The term 'Orchard Holdings' or 'Orchard Holdings Group, LLC' or 'us' or 'we' refers to the owner of the website whose registered office is 8044 Montgomery Rd,, Suite 480, Cincinnati, Ohio 45236. The term 'you' refers to the user or viewer of our website.
Our Commitment to Your Privacy:
Orchard Holdings Group, LLC and its affiliated entities (including any investment funds or vehicles) (collectively, “we,” “us” and “our”) are sensitive to your privacy concerns. We have a policy of protecting the confidentiality and security of information we collect about you. We are providing you this notice to help you better understand why and how we collect certain personal information, the care with which we treat that information, and how we use that information.
Sources of Non-Public Information:
We use the personal information collected from you in order to provide you with better service or to comply with law and regulations. In connection with forming and operating our private investment funds, we collect and maintain non-public personal information from the following sources:
Disclosure of Information:
- Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e- mail, or on subscription agreements, investor questionnaires, partnership agreements, applications or other forms (for example, name, address, Social Security number, assets and income);
- Information about your transactions with us or others, including ownership records of the fund(s) in which you are a subscriber (such as the amount of your percentage ownership interest and any capital commitment).
- Information captured on our website, including any information captured via “cookies.”
We may disclose non-public personal information we collect about you to our affiliates and to nonaffiliated service providers only as permitted by law and regulation. For example, we may share non-public personal information about you in the following situations:
- In connection with the administration and operations of the fund of which you are a subscriber, including disclosure to attorneys, accountants, auditors, administrators, companies that assist us with mailing statements or processing your transactions, and other professionals;
- In connection with investment activities, including disclosure to portfolio companies, co-investors in portfolio companies and their respective advisors and financial service providers (such as broker-dealers, custodians, banks and others used to facilitate transactions for our private funds)
- To respond to a subpoena or court order, judicial process or regulatory inquiry; and
- At your direction or with your consent, including upon your authorization to disclose such information to persons acting in a fiduciary or representative capacity on your behalf.
If you are a citizen or resident of the European Union (“EU
”) or the European Economic Area (“EEA
”), we will ensure appropriate safeguards are in place as required by applicable law to adequately protect your personal information if it is processed by third parties outside the EU and EEA, including the execution of standard contractual clauses if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission).
Rights Under the General Data Protection Regulation (“GDPR”) for Citizens of the EU or the EEA and under the California Consumer Protection Act (“CCPA”) for Residents of California:
Citizens of the EU or the EEA and residents of California have certain specific rights provided under the GDPR and CCPA, respectively. For personal data that we collect about you, we hereby notify you that you have the following rights:
Rights to Opt Out:
- Delete Persona Data: You can ask us to erase or delete all or some of your personal data (i.e., if it is no longer necessary to provide services to you) unless otherwise restricted by law or regulation.
- Right to Rectification: You also have the right to ask us to change, update or fix your personal data in certain cases, particularly if it is inaccurate.
- Object to, or Limit or Restrict Use, of Personal Data: You can ask us to stop using all or some of your personal data (i.e., if we have no legal right to keep using it) or to limit our use of it (i.e., if your personal data is inaccurate or unlawfully held).
- Right to Access and/or Take Your Data: You can ask us for a copy of your personal data, a copy of personal data you provided and personal data disclosed to a third party. You may request your personal information up to 12 months preceding your request.
- Non-Discrimination: You have the right not to be subject to discriminatory treatment from us as a result of the exercise of your privacy rights.
You have the right to direct us to not disclose non-public information about you to nonaffiliated third parties if its disclosure is beyond rendering services to you. Limiting our disclosure of such information may limit the services we are able to provide to you. We will not share your non-public information unless compelled to do so by order of a court or in response to a subpoena.
To limit our sharing of your non-public information, please contact us at 513-754-3500 or email@example.com.
We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your non-public personal information in our possession or under our control. We restrict access to non-public personal information about you to those employees who need to know that information to provide products or services to you.
We reserve the right to change our privacy policies and this Privacy Notice at any time. This notice is effective from April 2022.
The examples contained within this notice are illustrations only and are not intended to be exclusive. This notice complies with United States federal law regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you.
Former Investors and Clients:
When you are no longer an investor or client, we continue to maintain your non-public personal information and apply the same policies that apply to our current investors and clients.