Privacy Policy

We recognize and respect the privacy expectations of our clients, former clients and those we have a privacy obligation. This Privacy Notice (the “Privacy Notice”) is being provided to you on behalf of Summit Rock Advisors, LP and each SRA Portfolio (collectively, “Summit Rock,” “we,” “our,” or “us”). We provide this Privacy Notice to you so that you will know what kinds of information we collect about our clients and others, if applicable, how we use that information, and the circumstances in which that information may be disclosed. This Privacy Notice applies to individuals and is subject to change. If you are a corporate client (including, for these purposes, legal arrangements such as trusts, exempted limited partnerships, or similar entities) that provides us with personal data (as defined below) on individuals connected to you for any reason in relation to your investment with us, this will be relevant for, and applicable to, those individuals, and you should transmit this document to such individuals or otherwise advise them of its content. When you provide any information to us in connection with a subscription to a SRA Portfolio that we manage, such information will be deemed to be held by all parts of “us,” i.e., Summit Rock, the SRA Portfolio into which you are investing, its governing body, such as the SRA Portfolio’s general partner and that information may be housed with any of the foregoing’s respective service providers.

This Privacy Notice contains information on our use of your personal data in accordance with relevant laws and regulations, including the Cayman Islands Data Protection Law, 2017 (“DPL”), the Gramm-Leach-Bliley Act, the California Privacy Rights Act (“CPRA”), and the California Consumer Privacy Act (“CCPA”). The rights discussed in certain sections of this Privacy Notice may be subject to exemptions or other limitations under applicable law. Please review this Privacy Notice carefully to understand what we do with respect to your personal data.

This policy applies to personal data which is collected and/or processed by Summit Rock in our capacity as a data controller as that term is defined in the DPL, GDPR, and similar privacy laws, for the purposes set out in this notice. “Personal data” and other terms as used in this notice have the same meaning provided in applicable privacy laws.

Collection of Information

We may collect personal data about you to facilitate your investments and for our business and commercial purposes. “Personal data” for the purposes of this Privacy Notice means any information that can help us directly or indirectly identify you and includes nonpublic personal information and personal information.

We may collect certain types of personal data from or about you, including:

Identifiers such as your name, address, date of birth, email address, social security number, driver’s license number, passport number or other similar identifiers.
Additional information protected under federal or state law, like a signature, bank account or other financial information.
Characteristics of protected classifications under certain federal or state law, including gender, national origin or marital status.
Commercial information, including records of products or services purchased, obtained, or considered or other purchasing histories or tendencies; for example, funds invested or investments considered.
Internet or other electronic network activity information, including, but not limited to, information collected from website browsing such as an Internet Protocol (“IP”) address and browser type.
Professional or employment-related information, including employer names and professional titles.
Education information, including information that is not publicly available, personally identifiable information as defined in the Family Educational Rights and Privacy Act.
Inferences drawn from other information to create a profile reflecting a client’s preferences or characteristics; for example, information on a client’s potential interest in investing in new funds.

Sources of Information

We may collect personal data from you or your advisor or intermediary from the following sources:

Subscription Agreements, Client Information Packages, and other forms. These documents may include your name, address, social security number or U.S. taxpayer identification number and personally identifiable financial information.
Account Information. This may include information about your capital account, such as capital contributions, profit and loss allocations, and distributions and withdrawals with us or our affiliates.
Transactions with us. This may include information we receive and maintain relating to restricted new issues and other securities transactions with and through us and our affiliates.
Correspondence. This may include written, telephonic, or electronic correspondence, between you and us or any of our affiliates or service providers.

In addition, we also may collect personal data from different sources, such as public websites or other publicly available sources like government records, or from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

Purposes for Collection and Use of Information

Summit Rock, as a data controller, may process personal data for lawful purposes, including where this is necessary for the performance of our rights and obligations under the Subscription Agreement and / or the constituent and operational documents of Summit Rock. We may collect, store, and use personal data for business or commercial purposes such as:

Performing services on behalf of Summit Rock. This may include, for example, maintaining or servicing accounts, providing customer service, processing transactions, verifying information, processing payments, or providing similar services.
Performing our contractual obligations to a client. This may include processing initial subscriptions and providing updates on our performance and other operational matters.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity.
Enabling or effecting commercial transactions. This may include using a client’s bank account details to remit funds and process distributions.
Complying with legal requirements. This may include complying with federal, state, local and non-U.S. laws, rules, and regulations.

For example, this may include preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing and conflict checks.

Disclosure of Information

We may share all of the personal data that we collect, as described above, for our everyday business purposes and with each other in order to service your account or provide you with information about services that may be of interest to you. In addition, we may disclose all of the information that we collect about you to certain third parties who are not affiliated with us for our everyday business purposes under one or more of the following circumstances which may include:

As authorized: if you request, authorize, or intentionally direct disclosure of the information.
As required by law: to cooperate, for example, with or respond to regulatory authorities, tax authorities, court orders, self-regulatory organizations, credit bureaus or law enforcement authorities.
As permitted by law: for example, sharing information with companies that maintain, process, or service customer accounts or financial products and services or who effect, administer, or enforce customer transactions is permitted.

Among other activities, we may share information with persons acting in a representative or fiduciary capacity on your behalf, or as reasonably necessary to prevent fraud, unauthorized transactions, or liability. Such recipients include our administrators, lawyers, auditors, accountants, consultants, banks, broker-dealers, custodians, financing parties, insurers, AML service providers and other back-office service providers and other entities that have been advised as to the proper handling of such data. We believe that sharing of information for these purposes is essential to providing you with necessary or useful services with respect to your accounts.

Notwithstanding the foregoing, Summit Rock does not sell your personal information or data.

Former Clients

We maintain personal data of our former clients and apply the same policies that apply to current clients.

Information Safeguarding Policy

We will take reasonable steps and use technical, administrative, and physical security measures appropriate to the nature of the personal data and that comply with applicable laws to help protect clients’ personal data against unauthorized access and exfiltration, acquisition, theft or disclosure. In addition, we have implemented internal procedures that are designed to help safeguard clients’ personal data. Our policies are designed to restrict access to personal data to those employees and agents who have been informed as to the proper handling of such information and who need to know such data to provide services to clients. Given the nature of information security, there is no guarantee that such safeguards will always be successful.

Transfer of Personal Data

Any transfer of personal data by us or our duly authorized affiliates and / or delegates shall be in accordance with applicable requirements. We and our duly authorized affiliates and / or delegates shall apply appropriate technical and organizational information security measures that are reasonably designed to help protect against unauthorized or unlawful processing of personal data, and against accidental loss or destruction of, or damage to, personal data.

Rights to Limited Sharing

Applicable law may give you the right to limit some but not all sharing of your information. Summit Rock does not: (i) share nonpublic personal information with nonaffiliates to market to you; (ii) engage in joint marketing with nonaffiliates; (iii) share nonpublic personal information with affiliates to market to you; or (iv) share nonpublic personal information about your creditworthiness with our affiliates.

In addition, individuals in certain jurisdictions may have data subject rights according applicable law in their jurisdiction. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their personal data; (ii) restrict or object to the processing of their personal data; and (iii) obtain a copy of their personal data in a portable format. Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection authority.

Submitting Requests Regarding Your Personal Information

If you wish to submit a request to exercise any of the data subject rights described in this notice, you may submit requests by (1) emailing Summit Rock at privacy.request@summit-rock.com or (2) calling this toll-free telephone number: 1-833-302-3100.

We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. When you submit a Request to Know or Request to Delete, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.

You are permitted to designate an authorized agent to submit a Request to Know or a Request to Delete on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

Changes to this Privacy Notice

This Privacy Notice was last revised as of April 2025. From time to time, we may update or revise this Privacy Notice.

Contact Details

If you have questions regarding this Privacy Notice, please contact us in writing at Summit Rock Advisors, LP, 9 West 57th Street, 18th Floor, New York, New York 10019, Attention: Chief Compliance Officer.