Website Privacy Notice

Last updated: June 2025

Privacy Notice 

Your privacy is important to Recess Capital and its affiliates (together, “Recess,” “our,” “us,” or “we”). To better protect your privacy, we are providing information explaining how we use your personal data. In this privacy notice (this “Privacy Notice”), we describe the types of personal data we collect, how and why we collect it, to whom we disclose it, and the choices available to you, including how to contact us about our privacy practices. Please read this Privacy Notice carefully.

As further described below in the section titled [How We Collect Your Personal Data], this Privacy Notice applies to our collection and processing of personal information or personal data (or any such similar term):

• from and about visitors of this website or our other digital platforms;
• when you opt to receive communications from Recess;
• when you communicate with us offline and online (including via phone and email correspondence);
• from and about representatives of, or individuals in connection with, our actual or prospective vendors, business partners or portfolio companies;
• to conduct business with you;
• when you apply for a job with us;
• about visitors to our premises and attendants of events or meetings we may arrange; and
• through other data collection points where we refer to this Privacy Notice.

This Privacy Notice does not apply to any processing of personal data by or on behalf of Recess that is covered by a more specific privacy notice, including in relation to investors in connection with the funds that we manage.

If you are:

• a resident of California, you should also refer to our [California Privacy Notice]; or
• located in the United Kingdom (the “UK”), the European Union (the “EU”), the European Economic Area (the “EEA”), or Switzerland, or the processing of your personal data would otherwise be subject to applicable laws and regulations relating to privacy, protection or processing of personal data in the EEA, EU, UK, or Switzerland, including the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the UK’s equivalent to the EU GDPR (the “UK GDPR”) and the Swiss Federal Act on Data Protection (collectively, the “EEA-UK Data Protection Laws”), in addition to the details contained in this Privacy Notice, please also refer to our [EEA-UK Privacy Notice].

1. The Personal Data We Collect

For the purposes described in this Privacy Notice, the types of personal data we collect about you (and which we have otherwise collected in the last twelve (12) months), depends on the nature of your interaction with us, and includes the following:

• ‍Your basic information: such as your name, prefix/title, gender, age and/or date of birth, job title and/or position.‍
• Contact information: such as personal and work physical address(es), investor portal access credentials, telephone number(s) and/or email address(es). ‍
• Information we collected by automated means: such as information about your computer / device and IP address, content and traffic data. We may also collect personal data about you through automated technology when you access and use our website, such as cookies and similar technology (please see the [“Cookies”] section below for information about how we use such technologies). This information may include the number and frequency of your visits to our website, the websites accessed before and after you visit our website, the internet browser used by you and your IP address.‍
• Information collected through communications with us: such as information obtained through telephone calls (which may be recorded for compliance purposes), video communications and other verbal communications, and written correspondence.‍
• Job applicant information: such as information that you may provide to us in connection with a job application, including CV information and identification documentation.‍
• Other information: such as background information as made available by third parties or obtained through publicly available sources.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.

2. How We Collect Your Personal Data

We may collect and maintain your personal data from the following sources:

• Information provided by you in person or through communications with us, such as information collected through written correspondence, including when you provide it to us in online or offline correspondence via physical mail, email, telephone calls (which may be recorded for regulatory purposes), video communications and other verbal communications.
• Information captured on our website or our other digital platforms, including registration and account information, information provided through online forms or similar pages.
• Information provided by third parties or as available from publicly available sources, such as a CV sent to us by a recruiting firm, background information from a background check provider, personal data we viewed on social media (e.g., LinkedIn) or information collected from publicly available or accessible directories, databases and agencies, including lists of individuals subject to sanctions or trade restrictions. If you represent one of our vendors, business partners or portfolio companies, we may also collect your personal data from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.
• Information such as your IP address and other online identifiers that are collected through automated technology when you access and use our website, such as cookies and similar technology.

We process information in relation to companies that we are evaluating in connection with a corporate transaction or potential investment. This information may include your personal data including name, title, email address, postal address, job title, telephone number, passport or other government-issued identification, financial information and/or job and benefits information, as appropriate.

3. How We Use the Personal Data We Collect

We will use the personal data we collect for one or more of the following purposes:

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, failure to provide this information means that we may not be able to conduct business with you. In this case, we may have to cancel an existing business arrangement with you but we will notify you if this is the case at the time.

[You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails. You may also request that we stop sending you marketing communications by emailing info@recess.fund at any time.

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4. With Whom do we Disclose Personal Data

Your personal data may be disclosed to and processed by our affiliates and agents and certain service providers as necessary to fulfill the purposes set out in this Privacy Notice, including professional advisors, recruitment firms, consultants, data hosting providers and customer relationship manager software platform providers, and in some instances, placement agents and other fund administrators, as well as regulators, law enforcement and other government bodies. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. When we disclose your personal data, we will only do so to the extent such disclosure complies with applicable data protection laws.

We may also disclose personal data for the purposes described in this Privacy Notice and as required by law or regulation, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment, acquisition, joint venture, bankruptcy or similar proceeding, we may disclose your personal data to the new owner of the relevant business and their advisors.

Recess does not sell or transfer personal data to affiliates or third parties for value and does not intend to do so in the future. We will amend the Privacy Notice promptly upon any changes to this policy.

The website may contain links to other websites which are not hosted, affiliated or operated by us. These websites may use automated means to collect information regarding your use of the websites. Your use of such websites is subject to the privacy policies or notices of the provider’s website.

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5. Cookies

Information regarding how you access this website (e.g., browser type, access times and IP address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes, including to help provide you with a better experience when you browse the website. Where cookies are not necessary for us to provide the services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser.

If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

You may access any personal data we have about you by contacting us at info@recess.fund.

6. Security and Retention

The security of your personal data is important to us. We adopt and employ robust and appropriate security measures to protect any personal data you provide through the website from unauthorized access or use. You should be aware, however, that absolute security does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your data.

Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through the internet or our website; any transmission of information or data by you to or through the internet, including, this website is at your sole risk.

We have put in place procedures to deal with any suspected or actual personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We review the personal data we hold periodically and delete it securely. We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required by law. We will not keep more personal data than we need for those purposes. For further information about how long we will keep your personal data, please contact us at info@recess.fund.

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7. Privacy Notice Changes

We reserve the right to amend this Privacy Notice from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Notice. Accordingly, users are strongly encouraged to review our Privacy Notice regularly. If we decide to change our Privacy Notice, we will post those changes so our users are always aware of what personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use personal data only in accordance with this Privacy Notice under which the personal data was collected. Your continued access or use of this website following the posting of changes to this Privacy Notice means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Notice, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Notice carefully so you are aware of any changes, as they are binding on you.

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8. Capacity

This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal data from anyone under the age of 18 without parental consent. If we learn we have collected or received personal data from an individual under the age of 18, we will delete that data.

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9. Contact Us

If you have any questions or comments about this Privacy Notice, wish to submit requests, or wish to notify us of any errors or changes as to any personal data you provide us through this website (each, a “Communication”), you can e-mail us at info@recess.fund.

We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information or your investor portal access credentials, if applicable in order to verify your Communication.

California Privacy Notice

Last Updated: June 2025

This California privacy notice (the “California Privacy Notice”) supplements the [Privacy Notice] with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this California Privacy Notice is otherwise set forth in the  [Privacy Notice]. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this California Privacy Notice apply to?

This California Privacy Notice applies solely to your interactions with us through our website (as defined below) or as outlined in the Privacy Notice above. If you provide personal information to us through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you?

We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic or physical communications (e.g., physical mail, emails or social media messaging), and the other collection points as described the Privacy Notice above (collectively, the “collection point”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of collection point personal information we have collected from individuals over the last twelve (12) months include the following:

We do not collect or use sensitive personal information other than:

• To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
• As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
• As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
  
• For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
• To perform services on behalf of our business; and
• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

How do we use your personal information?

We collect personal information for the business or commercial purposes and from the sources set forth in “The Personal Data We Collect” and “How We Collect Your Personal Data,” respectively, in the Privacy Notice above. We retain the categories of personal information set forth above in the “What information do we collect about you?” section of this California Privacy Notice only as long as is reasonably necessary for those business or commercial purposes set forth in “The Personal Data We Collect” in the Privacy Notice above, except as may be required under applicable law, court order or government regulations.

To whom do we disclose your personal information?

We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we have disclosed personal information collected in connection with the collection points for a business or commercial purpose to the categories of third parties indicated in the chart below[, and to affiliates and service providers, including, but not limited to, administrators, lenders, banks, auditors, law firms, state and federal governmental agencies or pursuant to legal process, regulatory entities, self-regulatory organizations, consultants, third-party due diligence providers and placement agents]. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

How do we keep your personal information secure?

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Your rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:

• the categories of personal information we collected about you;
• the categories of sources from which the personal information is collected;
• our business or commercial purpose for collecting such personal information;
• the categories of third parties to whom we disclose the personal information;
• the specific pieces of personal information we have collected about you; and
• whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, to access this notice in an alternative format, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the following methods below:

If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email to the following address info@recess.fund and we will call you during business hours.

Alternatively you can please email us at the following email address, info@recess.fund.

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request.You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

Please contact us at info@recess.fund with any questions about this California Privacy Notice.

EEA-UK Privacy Notice

This EEA-UK privacy notice (the “EEA-UK Privacy Notice”) supplements the Privacy Notice with respect to our use of personal data to the extent that EEA-UK Data Protection Laws (as defined in the Privacy Notice) apply to our processing of your personal data.

Information required to be disclosed under EEA-UK Privacy Notice regarding the collection of your personal data that is not set forth in this EEA-UK Privacy Notice is otherwise set forth in the Privacy Notice above. To the extent there is any conflict in respect of any processing subject to EEA-UK Data Protection Laws between the Privacy Notice and this EEA-UK Privacy Notice, this EEA-UK Privacy Notice shall apply. Please read this EEA-UK Privacy Notice carefully.

You do not need to take any action as a result of this EEA-UK Privacy Notice, but you may have certain rights as described below in the section headed [Your Rights].

If you have any questions regarding our use of your personal data, or this EEA-UK Privacy Notice, please contact us at info@recess.fund.

The Controller

For the purposes of EEA-UK Data Protection Laws, Recess Capital and certain of its affiliates will be a controller of any personal data collected by us. In simple terms, this means that we: (i) “control” the personal data that we collect from you or other sources provide, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data.

Any Additional Personal Data We May Collect

As described in the [The Personal Data We Collect] section of the Privacy Notice, the types of personal data we collect about you depends on the nature of your interaction with us.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or information about criminal convictions and offences, although there may be limited circumstances where we need to collect this type of personal data (e.g. as part of our legal obligations, in performance of a contract or as may be disclosed in our legitimate interest as part of a job application).

How We Collect Your Personal Data

We collect and process your personal data from you and other third parties and/or publicly available sources listed in [How We Collect Your Personal Data] section of the Privacy Notice above. 

How We Use Your Personal Data and Lawful Basis

Further information about the legal bases under which we process your personal data is included in the section of the Privacy Notice headed [How We Use the Personal Data we Collect].

We may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

No solely automated decision making, including profiling, is used when processing your personal data.

Disclosure and Transfers of Personal Data

Your personal data may be transferred to, or processed by, us, our affiliates or third parties located in Non-Equivalent Countries (as defined below), including in the United States. Further information about who we may disclose your personal data to is included in the section of the Privacy Notice headed [With Whom do we Share or Disclose Personal Data]. To the extent your personal data is transferred to a Non-Equivalent Country, such transfers will only be made in accordance with EEA-UK Data Protection Laws. For the purposes of this EEA-UK Privacy Notice, “Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the UK, or the UK Information Commissioner (as applicable) in accordance with the applicable EEA-UK Data Protection Laws to ensure an adequate level of protection for personal data. For further information about the safeguards/derogations used, please contact info@recess.fund.

Retention and Security of Personal Data

Information about the legal bases under which we process your personal data is included in the section of the Privacy Notice headed [Security and Retention].

We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this EEA-UK Privacy Notice, unless a longer retention period is required by law. We will not keep more personal data than we need for those purposes. For further information about how long we will keep your personal data, please contact info@recess.fund.

Your Rights

To the extent the EEA-UK Data Protection Laws apply to our processing of your personal data, you may have the following rights:

• ‍Access: You have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the personal data you have requested.‍
• Correction: You may notify us of changes to your personal data if the data we hold and process about you is inaccurate or it needs to be updated.‍
• Deletion: If you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.‍
• Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.‍
• Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests unless we reasonably demonstrate compelling legitimate grounds for the processing.‍
• Portability: If you wish to transfer your personal data that we hold and process about you on the legal ground of contractual necessity to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.‍
• Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose not specified in this EEA-UK Privacy Notice, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

These rights are not absolute and in certain circumstances their exercise may not be possible including when personal data must be maintained to comply with applicable laws.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Contact Us

If you have any questions or concerns about this EEA-UK Privacy Notice, please contact us by emailing us at info@recess.fund.

Complaints

Should you wish to lodge a complaint with regards to how your personal data has been processed by us, you may do so with your local supervisory authority, including under:

• the UK GDPR and/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us; or
• the EU GDPR, please contact your local supervisory authority in particular in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.

We would, however, appreciate the opportunity to address your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.

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