Privacy Policy

Vanier Capital, LLC ("Vanier Capital," "the Firm," "we," "us," or "our") is committed to safeguarding the privacy and security of all personal information entrusted to us by visitors, prospective investors, limited partners, and other users of this website (vaniercapital.com, the "Site"). This Privacy Policy describes our practices concerning the collection, use, retention, and disclosure of personal data.

By accessing or using this Site, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, you should discontinue use of the Site immediately.

Information We Collect

Personal Data

In the course of your interaction with the Firm—whether through inquiry forms, investor applications, or direct correspondence—we may collect personally identifiable information including but not limited to:

• Full legal name
• Email address and telephone number
• Entity name, title, and professional affiliation
• Accreditation status and investor classification
• Capital commitment and investment interest details
• Geographic location (city/state)

Usage & Technical Data

We automatically collect certain technical information when you visit the Site, including IP address, browser type and version, operating system, referring URLs, pages visited, time and duration of visits, and unique device identifiers. This data is collected through server logs and, where applicable, analytics tools.

Cookies & Tracking Technologies

We use strictly necessary cookies to operate the Site (session management, CSRF protection, authentication). We may also employ analytics cookies to understand aggregate usage patterns. You may configure your browser to reject cookies; however, certain Site functionality may be impaired.

How We Use Your Information

The Firm uses collected information exclusively for legitimate business purposes:

• To evaluate and process investor applications and capital commitments
• To communicate with prospective and existing limited partners regarding fund matters
• To respond to inquiries, requests, and correspondence
• To maintain and secure the Site and our technology infrastructure
• To comply with applicable legal and regulatory obligations
• To analyze aggregate, anonymized usage data for the purpose of improving the Site

Data Sharing & Disclosure

Vanier Capital does not sell, rent, or trade your personal information. We may share data only in the following limited circumstances:

• Service Providers: Trusted third-party vendors who assist in Site hosting, email delivery, analytics, and data storage, bound by contractual confidentiality obligations
• Legal Compliance: When required by law, subpoena, court order, or regulatory authority
• Protection of Rights: To protect the rights, property, or safety of Vanier Capital, its partners, or the public
• Business Transfers: In connection with any merger, acquisition, or sale of assets, where data may be transferred as part of the transaction

Investor Data Protection

We recognize the heightened sensitivity of financial and investment-related data. All investor information—including capital account data, subscription documents, K-1 statements, and fund correspondence accessible through our LP Portal—is subject to enhanced security measures including:

• Encryption in transit (TLS/SSL) and at rest
• Role-based access controls restricting data to authorized personnel
• Authentication-gated portals for investor-specific information
• Regular security audits and vulnerability assessments

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, satisfy legal and regulatory retention requirements, resolve disputes, and enforce our agreements. Investor records may be retained for the duration of the fund lifecycle and such additional periods as required by applicable tax and securities regulations. When data is no longer required, it is securely deleted or irreversibly anonymized.

Your Rights

Depending on your jurisdiction, you may have rights regarding your personal data, including:

• Right of access to the data we hold about you
• Right to correction of inaccurate or incomplete data
• Right to deletion, subject to legal retention requirements
• Right to restrict or object to processing
• Right to data portability where technically feasible

To exercise any of these rights, please contact us at info@vaniercapital.com. We may require identity verification prior to processing your request.

Legal Bases for Processing (EEA/UK)

If you are located in the European Economic Area or the United Kingdom, we process personal data under the following legal bases:

• Contract: To provide services you have requested or to take pre-contractual steps at your request
• Legitimate Interests: To secure and improve the Site, prevent misuse, and understand usage patterns
• Consent: Where specifically required; you may withdraw consent at any time
• Legal Obligation: To comply with applicable laws and regulatory requirements

International Data Transfers

Your information may be transferred to, stored, and processed in the United States, where our servers and operations are located. If you are accessing this Site from outside the United States, please be aware that data protection laws may differ from those in your jurisdiction. By continuing to use the Site, you consent to the transfer and processing of your data in the United States in accordance with this Policy.

Third-Party Links

This Site may contain links to third-party websites. Vanier Capital is not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party site you visit.

Children's Privacy

This Site is not directed at individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected data from a minor, we will take prompt steps to delete it.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The revised policy will be posted on this page with an updated effective date. Your continued use of the Site after such changes constitutes acceptance of the revised Policy.