TopTier

Privacy Policy

This Privacy Notice explains how Top Tier Capital Partners, LLC, funds which it manages and/or their corporate affiliates (“TTCP” or “We”) as data controllers, collect, use, and disclose information about you when you access or use the website ttcp.com (our “Website”) and when you use our services, in connection with investing in a TTCP fund, contact our customer service teams, and engage with us or otherwise interact with us (collectively, the “Services”). Specifically, this policy applies to information we collect:

  • On our Website and TTCP’s associated LP portals.
  • In email, text, and other electronic messages between you and us and our Website.
  • When you submit information to TTCP, including with respect to Services.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website and Services. This Privacy Notice may change from time to time. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s “Last Updated” date.

The information provided on the Website, including information regarding TTCP’s current and historical portfolio investments and Services, is not intended to recommend any company or investment described herein and is not an offer or sale of any security or investment product or investment advice. In any event, past performance is not a guarantee of future results, and it should not be assumed that results for portfolio investments will be achieved for other investments.

Our Website and Services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16 years of age. If you are under 16 years of age, do not use or provide any information on the Website or in any TTCP document.

TTCP provides investment advisory services only to the privately‑offered funds and certain types of institutional clients. TTCP does not solicit or make its services available to the general public.

The TTCP website may link to third‑party sites. These links are provided for your convenience, and TTCP assumes no responsibility for any content made available at any third‑party site. Any privacy policies/notices of any third‑party sites are governed by the operator of such site. TTCP urges you to read the posted access and privacy policy (if any) of these third‑party sites.

TTCP is an investment adviser registered with the SEC under the Investment Advisers Act of 1940, as amended. However, such registration as a registered investment adviser does not imply a certain level of skill or training.

The “LP Login” is solely for the use of existing limited partners of investment funds sponsored by TTCP, and is intended to provide electronic copies of information that is provided to existing limited partners in their capacity as investors in TTCP funds.

Contents

You can click on the following links to go directly to the corresponding sections of this Privacy Notice.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website and Services, including information:

  • Identity/Contact information: including your first name, last name, middle names, title, work email address, work phone number as well as other information you directly give us on our Website, telephone numbers;
  • Professional information: including your job title, email address, phone number, addresses, employment status, employer name, previous positions, and professional experience, dietary requirements, CV information;
  • Finance‑related information: including the amount invested and details of the investment made, name of the organization you work for and/or is a controlling person for, bank account and routing information, other payment information, wire transfer instructions;
  • Work contact information: including name, name of the business you work for and/or are a controlling person for, business address, business telephone number, and business email address as well as preference related and work‑related information (e.g., role title, dietary requirements);
  • Investment experience information: including information in support of your accredited investor status, capital account or other information about investments, risk tolerance and transaction history, investment experience, income sources, net worth, investment preferences;
  • Interaction information: including certain audio, electronic, or visual information, including phone call recordings.
  • Usage data: including information about your internet connection, the equipment you use to access our Website, information collected by cookies and similar tracking technologies, and usage details.

We do not anticipate that any “special category” personal data (e.g., any information that reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life, and sexual orientation) will be collected. It may be collected incidentally. Where any such information is provided, this will generally be because you have volunteered such information and/or documents gathered for certain regulatory or legal purposes (e.g., for AML/KYC checks) reveal such information.

We collect certain personal information about you from multiple sources, including: (i) collecting personal information directly from you; (ii) personal information that is automatically generated about you; and (iii) personal information that we receive about you from others.

Information You Provide to Us

The information we collect on or through our Website and Services may include:

  • Information that you provide by filling in forms on our Website, including the “Contact Us” form. This includes information requesting further services. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses) if you contact us.

Information We Collect Through Automatic Data Collection Technologies

Where permitted, as you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The technologies we use for this automatic data collection are cookies. These are a small file placed on the hard drive of your device. Where you consent, we place functional and analytical cookies on your system. Functional cookies are used to recognize you when you return to our Website. This enables us to personalize our content for you, and remember your preferences. Analytical cookies allow us to recognize and count the number of visitors to our Website and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

Please see below for further information as to the cookies that are placed. We use the following cookies.

Information we might receive from others

The information we collect about you may include:

  • This could be from our third‑party service providers, e.g., administrators, banks, placement agents, or similar.
  • From publicly available information.

How We Use Your Information

Under certain data protection laws, we can only use your personal information if we have a valid reason. With respect to the processing of your personal data in the context of the Website, this is generally because:

  • you have given consent (“Consent”);
  • to comply with our legal and regulatory obligations (“Legal/Regulatory Obligations”);
  • it is necessary for the performance of a contract with you or to take steps at your request before entering into a contract (“Performance of a Contract”); or
  • it is in our legitimate interests or those of a third party (“Legitimate Interests”).

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests to balance our interests against your own.

The nature of your interaction with us will determine how we will process your personal data. The relevant specific purposes and lawful bases (to the extent required by applicable data protection laws) for which we will process your personal data are set out below in the relevant tables:

  • For visitors to and users of our Website
  • For visitors to our offices
  • For investors, representatives of our investors, and others associated with investors
  • For our representatives of our service providers or professional advisers or other counterparties
  • For all visitors, users, investors, representatives of our investors, and others associated with investors, representatives, professional advisers, and other counterparties

For Visitors to and Users of Our Website

Purpose of Processing Category of Personal Data Lawful Basis (to the extent applicable under relevant data protection laws)
To operate our Website, and maintain and improve our sites and services Identity/Contact information

Usage data

 Where your Consent is required by applicable laws.

In all other cases, where it is in our Legitimate Interests to process such data in order for us to operate its Website and business, such as for IT operations and security.
To respond to comments, concerns, and questions Identity/Contact information

Professional information

 It is in our Legitimate Interests to process such data in order for us to provide the expected service, including to send technical notices, updates, security alerts, and support and administrative messages.
To conduct electronic direct marketing to you and to alert you to our financial products or services Identity/Contact information

Professional information

 Where your Consent is required by applicable laws.

In all other cases, where it is in our Legitimate Interests to process such data in order to promote our services and products, and provide value added benefits to clients.
To place analytical and functional cookies on your browser Usage Data Where your Consent is required by applicable laws.

 

For Visitors to our Offices

Purpose of Processing Category of Personal Data Lawful Basis (to the extent applicable under relevant data protection laws)
To register your attendance at our offices Identity/Contact information To comply with our Legal/Regulatory Obligations, including to comply with any applicable health and safety obligations.

Where it is in our Legitimate Interests to ensure safety and security in our offices.

 

For Investors, Representatives of Our Investors, and Others Associated with Investors

Purpose of Processing Category of Personal Data Lawful Basis (to the extent applicable under relevant data protection laws)
To undertake pre‑investment steps, including, but not limited to: (i) determining eligibility to invest in a fund; (ii) required due diligence; and (iii) ascertaining investment preferences. Identity/Contact information

Verification information

Finance‑related information

Work contact information

Investment experience information

Interaction information

 In order to perform our obligations under our Contract (with you or with the entity you represent).

Or

To comply with Legal/Regulatory Obligations

Or

In all other cases, where it is in our Legitimate Interests in establishing preferred investment strategies and to provide a tailored service to you.
To process the subscription, to accept you and/or the organisations you represent as a limited partner/investor, and to process transactions in any fund, and to carry out obligations arising from any subscription agreement (and related investment documents) entered into by or on behalf of the investor. Identity/Contact information

Verification information

Finance‑related information

Work contact information

Investment experience information

Interaction information

 In order to perform our obligations under our Contract (with you or with the entity you represent).
To provide services to and manage the affairs of the investments in the funds and relationships with you (including the acquisition and disposal of investments, the arranging of any financing, and arranging for the preparation and auditing of accounts, statements, or reports and similar), for periodic investor reporting, and for other administrative purposes including to maintain records and correspondence relating to participation in the fund as well as for corporate governance. Identity/Contact information

Verification information

Finance‑related information

Work contact information

Investment experience information

Interaction information

 In order to perform our obligations under our Contract (with you or with the entity you represent).

Or

In all other cases, where it is in our Legitimate Interests to provide a comprehensive, efficient, and tailored service to you.
To complete anti‑money laundering checks and other checks as are required by law (including counter‑terrorist financing law (such as carrying out customer due diligence) and tax law (including reporting under any tax reporting regime), which, if not conducted, means that we will be unable to carry out obligations arising under the Subscription Agreement or any other agreement (including, but not limited to, limited partnership agreements, subscription agreements, and investment management agreements)), and/or detect crime. Identity/Contact information

Verification information

 To comply with Legal/Regulatory Obligations

Or

In all other cases, where it is in our Legitimate Interests to protect and enhance the business and operations, including (i) to comply with applicable regulations and guidance as well as internal policies and procedures; and (ii) to respond to requests from legal, regulatory, judicial, administrative, governmental, and other official bodies.
To communicate with you for business development purposes, and to send informational and/or marketing messages with you. Identity/Contact information

Work contact information

 Where it is in our Legitimate Interests to promote our Services and provide a comprehensive, efficient, and tailored service to you.
In general practice, telephone conversations and instructions may be monitored and recorded as proof of a transaction or related communication. Such recordings will be processed in accordance with applicable laws and shall not be released to third parties, except in cases where we are compelled or entitled by laws or regulations or court order to do so. Interaction information To comply with Legal/Regulatory Obligations

Or

In all other cases, where it is in our Legitimate Interests to maintain relations with investors and in conducting their business in a proper manner.

 

For Representatives of Our Service Providers or Professional Advisers, or Other Counterparties

Purpose of Processing Category of personal data Lawful Basis (to the extent applicable under relevant data protection laws)
To conduct business with you/the business you represent Identity/Contact information

Professional information

 Where it is in our Legitimate Interests (i) to contact you; or (ii) to manage our relationship.
To invoice you or deal with invoices Identity/Contact information

Professional information

 In order to perform our obligations under our Contract (with you or with the entity you represent).

In all other cases, where it is in our Legitimate Interests to invoice you or an entity that you represent.

 

For All Visitors, Users, Investors, Representatives of Our Investors, and Others Associated with Investors, Representatives, Professional Advisers, and Other Counterparties

Purpose of Processing Category of personal data Lawful Basis (to the extent applicable under relevant data protection laws)
To meet current or future legal and regulatory obligations Identity/Contact information To comply with our Legal/Regulatory Obligations.

In all other cases, where it is in our Legitimate Interests to protect and enhance our business and its operations, including (i) to comply with applicable regulations and guidance as well as internal policies and procedures; (ii) for audit purposes and quality checks; and (iii) to respond to requests from legal, regulatory, judicial, administrative, governmental, and other official bodies.
To disclose information to Data Recipients (as defined below) in order to enable the other purposes outlined in this Privacy Notice Identity/Contact information

Verification information

Finance‑related information

Work contact information

Investment experience information

Interaction information

 To comply with Legal/Regulatory Obligations

Or

In all other cases, where it is in the Legitimate Interests of the Data Controllers or any other applicable parties to conduct business and provide services in a comprehensive, efficient, and effective manner.
To protect our rights, including initiating and defending claims, protecting, investigating, and deterring against fraudulent, unauthorized, or illegal activity, and/or to comply with judicial or regulatory proceedings, a court order, or other legal process. Identity/Contact information

Verification information

Finance‑related information

Work contact information

Investment experience information

Interaction information

 To comply with Legal/Regulatory Obligations

Or

Where it is in our Legitimate Interests to protect our business including by: (i) collecting amounts from you; (ii) enforcing our legal rights; (iii) initiating claims; (iv) defending claims; (v) preventing and detecting crime, fraud, and other abuses; (vi) investigating and attending to enquiries; and (vii) creating and maintaining our risk‑related models.
In case of sale, merger, reorganization, restructuring, investment, or similar Identity/Contact information

Professional information

Usage Data

 Where it is in our Legitimate Interests to manage and develop our business by enabling corporate transactions. Such transactions may require the provision of your personal data to actual or potential buyers, investors, merger entities, or our assignees business or assets. Such data provision may also occur to allow such parties to evaluate or complete the corporate transaction.

 

Failure to provide us with the relevant personal data, in cases where you are legally or contractually required to provide it, may result in our being unable to establish or continue our business relationship with you or to provide products and services to you.

In general, we will not conduct any processing activities relating to your personal data that involves any automated decision‑making (including profiling). Typically, there is always human involvement. However, where we make a decision or profile through automated means, then we will put systems in place that comply with applicable laws.

Cookies

The table below provides more detailed information about the cookies we use (where you have provided your consent) and why:

Cookie Owner Cookie Name Type Purpose Duration
Cloudfare __cf_bm Functional Cloudflare set the cookie to support Cloudflare Bot Management. 1 hour
Cloudfare __cf_bm Functional Cloudflare set the cookie to support Cloudflare Bot Management. 1 hour
Google Analytics _ga_* Analytical Google Analytics sets this cookie to store and count page views. 1 year 1 month
Google Analytics _ga Analytical Google Analytics sets this cookie to calculate visitor, session, and campaign data, and track website usage for the website’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. 1 year 1 month
Google Analytics _gid Analytical Google Analytics sets this cookie to store information on how visitors use a website while also creating an analytics report of the website’s performance. Some of the collected data includes the number of visitors, their source, and the pages they visit anonymously. 1 day
Google Analytics _gat_gtag_UA_ Analytical Google Analytics sets this cookie to store a unique user ID. 1 minute

 

Please note, you can revoke your consent (if given) at any time. However, such revocation will have no effect on the lawfulness of the processing that took place before you revoked your consent. To revoke your consent, it is sufficient that you delete your cookies and cache from your browser history.

Third‑Party Use of Cookies and Other Tracking Technologies

Some content or applications, including any advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest‑based (behavioral) advertising or other targeted content.

Please see below for further information as to the cookies that are placed.

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this Privacy Notice to our subsidiaries and affiliates as well as certain third parties, including the AIFM, legal advisers, accountants, third‑party service providers or agents, administrators, placement agents, advisers, depository, financial service providers, banks, broker‑dealers, credit providers, IT service providers (such as cloud services providers and software‑as‑a‑service providers), parties undertaking anti‑money laundering checks, companies engaged to dispose of or store data including personal data, adverse parties who have a legal right to receive such information and their counsel, experts, portfolio companies and their advisors, other funds in which the funds invest, relevant governmental or regulatory authorities, supervisory, tax, or other authorities and regulators in various jurisdictions, transfer agents, brokerage firms and/or other such advisors, and relevant affiliates or third‑party service providers of each of the above, and to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TTCP’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TTCP about our Website users and customers is among the assets transferred (each a “Data Recipient”).

The Data Recipients may, as the case may be, process the personal information as data processors (when processing the personal data upon instructions of a data controller), or as distinct and independent data controllers (when processing the personal data for their own purposes, or fulfilling their own legal obligations). Your attention is therefore also drawn to the relevant privacy notices of Data Recipients of data controllers for further details of their further processing.

Retention of Your Information

We will endeavor not to keep personal information in a form that allows you to be identified for any longer than it is reasonably necessary for achieving the permitted purposes. At the end of the applicable retention period, we may destroy, erase from our systems, or anonymize personal information as part of such efforts. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process the personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.[2]

International Transfers

We will process personal data in, and transfer personal data to, countries outside of the UK and EEA, e.g., to USA, Israel and Switzerland. Where the Data Recipients are located outside the EEA or the UK, to the extent required by applicable laws, we will enter into a legally binding transfer agreement with the relevant Data Recipients in the form of the EU Commission’s or the UK’s approved model clauses, as applicable, unless there is another suitable safeguard in place, or the Data Controllers can otherwise transfer the personal data in accordance with the applicable laws. If you require further information about this, you can request it using the details set out in the “Contact Information” section below.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, click here to take you to TTCP’s CA Notice.

 

Rights Under UK/European Union Law

You may have certain rights in addition to those described elsewhere in this Privacy Notice. These rights are in relation to your personal information, and include the right to be informed about the collection and use of your personal information, as outlined in this Privacy Notice.

Such rights may also include, where certain conditions are met:

  • the right to request access to the personal information we hold about you;
  • the right to have information about you amended, updated, or deleted;
  • the right to object to processing of personal information about you;
  • the right to withdraw consent at any time (where relevant);
  • the right to have personal information about you erased or to restrict processing in certain limited situations;
  • the right to data portability and to request the transmission of personal information about you to another organization;
  • the right to object to automated decision making that materially impacts you, direct marketing, and processing for research or statistical purposes;
  • the right to lodge complaints with applicable data supervisory authorities;

You should use the contact information below to get more information and/or to make a formal request. We will endeavor to keep the personal information we store about you reasonably accurate and up‑to‑date by enabling you to correct it by request.

You should notify us if any of your Personal Information changes or if you become aware of any inaccuracies in the personal information we hold about you.

Contact Information

To ask questions or comment about this Privacy Notice and our privacy practices, contact us at:

Top Tier Capital Partners, LLC
600 Montgomery Street
Suite 480
San Francisco, CA 94111
Phone: 415‑835‑7500
Toll Free: 888‑835‑8827
Email: [email protected]

 

Top Tier Capital Partners, LLC Privacy Notice for California Residents

Effective Date: April 1, 2021

Last Reviewed and Updated on: March 2024

 

This Privacy Notice for California Residents (“CA Notice”) supplements the information contained in Top Tier Capital Partners, LLC’s (“TTCP” “Company” or “We”) Privacy Notice, and applies solely to all visitors, customers, users, and others who reside in the State of California (“consumers” or “you”). We adopt this CA Notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (collectively “CCPA”) and any terms defined in the CCPA have the same meaning when used in this CA Notice.

When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, consumer, or household.

This CA Notice does not apply to workforce‑related personal information collected from California‑based employees, job applicants, contractors, or similar individuals.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include:

Publicly available information from government records.

Deidentified or aggregated consumer information.

Information excluded from the CCPA’s scope, including personal information covered by certain sector‑specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm‑Leach‑Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

 YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
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. NO
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

 

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or services you use.

Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information.

To create, maintain, customize, and secure your account with us.

To process your requests, purchases, transactions, and payments and prevent transactional fraud.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns, and monitor and improve our responses.

To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our clients is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosure of Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information (corresponding with the chart above) to third party service providers in connection with our provision of services: A. Identifiers; B. Personal information categories listed in the California Customer Records statute; C. Protected classification characteristics under California or federal law; D. Commercial information; and F. Internet or other similar network activity.

We may have disclosed these categories of personal information to the following third parties: Service providers; Third parties to whom you or your agents authorized us to disclose your personal information in connection with our services we provide to you; and Third-party investors that are performing due diligence.

No Selling or Sharing for Targeted Advertising

The Company has not sold or shared Personal Information as defined or as contemplated by the CCPA in the preceding 12 months. As defined and contemplated by the CCPA, the Company does not sell or share Personal Information of minors under the age of 16.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:

The categories of personal information we collected about you.

The categories of sources for the personal information we collected about you.

Our business or commercial purpose for collecting or selling that personal information.

The categories of third parties with whom we share that personal information.

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

sales, identifying the personal information categories that each category of recipient purchased; and

disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

The specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for business‑to‑business personal information.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

Comply with a legal or regulatory obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for business‑to‑business personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by contacting TTCP:

Top Tier Capital Partners, LLC
600 Montgomery Street
Suite 480
San Francisco, CA 94111
Phone: 415‑835‑7500
Toll Free: 888‑835‑8827
Email: [email protected]

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12‑month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10‑day timeframe, please contact TTCP at Phone: 888‑835‑8827 or email at [email protected].

We endeavor to substantively respond to a verifiable consumer request within forty‑five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Non‑Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

Provide you a different level or quality of goods or services.

Suggest that you may receive a different price or rate for goods or services, or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA‑permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt‑in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at the address below.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website and/or services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which TTCP collects and uses your information described here and in TTCP’s Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Top Tier Capital Partners, LLC
600 Montgomery Street
Suite 480
San Francisco, CA 94111
Phone: 415‑835‑7500
Toll Free: 888‑835‑8827
Email: [email protected]

If you need to access this Policy in an alternative format due to having a disability, please contact TTCP’s [email protected] or TTCP’s Phone Number: 415‑835‑7500.