Privacy Policy

For all California residents, please refer to RCF’s California Consumer Privacy Act Privacy Notice, which may be found: Privacy Notice for California Residents.

For all EU and UK residents, please refer to RCF’s UK/EU/EEA Data Protection Notice, which may be found: EU/UK Data Protection Notice. 

Privacy Policy

EFFECTIVE DATE: January 3, 2023

LAST UPDATED: January 3, 2023

Resource Capital Funds and its affiliates (referred to collectively in this Policy as “RCF,” “we,” “us,” “our,” and similar pronouns) knows that your privacy is important to you, and we want you to know that it is important to us too. We created this Policy to explain the types of information we collect through the RCF website available at https://resourcecapitalfunds.com/ and the various social networking platforms that we use (each, a “Site”), how we will use, disclose and protect this information once it is collected, and how you can opt-out of some of our uses and disclosures of your information. As our business evolves, this Policy may change, so check back to this page periodically to make sure you understand how your personal information will be treated.

What information is collected on this site?

“Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information. We collect different categories of Personal Information from different sources, including User-Provided Information and Site Usage Information. We also may collect Personal Information from social networking and blogging.

User-provided information

We collect Personal Information such as your: name; e-mail addresses; telephone numbers; ISP account addresses (including text message addresses); and site browsing history. For example, we may collect Personal Information such as your e-mail address, or any other information you may choose to provide, when you submit a comment or question to us through the Site.

Site Usage Information

As is the case with many websites, our servers automatically collect your IP address when you visit our Site, and we may associate that with your domain name, your Internet access provider, or physical location. We may also capture certain “clickstream data” pertaining to your Site usage. Clickstream data includes, for example, information about your computer or device, Web browser and operating system and their settings, the referring page that linked you to the Site, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next website you visit when you leave the Site, and any search terms you have entered on the Site or a referral site.

Among other things, this information enables us to generate analytics reports on the usage of our Site. To opt-out of your Site usage being included in our Google Analytics reports, you may follow these instructions: https://tools.google.com/dlpage/gaoptout

In addition, we may deploy various tracking technologies on the Site to collect additional information about your Site visits. For example:

  • Cookies are small data files stored on your computer or device at the request of a website. A cookie assigns a unique numerical identifier to your Web browser, and may enable us to recognize you as the same user who was at our Site in the past, and relate your use of the Site to other information about you, such as your Site usage information and Personal Information. Cookies may also be used to enhance your experience on the Site (for example, by storing your username so you can log in easily, keeping you logged into the Site after you have provided your password, and storing the contents of your shopping cart as you browse) or to collect general usage and aggregated statistical information and detect and prevent fraud. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of the Site or its features.
  • A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Web pages.

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number or identifier to you, and relate your Site Usage Information to other information about you, including your Personal Information. These technologies also enable us to recognize you when you access our Site using different Web browsers and different computers or devices.

Social Networking

We maintain a presence on social networking and blogging platforms, some of which are operated by third parties, such as LinkedIn, Instagram, Facebook, and Twitter. This Policy applies to our use of information you submit to us there, but it does not apply to what those third party platforms do with your information. Those platforms have their own privacy policies, and we encourage you to read them.

Articles on this site may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other sites behaves in the exact same way as if the visitor has visited the other site.

These sites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that site.

How is your information used?

We or our service providers may use the Personal Information we collect from and about you, including User-Provided Information, Site Usage Information and/or any information collected through Social Networking sites, to perform the following business functions:

  • enabling users to use our Site and its features
  • administering the Site and your account with us
  • responding to your requests, questions, and concerns
  • market research and better understanding our audience
  • developing new features and offerings on the Site
  • increasing the functionality and user-friendliness of the Site
  • protecting our rights and property
  • other purposes disclosed when Personal Information is submitted to us.

To perform the above functions, we may match information collected from you through different means or at different times, including both Personal Information and Site Usage Information, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Site, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.

Do we share Personal Information and Site Usage Information with others?

Yes. We may share the information we collect on the Site with others for a variety of reasons. In addition to the kinds of information sharing you might expect, such as sharing with third parties who need your information in order to provide services to us (or on our behalf), we may share your information:

  • when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law.
  • in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business. In addition, we may share non-personally identifiable Site Usage Information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.

Do Not Track Disclosures

Some web browsers may transmit “do-not-track” (DNT) signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We change our tracking practices (which are explained in more detail under “Site Usage Information” above) in response to DNT settings in your web browser where we are required by law.

Our third party partners, such as Google Analytics, collect information about your online activities over time and across our Site and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. We utilize Google Analytics for our web analytics and you can opt out of your Site usage data being included in our Google Analytics reports by visiting https://tools.google.com/dlpage/gaoptout

Security

While we endeavor to protect the security and integrity of sensitive Personal Information collected via this Site, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely error-free or safe from intrusion by others, such as hackers. We do not warrant or represent that the Site’s level of security meets or exceeds any particular standard, and any information you submit via the Site is at your own risk.

If you correspond with us by e-mail, text message, or using a “contact us” feature on our Site, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

If at any time during or after our relationship we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you. We will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us.

“Linked-To” Websites

The Site may contain links, banners, widgets or advertisements that lead to other websites. We are not responsible for these other sites, and so their posted privacy policies (not this Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of each website visited after leaving the Site to learn about how your information is treated by others.

Disclosure & Retention of Data Subjects’ Personal Information

We will take reasonably necessary steps to ensure that where Personal Information of Data Subjects is shared with third parties, it is treated securely and in accordance with this Policy and applicable laws.

Changes to this Privacy Policy

We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page with a new “Effective Date” and a new “Last Updated Date.” In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. In some cases, we may request your consent to the changes.

Contact us

If you have any questions or comments regarding our privacy practices, you may contact us at:

RCF Management LLC
Attention: CCO
1400 Wewatta Street, Suite 850
Denver CO 80202
United States of America

+1 720 946 1444

enquiries@rcflp.com

Privacy Notice for California Residents

EFFECTIVE DATE: January 3, 2023

LAST UPDATED: January 3, 2023

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in Resource Capital Funds and its corporate affiliates (referred to collectively in this Policy as “RCF,” “we,” “us,” “our,” and similar pronouns)  Privacy Policy and applies solely to all visitors and users who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 and the California Privacy Rights Act (collectively, “CCPA”), and any terms defined in the CCPA have the same meaning when used in this Notice. This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • 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 within the last twelve (12) months:

CategoryExamplesCollected
A. IdentifiersA 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.No
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.No
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).No
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.No
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 products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Site.
  • Third party vendors that provide databases.

Use of Personal Information

We do not sell your 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. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we will use that information to provide that service to you. We may also save your information to facilitate future communications and services.
  • To provide, support, personalize, and develop our Site, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, 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 Site, 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 consumers 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.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we make efforts to ensure that the recipient will both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Affiliates.
  • Firms that provide assistance in servicing RCF and that have a need for such information, such as CRMs or other service providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, RCF has disclosed the following categories of personal information for a business purpose:

  • A. Identifiers
  • B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  • C. Protected classification characteristics under California or federal law.
  • D. Commercial information.
  • E. Biometric information.
  • F. Internet or other similar network activity.
  • G. Geolocation data.
  • H. Sensory data.
  • I. Professional or employment-related information.
  • 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)).
  • K. Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.

Sales of Personal Information

In the preceding twelve (12) months, RCF has not sold personal information.

Your Rights and Choices

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

Access to Specific Information and Data Portability Rights

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. Once we receive and confirm your verifiable consumer request 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.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • 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.

We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

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. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records, unless an exception 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 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.
  • Exercise another right provided for by law.
  • 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 obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

RCF Management LLC
Attention: CCO
1400 Wewatta Street, Suite 850
Denver CO 80202
United States of America

+1 720 946 1444

enquiries@rcflp.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
    • An email address that operates as a user log-in, name, and date of birth.
    • 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.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

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

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Site and update the Notice’s effective date. Your continued use of our Site 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 we collect and use your information described here and in the Privacy Policy, your choices and rights regarding such use, or you wish to exercise your rights under California law, please do not hesitate to contact us at:

RCF Management LLC
Attention: CCO
1400 Wewatta Street, Suite 850
Denver CO 80202
United States of America

+1 720 946 1444

enquiries@rcflp.com

EU/UK Data Protection Notice

EFFECTIVE DATE: January 3, 2023

LAST UPDATED: January 3, 2023

RCF Management LLC (“RCF” and its corporate affiliates (referred to collectively in this Policy as “RCF,” “we,” “us,” “our,” and similar pronouns) collect and process Personal Data (as defined by the privacy, security, data protection rules and regulations, including those regarding the processing, privacy and use of personal data that apply to RCF in the United Kingdom (the “UK”), the European Union (“EU”), and the European Economic Area (“EEA”)). This UK/EU/EEA Data Protection Notice (this “Data Protection Notice”)  summarizes our policies with respect to personal information that we receive and process about various data subjects/of the following who are from natural persons resident in the UK/EU/EEA (“Data Subjects”). This Data Protection Notice sets out the kinds of personal information we collect and how that personal information is used. Please read the following carefully to understand our views and practices regarding Data Subjects’ personal information and how we will treat it.

Personal Information We Collect

We may collect and otherwise process different types of personal data from multiple sources, including: (i) collecting personal data directly from you; (ii) personal data that is automatically generated about you; and (iii) personal data that we receive about you from third parties.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth.
  • Contact Data includes billing address, delivery address, home address, email address and telephone numbers (including emergency contact information).
  • Financial Data includes bank account and payment card details.
  • Profile Data includes username and password, financial donations made by you, your interests, preferences, feedback and survey responses.
  • Service Usage Data includes information about how you use our Services and responses to questions given as part of projects.
  • Marketing and Communications Data includes preferences in receiving marketing from us and our third parties and your communication preferences.
  • Geolocation Data includes location data that is automatically collected via the app or provided by the user. 
  • Demographics Data includes information about your identity, including your gender and ethnicity.
  • Social Media Data includes your social media profile handles and information obtained from your social media profiles and/or personal/group websites.
  • Transaction Data includes details about payments to and from you and other details of financial donations that you have made to us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, language settings, mobile device operating system, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

We will endeavour to keep personal information we store about the Data Subjects reasonably accurate and up to date by enabling Data Subjects to correct it by request. The Data Subjects should notify us if any of their personal information changes or if they become aware of any inaccuracies in the personal information we hold.

Purposes of Processing Personal Information

We use the personal information held about Data Subjects for the following purposes:

  • enabling users to use our Site and its features
  • administering the Site and your account with us
  • responding to your requests, questions, and concerns
  • market research and better understanding our audience
  • developing new features and offerings on the Site
  • increasing the functionality and user-friendliness of the Site
  • protecting our rights and property
  • other purposes disclosed when Personal Information is submitted to us

We will only process personal information under a lawful basis. We do not anticipate that RCF will make any decision with respect to Data Subjects’ personal information using fully automated means. We will notify you in writing if this position changes.

Disclosures of Personal Information

We do not disclose any personal information about Data Subjects to any third parties, except:

  • as reasonably necessary or appropriate in connection with the services provided to you;
  • as required by law or any applicable regulatory authority;
  • in case of sale or merger or similar to potential purchasers, and their applicable third party service providers;
  • to protect the rights, property, or safety of our business, its clients, investors or others; or
  • as otherwise set out in this Data Protection Notice.

We will take reasonably necessary steps to ensure that where personal information is shared, it is treated securely and in accordance with this Data Protection Notice and applicable laws.

Personal Information Retention

We will endeavor not to keep personal information in a form that allows a Data Subject to be identified for any longer than 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 data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In general, this means, we shall retain Personal Data for so long as is required for the purposes of this agreement or for the full duration of your investment in the Fund and ten (10) years after the liquidation of the Fund/Partnership if the Data Subject has was directly or indirectly involved in an investment in a fund or, of any other Data Subject for ten (10) years after the last contact with the Data Subject, and/or in accordance with and subject to legal and regulatory requirements and tax and accounting rules.

Storage & Transfer of Personal Information

We maintain physical, electronic and procedural safeguards designed to protect Data Subjects’ personal information, prevent unlawful or unauthorized processing of personal information, and prevent unauthorized disclosure of, or accidental loss of, or damage to, such information. We may process personal information in, and transfer personal information to, countries that may not guarantee the same level of protection for personal information as the country in which Data Subjects reside.

Rights in Relation to Personal Information

Depending on the applicable legislation, Data Subjects may have certain rights in relation to their personal information, these may include, where certain conditions are met:

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

Data Subjects should use the contact information below to obtain more information and/or to make a formal request.

Changes to this Data Protection Notice

We reserve the right to modify this Data Protection Notice at any time and without prior notice.

Contact Information

If Data Subjects have any questions in relation to this Data Protection Notice, please contact:

RCF Management LLC
Attention: CCO
1400 Wewatta Street, Suite 850
Denver CO 80202
United States of America

+1 720 946 1444

enquiries@rcflp.com