Privacy Policy Notice

Information BPEA Collects

Brooke Private Equity Associates Management, LLC (“BPEA”) collects nonpublic personal information (“Personal Data”) about individuals that are investors in the investment funds and accounts that are managed, directly or indirectly, by BPEA (the “Funds”) from the following sources:

  • Information received from investors on subscription agreements, partnership agreements and other forms; and
  • Information about investors’ transactions with BPEA and their investments in the Funds.

How BPEA Uses Personal Data

BPEA does not disclose Personal Data about individuals who are current or former investors to anyone, except as permitted by law. BPEA may disclose such information to its affiliates and to third parties that perform services for BPEA. For example, BPEA may forward such information to its accountants to complete financial statements and maintain accounting records or to lenders that provide financing for the Funds’ investments.  Furthermore, consistent with industry practice and the provisions of BPEA’s Fund agreements, BPEA may distribute certain personally identifiable information, such as the schedule of investors, to all investors in each specific Fund.

BPEA also may disclose Personal Data about current or former investors obtained from subscription agreements, partnership agreements and other forms (such as the investors’ names, contact information and financial profiles) to companies that perform marketing services on BPEA’s behalf or to other financial institutions, such as broker-dealers and placement agents with whom BPEA has agreements in connection with offering new and existing Funds.

BPEA restricts access to Personal Data about individuals who are investors in the Funds to those employees and service providers that use such information in connection with the offering, formation and operation of new and existing Funds or managing and servicing investor accounts. BPEA maintains physical, electronic and procedural safeguards that comply with federal guidelines to protect nonpublic personal information.

California Privacy Rights Disclosures

Collection, Disclosure and Use of Personal Data: The categories of Personal Data BPEA has collected in the preceding twelve months are described above in the “Information BPEA Collects” section. In the preceding twelve months, we have disclosed Personal Data for business purposes as described in the “How BPEA Uses Personal Data” section. The business purposes for collecting Personal Data are also described in the “How BPEA Uses Personal Data” section. BPEA collects Personal Data directly from you.

Privacy Rights: Where provided for by law and subject to any applicable exceptions, California residents may have the following rights under the California Consumer Privacy Act of 2018 (“CCPA”:

  • The right to know what Personal Data we have collected and how we have used and disclosed that Personal Data;
  • To access the specific pieces of Personal Data that BPEA has collected about you;
  • To have BPEA, under certain circumstances, delete your Personal Data; and
  • To be free from discrimination related to the exercise of these CCPA rights.

BPEA does not sell your Personal Data.

This Privacy Policy Notice is provided on behalf of BPEA and the Funds, including, without limitation, any Fund in which the recipient of this Privacy Policy Notice invests, has invested or intends to invest. BPEA will notify individuals that are investors in the Funds of its Privacy Policy annually. BPEA reserves the right to modify this Privacy Policy Notice at any time, but investors can always review the current Privacy Policy Notice by contacting BPEA for a copy.