PRIVACY NOTICE SUPPLEMENT FOR CALIFORNIA RESIDENTS
This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018 (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 have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:
Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and drivers’ license or state identification card number);
Other customer records, such as 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);
Protected classification characteristics under California or federal law, such as date of birth, citizenship and birthplace;
Commercial information, such as 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); and
Internet or other electronic network activity information, such as information regarding your 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.
Within the last twelve (12) months, we have shared each of the categories of personal information collected with affiliates and third-party service providers as set forth in “Disclosure of Information” in the Privacy Notice above, and we collect personal information from the sources set forth in “Sources of Non-Public Information” in the Privacy Notice above.
Purposes for Collecting Personal Information: We may collect or share 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);
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;
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;
auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and
complying with U.S., state, local and non-U.S. laws, rules and regulations.
We do not sell any of the personal information we collect about you to third parties.
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.
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 over the last twelve (12) months. 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 with whom we share 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.
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 notice in an alternative format, please submit a request by emailing us at the following email address : info@nexuslp.com or contacting us by telephone at the numbers listed below. If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email to info@nexuslp.com, 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.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. Please contact the General Partner, Nexus Partners, LLC, at (424) 330-8820 with any questions about this Privacy Notice.
SMS PRIVACY STATEMENT FOR NEXUS
At Nexus, located in California, we value your privacy and are committed to protecting your personal information. This SMS Privacy Statement explains how we collect, use, and protect the information related to your use of our SMS (text message) services.
1. Collection and Use of Personal/Contact Data
When you opt-in to receive SMS messages from Nexus, we collect your mobile phone number. This contact data is primarily used to:
Deliver informational alerts: Such as market updates, portfolio summaries, important account notifications, or changes to our services.
Provide promotional messages: Including information about new investment products, upcoming webinars, or special offers, only if you have explicitly consented to receive marketing communications.
Respond to your inquiries: If you use our SMS service to ask for assistance or information.
Maintain and improve our services: We may analyze aggregated and anonymized SMS usage data to understand service performance and identify areas for improvement.
We may also collect other personal information you provide when interacting with our SMS services, such as your responses to specific messages, which helps us tailor our communications to your preferences.
2. No Sharing of SMS Data
We do not sell, rent, or share your SMS opt-in data or consent with any third parties, including subsidiaries and affiliates, for their independent marketing or promotional purposes. Your mobile number, and any data collected via our SMS service, is solely used by Nexus for the purposes outlined in this statement and our general Privacy Policy. We may use third-party service providers to facilitate our SMS messaging, but they are strictly prohibited from using your data for their own purposes and are contractually obligated to protect your information.
3. Your California Privacy Rights
As a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). While this SMS Privacy Statement specifically addresses our SMS services, our comprehensive Privacy Policy at [Link to Investment Manager's General Privacy Policy] provides full details on your rights, including:
Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, the sources from which it's collected, the purposes for collecting it, and the categories of third parties with whom we share it.
Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions.
Right to Opt-Out of Sale/Sharing: As stated above, we do not sell or share your SMS data for cross-context behavioral advertising.
Right to Correct: You have the right to request the correction of inaccurate personal information we maintain about you.
Right to Limit Use and Disclosure of Sensitive Personal Information: While we do not collect sensitive personal information through our SMS services (e.g., Social Security numbers), our general Privacy Policy details your rights regarding any such data we may collect elsewhere.
4. How to Revoke Consent / Opt-Out
You can revoke your consent to receive SMS messages from Nexus at any time.
To stop all SMS messages: Simply reply "STOP" to any message you receive from us. You will receive a single confirmation message that you have been unsubscribed, and no further messages will be sent from that service.
To get assistance: Reply "HELP" to any message you receive for more information or contact our client service team.
Other Methods: You may also revoke consent by contacting us directly through the methods provided in the "Contact Us" section below.
We will honor your opt-out request as soon as practicable, and in no event later than 10 business days from the receipt of your request.
5. Data Security
We implement reasonable technical, administrative, and physical safeguards to protect the personal information collected through our SMS service from unauthorized access, use, or disclosure.
6. Changes to This SMS Privacy Statement
We may update this SMS Privacy Statement from time to time. We will post any changes on this page and, if the changes are significant, we will provide a more prominent notice. Your continued use of our SMS service after any such changes constitutes your acceptance of the revised statement.
7. Contact Us
If you have any questions or concerns about this SMS Privacy Statement or our privacy practices, or if you wish to exercise your California privacy rights, please contact us:
Nexus Capital Management
11111 Santa Monica Blvd
Ste 350
Los Angeles, CA 90025
(424) 330-8820
support@nexuslp.com