPS encryption to protect data in transit. Submissions through the contact form are routed directly to our internal email inbox and managed through our CMS platform, TinaCMS. Access to both the Website and any submitted data is restricted to select authorized Company personnel.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email and/or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Although guaranteed security does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. Your consent to such purpose remains valid after termination of our relationship with you.

14. Third-Party Websites

While visiting the Website, you may link to websites operated by third parties, or you may have come to the Website using a link found in another website. We do not make any representations or warranties about any third-party website, we have no control over them or the information, services, products they provide or the manner or methods they employ to collect, store, access, or otherwise use your Personal Information. If you provide Personal Information at one of those websites, you are subject to the privacy policy of the operator of that website, not our Privacy Policy. Please make sure you understand any other website's privacy policy before providing Personal Information.

We may link to a third-party investor portal for account management. We do not control authentication, data storage, or account access within that portal. Please review the investor portal provider’s privacy policy to understand how your data is handled once you leave our Website.

15. GLBA Privacy Disclosure

Certain personal information we collect in connection with investment activities may be subject to the Gramm-Leach-Bliley Act (GLBA) and related financial privacy rules. Where applicable, we provide separate notices that govern our use and sharing of nonpublic personal financial information. This Privacy Policy supplements, but does not replace, those financial privacy notices.

16. Changes to Our Privacy Policy

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted. However, we will not use your Personal Information in a way that is adverse and materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. The “Last Modified” date indicates if and as of when changes have been made to this Privacy Policy. Your continued use of the Website and Services after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended.

17. Contact Us

If you have any questions regarding our Privacy Policy, or if you wish to issue a request to exercise your rights where applicable by law, you can contact us via e-mail at privacy@eaglerockmanagement.com or by writing to us at Eagle Rock Advisors LLC, Attn: Privacy Office, 1670 Old Country Road Suite 227 Plainview, New York 11803.