PRIVACY NOTICE[1]
We are providing this privacy notice (the “Privacy Notice”) in compliance with Regulation S-P under the Gramm-Leach-Bliley Act (the “Privacy Rules”). This Privacy Notice explains the manner in which Alpine Management Services III, LLC and Affiliates (“Alpine”) collects and uses personal information about, or in connection with, our investors.
Sources of Information: In connection with forming and operating our private investment funds (or “funds”) for our investors, we collect and maintain personal information about our investors from the following:
(a) Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via email and other electronic communications, or on subscription agreements, investor questionnaires, limited partnership agreements or other forms or contracts (including, without limitation, any anti-money laundering, identification and verification documentation), such as name, address and social security number;
(b) Information about your transactions with us or others; and
(c) Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms including registration information and any information captured via “cookies.”
Disclosure of Information: Alpine is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. We only disclose personal information we receive from you (i) to third parties, including affiliates, agents and other investors, if it is necessary or appropriate for the effective management and administration of the investment funds in which you invest, (ii) to service providers (but only to the extent permitted by law), (iii) with your consent or as directed by you and (iv) as required by law. These disclosures include ones made to:
(a) Financial service providers, such as broker-dealers, placement agents, custodians, banks, lenders and others used to facilitate transactions for our funds;
(b) Other service providers, such as legal, consulting, administration, accounting, auditing or tax preparation services and placement agents;
(c) Other partners of our funds in connection with closing documentation, financial statements and other reports or other partner communications; and
(d) Transfer agents, portfolio companies, brokerage firms and the like, in connection with distributions to our partners.
Alpine has always considered the protection of sensitive personal information to be a sound business practice and we intend to continue to guard the privacy of our investors. We do maintain records of the information provided by our former investors and apply the same policies to them that apply to current investors. We restrict access to personal information about you to those employees who need to know that information to provide services to you. We maintain physical, electronic and procedural safeguards, which seek to guard the personal information that we have obtained from you.
Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time. The examples contained within this Privacy Notice are illustrations only and are not intended to be exhaustive. This Privacy Notice is intended to comply with the privacy provisions of applicable U.S. federal law and certain privacy provisions of other laws.
Further Jurisdictional Privacy Notices: You may have additional rights under other foreign or domestic laws that may apply to you, including as set forth in our additional privacy notices (which supplement this Privacy Notice). In particular, if you are a resident of California, please refer to the California Privacy Notice, and if and to the extent the EEA-UK Data Protection Legislation (as defined in the GDPR Privacy Notice) applies to you, please see the GDPR Privacy Notice.
CALIFORNIA PRIVACY NOTICE
This notice (the “California Privacy Notice”) supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (together with its implementing guidelines and regulations, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth above in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
Categories of Personal Information We Collect: We collect or have collected within the last twelve (12) months some or all of the following categories of personal information from individuals:
Category | Examples | Collected |
A. Identifiers | Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number). | YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets). | YES |
C. Protected classification characteristics under California or federal law | Date of birth, citizenship and birthplace. | YES |
D. Commercial information | Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s). | YES |
E. Biometric information | Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. | NO |
F. Internet or other similar network activity | Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries | YES |
G. Geolocation data | Physical location or movements. | YES |
H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
I. Professional or employment- related information | Current or past job history or performance evaluations. | YES |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
L. Sensitive Personal Information (see further information on use of sensitive personal information below) | Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. | YES, as to the following types of information: social security, driver’s license, state identification care, or passport numbers, account log-in, financial account in combination with any required security or access code password, credentials allowing access to an account only, or geolocation data. |
We do not collect or use sensitive personal information other than:
- To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
- As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
- As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
- For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
- To perform services on behalf of our business;
- To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
Purposes for Collecting Personal Information: We may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes:
- performing services to you, including but not limited to:
- the administrative processes (and related communication) in preparing for the admission of investors to the fund(s), including administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase interests in the fund(s);
- ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund and the execution of all relevant agreements;
- the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
- ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
- keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
- facilitating the execution, continuation or termination of the contractual relationship between an investor and the general partner or managing member, the investment adviser and/or the fund(s);
- facilitating the transfer of fund interests, and administering and facilitating any other transaction, between an investor, the general partner or managing member, the investment adviser and/or the fund(s);
- auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
- maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
- enabling any actual or proposed assignee or transferee of the fund(s), to evaluate proposed transactions;
- facilitating business asset transactions involving the funds; and
- complying with U.S., state, local and non-U.S. laws, rules and regulations.
We collect personal information from the sources set forth in “Sources of Non-Public Information” in the Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this California Privacy Notice only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.
Disclosure of Information: We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
Within the last twelve (12) months, we have disclosed personal information collected from you for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
Personal Information Category | Category of Third-Party Recipients |
A. Identifiers | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, cloud software providers and placement agents. |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, cloud software providers and placement agents. |
C. Protected classification characteristics under California or federal law | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, cloud software providers and placement agents. |
D. Commercial information | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, cloud software providers and placement agents. |
E. Biometric information | N/A |
F. Internet or other similar network activity | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, cloud software providers and placement agents. |
G. Geolocation data | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, cloud software providers and placement agents. |
H. Sensory data | N/A |
I. Professional or employment-related information | N/A |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | N/A |
K. Inferences drawn from other personal information | N/A |
L. Sensitive Personal Information | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, cloud software providers and placement agents. |
Rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting such personal information;
- Categories of third parties to whom we disclose the personal information;
- The specific pieces of personal information we have collected about you; and
- Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this California Privacy Notice in an alternative format, please submit a request on your behalf using any of the methods set forth below.
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number either (1) through the following online form https://resources.alpineinvestors.com/privacy-contact; (2) by email at the following address privacy@alpineinvestors.com; or, (3) at the following toll-free telephone number 1-800-388-4662, and we will call you between 9 a.m. and 6 p.m. Pacific Time.
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request your investor portal access credentials in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive our response, we will pause processing your request until such verification is received.
Please contact privacy@alpineinvestors.com with any questions about this Privacy Notice.
GDPR PRIVACY NOTICE
This GDPR Privacy Notice applies to the extent that EEA-UK Data Protection Legislation applies to the processing of personal data by an Authorized Entity (as defined below). If this GDPR Privacy Notice applies, the relevant data subject has certain rights with respect to such processing of their personal data, as outlined below.
For this GDPR Privacy Notice, “EEA-UK Data Protection Legislation” means all applicable legislation and regulations relating to the protection of personal data in force from time to time in the EU, the EEA, or the UK, including (without limitation): (a) Regulation (EU) 2016/679 (the General Data Protection Regulation); (b) the General Data Protection Regulation as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union Withdrawal Act 2018; and (c) any other legislation which implements any other current or future legal act of the EU, the EEA or the UK concerning the protection and processing of personal data and any national implementing or successor legislation, and including any amendment or re-enactment of the foregoing. The terms “controller”, “processor”, “data subject”, “personal data” and “processing” in this GDPR Privacy Notice shall be interpreted in accordance with the applicable EEA-UK Data Protection Legislation.
All references to “investor(s)” or “potential investor(s)” in this GDPR Privacy Notice shall be to such actual or potential investor(s) (who may or may not be admitted to the Fund as a limited partner) and, as applicable, any of such investor(s)’ authorized representatives, partners, officers, directors, employees, shareholders, members, managers, ultimate beneficial owners and affiliates and other data subjects.
Please contact Dorothy Walter, CFO of Alpine Investors at dwalter@alpineinvestors.com with any queries arising out of this GDPR Privacy Notice.
Controllers of personal data
In connection with offering, forming and operating private investment funds for potential investors, the Alpine funds (each, a “Fund” and together, the “Funds”), their general partners, Alpine and their respective affiliates, and, in each case, their administrators, legal and other advisors and agents (the “Authorized Entities”) collect, record, store, adapt, and otherwise process and use personal data relating to potential investors.
One or more of the Authorized Entities are “controllers” of personal data collected in connection with the applicable Fund(s). In simple terms, this means such Authorized Entities: (i) “control” the personal data that they or other Authorized Entities collect from potential investors or other sources; and (ii) make certain decisions on how to use and protect such personal data.
Sources of personal data collected
The Authorized Entities collect personal data about investors from the following sources:
(a) information received in telephone conversations, in voicemails, through written correspondence, via e-mail, or on subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation);
(b) information about transactions with any Authorized Entity or others;
(c) information captured on any Authorized Entity’s website, data room, investor reporting portal, including registration or online form information and any information captured via “cookies” and/or similar technologies; and
(d) information from available public sources, including from:
- publicly available and accessible directories and sources;
- bankruptcy registers;
- tax authorities, including those that are based outside the UK and the EEA if the applicable data subject is subject to tax in another jurisdiction;
- governmental and competent regulatory authorities to whom any Authorized Entity has regulatory obligations;
- credit agencies; and
- fraud prevention and detection agencies and organizations.
Categories of personal data collected
Any Authorized Entity may process the following categories of personal data:
(a) names, dates of birth and birthplace;
(b) contact details and professional addresses (including physical address, email address and telephone number);
(c) account data and other information contained in any document provided by potential investors to the Authorized Entities (whether directly or indirectly);
(d) information regarding the use of any Authorized Entity’s website, data room and/or investor portal;
(e) risk tolerance, transaction history, investment experience and investment activity;
(f) information regarding a potential investor’s status under various laws and regulations, including their social security number, tax status, income and assets;
(g) accounts and transactions with other institutions;
(h) information regarding a potential investor’s interest in the applicable Fund(s), including ownership percentage, capital investment, income and losses;
(i) information regarding a potential investor’s citizenship and location of residence;
(j) source of funds used to make the investment in the applicable Fund(s); and
(k) anti-money laundering, identification (including passport and drivers’ license), and verification documentation.
Any Authorized Entity may, in certain circumstances, combine personal data it receives from a potential investor with information that it collects from, or about such potential investor. This will include information collected in an online or offline context. In addition, personal data of potential investors could be processed and controlled irrespective of whether such investor is admitted to the Fund as a limited partner.
Purpose and lawful basis of processing
There is a need to process personal data for the purposes set out in this GDPR Privacy Notice as a matter of contractual necessity under or in connection with the applicable agreement of limited partnership or other governing agreement of the applicable Fund (the “Fund Agreement”) and associated documentation for the Fund(s) in which the data subject has or may invest, pursuant to applicable legal obligations, and in the legitimate interests of the Authorized Entities (or those of a third party) to operate their respective businesses. From time to time, an Authorized Entity may need to process the personal data on other legal bases, including: with consent; if it is necessary to protect the vital interests of a potential investor or other data subjects; or if it is necessary for a task carried out in the public interest.
A failure to provide the personal data requested to fulfill the purposes described in this GDPR Privacy Notice may result in the applicable Authorized Entities being unable to provide the services in connection with the terms of the Fund Agreement and/or the subscription agreement for the applicable Fund (the “Subscription Agreement”).
Purpose of processing
The applicable Authorized Entities process the personal data for the following purposes (and in respect of paragraphs (c), (d), (f), (h), (i) and (k) in the legitimate interests of the Authorized Entities (or those of a third party)):
(a) The performance of its contractual and legal obligations (including applicable anti‑money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable Fund.
(b) The administrative processes (and related communication) carried out between the Authorized Entities in preparing for the admission of investors to the applicable Fund.
(c) Ongoing communication with potential investors, their representatives, advisors and agents, (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the applicable Fund and execution of the Fund Agreement.
(d) The ongoing administrative, accounting, reporting and other processes and communication required to operate the business of the applicable Fund in accordance with the Fund Agreement and other applicable documentation between the parties, including in assessing suitability of investors in the applicable Fund or investment vehicle.
(e) To administer, manage and set up investor account(s) to allow potential investors to purchase their holding (of shares) in the applicable Fund (and any other funds operated by the general partner or its affiliates).
(f) To facilitate the execution, continuation or termination of the contractual relationship between potential investors and the general partner and/or the Fund (as applicable).
(g) To facilitate the transfer of funds, and administering and facilitating any other transaction, between potential investors and the applicable Fund.
(h) To enable any actual or proposed assignee or transferee, participant or sub-participant of the partnership’s or the applicable Fund’s rights or obligations to evaluate proposed transactions.
(i) To facilitate business asset transactions involving the applicable Fund’s partnership or applicable Fund-related vehicles, and/or including due diligence carried out by any third party that acquires, or is interested in acquiring or securitizing, all or part of a Fund’s assets or shares, or that succeeds to it in carrying on all or a part of its businesses, or services provided to it, whether by merger, acquisition, financing, reorganization or otherwise.
(j) Any legal or regulatory requirement.
(k) Keeping investors informed about the business of the general partner of the applicable Fund and its affiliates generally, including offering opportunities to make investments other than to the applicable Fund.
(l) Any other purpose that has been notified, or has been agreed, in writing.
The Authorized Entities monitor communications where the law requires them to do so. The Authorized Entities also monitor communications, where required to do so, to comply with regulatory rules and practices and, where permitted to do so, to protect their respective businesses and the security of their respective systems.
Sharing and transfers of personal data
In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where permitted by EEA-UK Data Protection Legislation, to other investors, service providers, employees, agents, contractors, consultants, professional advisers, lenders, processors and persons employed and/or retained by them, and any other third party, in order to fulfill the purposes described in this GDPR Privacy Notice (including any third party that acquires, or is interested in acquiring or securitizing, all or part of an Authorized Entity’s assets or shares, or that succeeds to it in carrying on all or a part of its businesses, or services provided to it, whether by merger, acquisition, financing, reorganization or otherwise). In addition, any Authorized Entity may share personal data with regulatory bodies having competent jurisdiction over them, as well as with the tax authorities, auditors and tax advisers (where necessary or required by law).
Any Authorized Entity may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfill the purposes described in this GDPR Privacy Notice and in accordance with applicable law, including where such transfer is a matter of contractual necessity to enter into, perform and administer the Subscription Agreement and Fund Agreement, and to implement requested pre-contractual measures. Transfers of personal data may be made pursuant to applicable adequacy decisions, appropriate or suitable safeguards permitted under EEA-UK Data Protection Legislation, or any other valid means permitted by applicable law. For information on the safeguards applied to such transfers, please contact the CFO as mentioned above. For the purposes of this GDPR Privacy Notice, “Non-Equivalent Country” shall mean a country or territory other than (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the United Kingdom (as applicable) in accordance with EEA-UK Data Protection Legislation to ensure an adequate level of protection for personal data.
Retention and security of personal data
Alpine and its affiliates consider the protection of personal data to be a sound business practice, and to that end, employ appropriate technical and organizational measures, including robust physical, electronic and procedural safeguards designed to protect personal data in their possession or under their control.
Personal data will not be retained for longer than necessary with regard to the purposes described in this GDPR Privacy Notice but shall be maintained as long as is required by applicable legal or regulatory obligations, or where necessary to defend or pursue legal claims (which can extend up to a number of years after the termination of an investor’s interest in the Fund). Personal data will be retained throughout the life cycle of any investment in the applicable Fund. However, some personal data will be retained after a data subject ceases to be an investor in such Fund.
Data subject rights
It is acknowledged that, subject to applicable EEA-UK Data Protection Legislation, the data subjects to which personal data relates, have certain rights under EEA-UK Data Protection Legislation: to obtain information about, or (where applicable) withdraw any consent given in relation to, the processing of their personal data (this will not affect the lawfulness of processing based on consent before its withdrawal); to access and receive a copy of their personal data; to request rectification of their personal data where it is inaccurate or incomplete; to request erasure of their personal data; to exercise their right to data portability; and the right not to be subject to automated decision-making. Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, erasure of the personal data requested to fulfill the purposes described in this GDPR Privacy Notice, may result in the inability to provide the services required pursuant to the Subscription Agreement and the Fund Agreement.
In case the data subject to whom personal data relate disagrees with the way in which their personal data is being processed in relation to the Subscription Agreement or the Fund Agreement, the data subject also has the right to object to this processing of personal data and request restriction of the processing (i) for direct marketing purposes and/or (ii) on grounds relating to the data subject’s particular situation when the processing is based on the legitimate interest basis, unless the controllers demonstrate compelling legitimate grounds for the processing. The data subject may also lodge a complaint with the competent data protection supervisory authority in the relevant jurisdiction.
The data subject may raise any request relating to the processing of his or her personal data with Dorothy Walter, CFO of Alpine Investors at dwalter@alpineinvestors.com.
[1] This Privacy Notice is intended only for individuals and certain entities that are essentially “alter egos” of individuals (e.g., revocable grantor trusts, IRAs or certain estate planning vehicles).