FACTS WHAT DOES SILVER CREEK1 DO WITH YOUR PERSONAL INFORMATION?
WHY? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. This Privacy Notice applies to consumers. Consumers do not include institutions. Please read this notice carefully to understand what we do.
WHAT? The types of personal information we collect and share depend on the products or services you have with us.  This information can include:

  • Social security number and income
  • Net worth and assets
  • Wire transfer instructions, email addresses, and physical addresses
  • Capital commitment and account balances
HOW? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons Silver Creek chooses to share, and whether you can limit this sharing.
Reasons we can share your personal information Does Silver Creek Share? Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your accounts(s), administer, and operate the fund in which you are invested, respond to court orders and legal investigations, for financial reporting, for tax reporting, for compliance purposes, or otherwise in furtherance of our business. This includes providing this information to third-party service providers contracted by Silver Creek. Yes No
For our marketing purposes – to offer our products and services to you No We do not share
For joint marketing with other financial companies No We do not share
For our affiliates’ everyday business purposes information about your transactions and account balances Yes No
For our affiliates’ everyday business purposes – information about your creditworthiness No We do not share
For our affiliates to market to you Yes No
For non-affiliates to market to you No We do not share
Questions? Contact Marissa Costales, Senior Counsel, Chief Compliance Officer, Managing Director at (206) 774-6000
Who we are
Who is providing this notice? This notice is provided by Silver Creek, which includes Silver Creek Advisory Partners LLC and its affiliated management company Silver Creek Capital Management LLC
What we do
How does Silver Creek protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Silver Creek collect my personal information? We collect your personal information, for example, when you

  • Subscribe for an interest in a Silver Creek Fund
  • Complete an investor questionnaire or subscription document
  • Give us your contact information
  • Make subscriptions to, redemptions from, or other transactions in connection with your interest in a Silver Creek Fund
  • Give us instructions regarding your interest in a Silver Creek Fund
Why can’t I limit all sharing? Federal law gives you the right to limit only

  • sharing for affiliates’ everyday business purposes – information about your creditworthiness
  • affiliates from using information to market to you, unless the affiliate has a pre-existing business relationship with you
  • sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.
Definitions
Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • The private investment funds we manage, and
  • The general partners and managing members, as applicable, of the private investment funds
  • Our related management companies
Non-affiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.
Joint Marketing A formal agreement between non-affiliated financial companies that together market financial products or services to you.
This Privacy Notice is provided by the following institutions:

       Silver Creek Advisory Partners LLC and Silver Creek Capital Management LLC

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

FACTS WHAT DOES SILVER CREEK1 DO WITH PERSONAL INFORMATION OF CALIFORNIA RESIDENTS?
APPLICABILITY This privacy notice supplements the information contained in Silver Creek’s main privacy notice2 and is applicable only to California residents (you).
PURPOSE This notice is being provided in accordance with the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (CCPA) and does not establish any contractual relationship. Any terms defined in the CCPA shall have the same meaning when used in this notice.

This notice applies to all websites operated by Silver Creek and its service providers.
WHAT? Personal Information broadly includes any information that may be used to identify, relate to, describe, be associated with or linked to (directly or indirectly) a particular consumer or household that resides or is located in California.

Silver Creek may collect, use, and/or share the following types of Performance Information:

  • Identification data (e.g., full name, date of birth, identification cards, social security numbers etc.)
  • Contact Data (e.g., address, phone number, email address)
  • Personal Information listed in the CCPA
  • Financial data (e.g., bank account, financial accounts, etc.)
  • Technical data (e.g., your use of our website or investor portal, IP address, browser data, operating system, etc.)
  • Geolocation data
  • Profile information (e.g., usernames, passwords, etc)
WHERE? Silver Creek may collect, use, and/or share Personal Information from the following sources:

  • Users of Silver Creek’s website or investor portal
  • Service providers
  • Third party data aggregators, social media, or other companies with whom Silver Creek has a business relationship
  • Online tracking technologies, including cookies   Manage Cookies
HOW? Silver Creek primarily uses Personal Information for business and research purposes, some of which may include:

  • Client services: communicating with you, payment of fees, costs or debts, contract performance, notifications to you about business changes, providing privacy notices
  • Vendor services to:
    • Engage you or the entity you work for in new services, Silver Creek may provide its service providers with your Personal Information in order to perform certain limited background checks in our efforts to prevent money laundering, terrorism funding, sanctions violations, fraud or other illegal actions
    • Obtain systems support that help to manage and protect Silver Creek’s business and data, such as maintenance, testing, troubleshooting, and data hosting
    • Pay and collect fees and charges, and to pay out any money that Silver Creek owes
  • Legal or regulatory: performance of contractual obligations, data requests from applicable regulatory agencies, anti-money laundering, due diligence
TO WHOM? We do not currently sell Personal Information. We may disclose Personal Information to certain service providers for business and client servicing purposes as follows:

  • Website hosting and troubleshooting
  • Fund administration
  • Compliance with legal, regulatory, tax reporting requirements, audit and other financial reporting requirements, internal policy, or for establishing a legal claim or defending against one
YOUR RIGHTS The CCPA provides you with the right to:

  • Know how and where Silver Creek has collected, used, stored, or shared your Personal Information within the last 12 months of a request for such information
  • Request your data be corrected or updated
  • Request your Personal Information be deleted under certain circumstances.
EXERCISING YOUR RIGHTS Contact Marissa Costales, Senior Counsel, Chief Compliance Officer, Managing Director at (206) 774-6000

1 Silver Creek Advisory Partners and Silver Creek Capital Management LLC (together, “Silver Creek”)
2 Any information collected [under the tenants of] the Gramm-Leach-Bliley Act and the applicable implementing regulation, Regulation SP, are mot covered by this notice for California residents. Please refer to the immediately preceding privacy notice.