AMERICAN INDUSTRIAL PARTNERS ONLINE PRIVACY POLICY

At American Industrial Partners (“AIP”), your privacy is very important to us. This notice explains AIP’s practices pertaining to the online collection of personally identifiable information, and the way such information is collected and used. Links to this notice are available on our homepage and throughout our website wherever personally identifiable information may be requested or collected. References to “we”, “us”, “our” or “AIP” in this Online Privacy Policy are intended to include AIP, LLC and its affiliates as the recipients of certain personally identifiable information.
This Online Privacy Policy is effective as of December 2018. Any changes we may make to this Online Privacy Policy in the future will form part of an updated Online Privacy Policy posted on this page.

WHAT INFORMATION WE COLLECT

This Online Privacy Policy applies to information collected from, or which may be submitted to, the AIP website. At the present time, we do not collect any personally identifiable information about visitors to the publicly available areas of our website, including any visitors’ names, addresses, phone numbers, social security numbers or email addresses. We may collect email addresses of those of our investors who choose to access the private, restricted area of our website reserved for our investors. At times, visitors to our website may choose to email individuals at AIP using links available on our site; in such instances, a visitor’s email address may be collected as part of the process of sending the email to us in order to enable us to reply to those emails. We may, however, but have no obligation to, monitor and record other activity on our website for any reason or for no reason.

Our website uses “cookies” technology, through which small amounts of data are sent to your computer from our web server and stored on your computer’s hard drive. This data identifies you as a unique user when visiting our website, and helps us in the ongoing maintenance of our website. This technology does not provide us with any information about your name, address phone number or email address, or any other personally identifiable information. We do, however, log visitor IP addresses.

The collection of the foregoing information is for the purposes of our legitimate business interests (such as to carry out and improve our business, and to analyze the use of our website and services).

HOW WE USE INFORMATION WE MAY COLLECT

We do not share any information collected from the publicly available areas of our website with any parties outside of our company. Information collected from our investors who choose to access the private, restricted area of our website reserved for our investors, may be used (i) to supply the investment services you have requested and correspond with you, or otherwise perform our contract with you, (ii) to provide support to you in respect of these services, (iii) to improve our website and services, and (iv) for our internal business processes. All information collected from our website may be used to comply with applicable legal and regulatory obligations and AIP reserves the right to disclose any such information we do collect when required by a valid subpoena or court order, or as otherwise required by law. In the event that a visitor submits their email address or any other personally identifiable information to us via our website while requesting information or sending any email to someone at AIP, other than as described above, we never use such information for any other purpose, and will not disclose such information to any outside party.

DATA TRANSFERS AND CERTAIN DATA PROTECTION RIGHTS

As an organization based in the United States, AIP will collect and process certain personally identifiable information outside the European Economic Area (“EEA”), and data protection legislation in the EEA provides individuals in the EEA with certain data protection rights which we are obliged to inform such individuals of, namely (i) the right to receive confirmation as to whether we have personally identifiable information concerning you and, if so, access to that personally identifiable information and information concerning the nature and processing of such personally identifiable information, (ii) the right to rectify or update personally identifiable information that is incomplete or inaccurate, (iii) the right to erase personally identifiable information in certain circumstances, (iv) the right to restrict the use of your personally identifiable information in certain circumstances, (v) the right to ask us to stop processing your personally identifiable information in certain circumstances, (vi) the right to receive your personally identifiable information in a structured, commonly used and machine-readable format, (vii) the right to request that we transmit such data to another party, in certain circumstances, and (viii) the right to make a compliant to your applicable data protection supervisory authority.

In addition, it will sometimes be necessary for us to transfer EEA personally identifiable information to our staff with an affiliate and our third party service providers outside the EEA. We will therefore take all steps reasonably necessary to ensure that relevant EEA personally identifiable information is only transferred if that party (i) is situated in a country that has been confirmed by the European Commission to provide adequate protection to personally identifiable information or (ii) has agreed (by way of written contract) to provide all protections to the EEA personally identifiable information as required by the applicable data protection legislation.

This Online Privacy Policy is in addition to our Investor Privacy Notice applicable to the relevant investors in AIP funds.

DATA AND NETWORK SECURITY

We maintain strict operational policies including physical, electronic and procedural protections to safeguard and secure our data networks to prevent the unauthorized access, unlawful processing, accidental loss, destruction and damage to data we may collect online, and have appropriate policies in place to ensure that any information we collect is used in strict compliance with this Online Privacy Policy.

We will only keep your personally identifiable information (if any) for as long as we reasonably require and, in any event, only for as long as the data protection legislation applicable to such information allows.

If you would like more information, enquire about your rights, or make a complaint, please contact us through our website.

ACCESS TO PORTFOLIO COMPANY AND OTHER THIRD PARTY WEBSITES

Our website contains links to websites controlled and maintained by our current or former portfolio companies and other third parties. We provide these links solely as a convenience for you. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites are used. This Online Privacy Policy does not govern the use of information collected on such third party websites.