Introduction and scope
This Privacy Policy explains how the administration office of CGP GP FUND I LP handles personal information when general partners, limited partners, counterparties and visitors interact with the funds, the investor portal and the public web pages. The administration machinery and the integrated reporting systems beneath these pages have been designed and developed by the developer CGP Fund, and this policy reflects the disciplined and documented approach CGP Fund applies to every ledger and every record it touches.
In this policy the words we, us and our refer to CGP GP FUND I LP, a limited partnership that maintains its registered and administrative office at 101 Larkspur Landing Cir Ste 310, Larkspur - 94939-1751, United States (US). Reference to the office or to the administration team means the people and the systems that carry out the fund administration work described on this website.
The policy covers information gathered in connection with the administration of private investment partnerships, capital calls, distributions, valuations, bookkeeping, tax reporting and regulatory filings. It also covers information that flows through the investor reporting portal, through the secure document vault and through contact with the office by email, by telephone, by the website contact form or by post.
The policy applies whether information is furnished by a partnership, by an individual officer of a fund, by a limited partner acting in a professional capacity, or by a casual visitor to the web pages. Different paragraphs respond to different roles because the office stores the least information that each task requires and no more. The governing rule is simple: records are opened only where there is a lawful reason, kept only for as long as they are genuinely needed, protected against loss and unlawful access, and never traded as a commodity.
Who controls the office records
The office that controls the personal information described in this policy is CGP GP FUND I LP. The registered place of business is 101 Larkspur Landing Cir Ste 310, Larkspur - 94939-1751, United States (US). The responsible person for privacy matters can be reached through notify@cgpfund.mom or by telephone at +18058220215 during business hours.
For some engagements the general partner of a fund acts as its own controller of the partnership records and instructs the office how to process them as a service provider. In those cases the privacy notice of the relevant partnership continues to govern the underlying handling, while this policy describes the shared baseline of care and security that the office applies in every instruction it accepts.
The office does not sell, rent, license or otherwise trade personal information to any third party for any commercial purpose. Personal information is never treated as a product, a mailing list, a data brokerage asset or a marketing lead. It exists solely as the controlled working paper of a fund administration practice whose entire reputation rests on discretion, accuracy and prompt accountability.
What the office collects
The amounts and kinds of personal information vary with the role of the person and the task at hand. In ordinary course the following categories may be present in the records of the office.
- Identity data such as full legal name, date and place of establishment for an organisation, and the name and title of an authorised signatory.
- Contact data such as a postal address, a business email address, a contact telephone number and a jurisdiction of residence.
- Professional data such as a national identifier used for tax returns, a fund registration reference, a proxy or voting instruction and a bank reference used to test a distribution routing.
- Financial records such as capital commitments, contributed amounts, capital account balances, subscription documentation and distribution schedules.
- Technical records such as the internet address of a device, the type of browser, the pages opened on the public website and a timestamp of each visit.
- Correspondence records such as the subject and body of a message sent to the office, along with the name and address attached to that message.
Information that is merely incidental, such as a name that appears on a carbon copy of a board minute, is not extracted into a separate profile unless a specific regulatory duty requires it. The office avoids building wider records than the engagement demands.
How records are received
The office receives personal information from several lawful channels, and each channel is recorded so the origin of a figure can be shown to an auditor without hesitation.
- Direct supply by the data subject, for example through the website contact form, a signed mandate, an email or a telephone conversation with the administration team.
- Supply by the general partner or the fund promoter when the office is engaged to administer a partnership and the required book of documents is handed over at onboarding.
- Supply by recognised intermediaries such as an introducing bank, a paying agent, a custodian, a legal adviser or a tax adviser acting within a legitimate instruction.
- Publicly available sources only where necessary to verify a counterparty identity or a registered address that a client has stated, and always proportionately.
- Public website logs that are generated passively as a visitor loads the pages of this site.
Where information is furnished by a third party on behalf of a person, that third party is responsible for holding the proper authority, and the office asks for confirmation of that authority at the point of collection whenever it is practical to do so.
Principles of the ledger
The handling of personal information in this office mirrors the way a careful bookkeeper treats a ledger entry. A number may be posted only where a source supports it, only once, and only in a way that can be traced.
- Lawfulness and fairness: every record has a stated and lawful reason behind it, and nothing is gathered by deception or surprise.
- Transparency: this policy tells a data subject what the office holds and why, and further detail is given on request without charge.
- Purpose limitation: a record opened for capital administration is not later used to market an unconnected product to the same person.
- Data minimisation: the office stores the smallest set of fields that the task needs and refuses fields that carry no purpose.
- Accuracy: figures are checked against source documents, corrected without delay and signed by the correcting officer.
- Storage limitation: folios are archived or destroyed at the end of the lawful use, on a fixed and documented schedule.
- Integrity and confidentiality: storage is protected by access control, encryption in transit and a written incident plan.
These principles are restated in the service agreements the office signs, so that the standard of care is not a goodwill promise but a contractual obligation.
Why records are kept
Personal information that reaches the office is processed for stated purposes connected to the business of administering investment partnerships under the umbrella of CGP GP FUND I LP.
- To open and maintain the partnership books, including the capital schedule, the distributions and the carried interest waterfall.
- To prepare capital calls, date notices, reconcile receipts and compute distributions to the correct recipients.
- To produce quarterly statements, capital account rolls, valuation reconciliations and tax letters.
- To meet statutory filing duties and to assemble the work papers that support an annual audit.
- To answer questions from general partners, limited partners and authorised advisers, and to keep a record of the correspondence.
- To maintain the investor portal and the secure document vault so that only entitled persons reach their own records.
- To detect, prevent and document fraud, error or attempted unauthorised access to the systems.
- To respond to a person who exercises a privacy right and to keep the office decision accountable.
No record is collected for these purposes and then applied to a materially different purpose without first informing the person, or establishing another lawful ground that is recorded in writing.
Lawful grounds for processing
Where a data protection law requires a stated lawful ground, the office relies on the grounds that best fit each activity, and it documents the choice in the instruction file.
- Performance of a contract, which covers almost all onboarding and administration where a general partner has engaged the office.
- Legitimate interests of the office and of the funds, which cover fraud prevention, security logging and operational record keeping, always balanced against the interests of the person.
- Compliance with a legal obligation, which covers tax and regulatory filings that the office cannot decline to make.
- Consent, which the office uses only sparingly, for choices that are genuinely optional, and which the person may withdraw at any time with the same ease.
- Where a special category of information appears in an anti money laundering check, the processing rests on a substantial public interest recognised in law and is handled under strict internal rule.
A person who prefers not to receive optional communications loses no service and no entitlement; the office sends only messages that are necessary to the administration relationship, and the rare marketing or news note is accompanied by a clear opt out.
Processors and their duties
Certain providers of technology act as processors, meaning they handle personal information only on the documented instruction of the office. The office selects processors that show a credible security posture and enters a data processing agreement with each one before any records are transferred.
Every processing agreement obliges the provider to process the records only for the agreed task, to keep them confidential, to assist the office in answering a data subject request, to report a security breach without unjustified delay, and to delete or return the records at the end of the engagement. The list of current processors is disclosed on request, subject to protecting the security of the office arrangements.
Because the office does not sell access to its records, no processor is permitted to mine those records for its own advertising, analytics or product development unrelated to the agreed task, and the agreement says so expressly.
Safeguards held around the records
The office protects the folios with layers of control appropriate to the sensitivity of fund records.
- Access is limited to the officers whose duties require it, on the principle that a person sees only the accounts they are assigned to close.
- Transport of records across the internet is protected by current encryption standards, and stored backups are protected at rest.
- Authentication uses separate credentials per officer with a documented review when someone leaves the team.
- All significant changes to a record leave an audit marker, and nothing can be silently rewritten after the quarterly seal is applied.
- Physical premises and machines are kept under lock, and portable copies are discouraged and encrypted when they must exist.
- A written incident response plan covers loss, theft or breach, with a duty to notify affected partners and any relevant authority without delay.
Despite these measures no method of storage is entirely immune to risk, and this policy does not promise absolute security. The office does promise care proportional to the value of the records and does promise candour if something goes wrong.
How long folios are kept
Records are kept only for the period that the law, the audit needs and the engagement require, and are then archived or destroyed on a schedule the office can demonstrate.
- Accounting records and their supporting schedules are typically retained for the full statutory period for books of US partnerships and any longer term a particular filing requires.
- Tax and regulatory work papers are retained while the relevant filing remains open to question and for the period the revenue rules demand thereafter.
- General correspondence is held for the active engagement and a short defined window beyond its close, then deleted.
- Website logs are held for a limited security window, measured in months rather than years, before they are aged out.
- Information held only for a request, such as a one off enquiry, is deleted once the enquiry is concluded and any follow up period has passed.
Destruction is performed in a way that prevents reconstruction, and a destruction certificate is filed for records that a client or regulator must see was handled with care.
Records of the general partners
The office keeps a control file for each general partner that has engaged CGP GP FUND I LP administration work. That file holds the signed mandate, the identity papers of the authorised signatories, the standing delivery instructions and the current contact route of the general partner.
These details let the office serve capital calls, circulate closings and reach the correct person without delay. The general partner contact is also the person who receives notices about incidents, about policy changes and about the exercise of a partner right, because that correspondence is the lawful lifeline of the administration relationship.
The office keeps these records current by asking the general partner to confirm standing details at least once a year and by acting promptly on a change of address or of authorised signatory.
Records of the limited partners
For each limited partner in an administered fund the office holds the subscription documentation, the committed amount, the contribution history, the capital account roll and the distribution records. This is the minimum that a fund administrator must hold to run a capital account, and it is used for that purpose alone.
Limited partner contact details are stored so that statements, tax letters and capital call notices reach the correct mailbox. The office does not use these details to market unrelated products, does not sell them and does not reveal a limited partner capital position to any other limited partner of the same fund.
A limited partner may ask the office what contact and identity records are held, may ask that obvious errors be corrected, and may ask for a copy of the account data that pertains to that limited partner. The office answers such requests through the ordinary governance of the partnership and within a reasonable time.
Privacy within the investor portal
The investor reporting portal shows a limited partner only the records of that limited partner. Access is personal, is tied to a credential owned by the office, and is revoked when the person leaves the fund or when a general partner requests removal.
Each portal session is dated, and each download of a statement or tax letter is logged so that a general partner can know, in a legitimate audit context, whether a document has been fetched. The portal does not display information about other partners, does not expose the office master files and does not allow a user to reach records of any other entity unless the partnership paperwork expressly creates the entitlement.
Passwords are never stored in a readable form, and the office encourages the use of a separate, strong credential for the portal rather than the reuse of a personal password from elsewhere.
Information of website visitors
The public pages of the office are mostly informational, and a visitor can read them without creating an account. At the server the office quietly receives the technical details that any website receives, such as the network address of the device, the type of browser, the screen size group and the pages requested.
This logging exists so the pages can be delivered, so faults can be found, and so an abusive or automated flood can be recognised and contained. The office does not use these logs to profile a private visitor, does not merge them with a commercial database and does not serve personalised advertising on the basis of a visit to this site.
Visitors who would rather not leave even this small trace are welcome, and many pages read perfectly well through a privacy-minded browser that blocks trackers; the site does not depend on surveillance to function.
Information in the contact forms
When a visitor sends a message through the contact page, the office receives the name, the reply address and the written message. This information is used to answer the enquiry and, where the enquiry concerns a partnership, to open a file for the conversation.
The contact pages do not attach any third party analytics. Because the site keeps no separate form database, a submitted message is delivered to the office mailbox rather than stored in a public queue, and the message is handled under the ordinary mailbox retention described above.
Callers and writers should include only the information needed to progress the enquiry, and should not place sensitive identifiers in the subject line of an unencrypted email where the law does not otherwise require their transmission.
International flows of data
Partnerships that CGP GP FUND I LP administers may welcome capital from more than one jurisdiction, and the parties, auditors and funds may sit in several countries. Where records travel across a border, the office relies on a recognised transfer ground and records the basis in the instruction file.
The office does not move records to a country for the purpose of weakening the protection available to the data subject, and the safeguards described in this policy are applied regardless of where a backup tape or a support engineer happens to be located. Standard contractual protections or the equal protections offered by an adequacy decision will be in place before a transfer is made to a processor in a third country.
A person may ask which transfer tool governs a particular fund, and the office will point to the agreement clause without exposing security-sensitive detail.
Safeguards for children
The partnerships and the public pages of this office are directed at professional investors and at the organisations that administer private capital, and they are not intended for children. The office does not knowingly collect information from or about a child, and a fund record would never be opened on a minor as a capital account holder in the ordinary course.
If the office becomes aware that information about a child has reached it by mistake, that information is deleted without unreasonable delay unless a narrowly defined legal duty binds the office to retain it, in which case the retention is limited to the duty.
A parent or guardian who believes that information about a child reached this office should write to notify@cgpfund.mom, and the request is handled promptly under the rights set out below.
Rights of the individual
Where the law of the residence gives a person rights over their data, the office honours them within the limits of the fund administration duties and the professional obligations that bind a service provider.
- The right to ask whether the office holds records at all and to receive a plain summary of what those records are.
- The right to ask for a copy of the records that relate to the requesting person in a readable, portable form where an agreement permits release.
- The right to ask that inaccurate records be corrected and that out of date contact details be refreshed promptly.
- The right to ask that records not needed for a current lawful duty be deleted, balanced against any accounting or regulatory retention duty.
- The right to object to processing based on a legitimate interest, where the office will then balance the interest again and record the outcome.
- The right to withdraw consent for any optional processing, without penalty and without loss of the service itself.
- The right to complain to the supervisory authority of the place of residence about the handling of a request.
The office verifies the identity of a person who exercises a right, so that it never releases a capital account record to someone who merely impersonates a limited partner. Rights are exercised without prejudice, and a refusal is always accompanied by a reason and by the route to complain.
Complaints and redress
If a person believes this office has mishandled personal information, the first and fastest route is to write to notify@cgpfund.mom so that the privacy responsible can review the file. The office answers a complaint within a reasonable period and records both the complaint and the resolution so that the pattern, if any, is visible.
Where the complaint concerns the conduct of the office itself, the office will investigate without referring the enquirer to the party that caused the issue. Where the complaint concerns the conduct of a general partner over records the general partner controls, the office will still route the matter promptly and keep the enquirer moving rather than letting the matter go cold.
Nothing in this section limits the right of a person to pursue an authority or a court where the law allows, and the office does not require arbitration of a privacy complaint before an authority is approached.
Changes to this policy
The office reviews this policy at least once a year and revises it whenever the services, the law or the security arrangements change in a way a reader should know. The current text, with its effective date at the top, is always the version in force.
Material changes that narrow a protection or add a new use of records are drawn to the attention of general partners who administer funds with the office, because they must be able to judge whether the change matters to their file. Minor housekeeping edits that clarify rather than expand are published without a special announcement.
Historic versions are kept in the office archive so that a person can compare what was promised at an earlier date with what is promised today, if a dispute ever turns on the wording.
How to reach the office
Questions about this policy, about a right, or about a record should be sent to the address and routes below. Include a note of the partnership or the general partner you relate to so the office can find the correct file quickly.
- Postal address: CGP GP FUND I LP, 101 Larkspur Landing Cir Ste 310, Larkspur - 94939-1751, United States (US).
- Email: notify@cgpfund.mom.
- Telephone: +18058220215.
- The office answers during ordinary business hours, Monday to Friday.
The office views a privacy enquiry with the same seriousness it applies to a closing entry, because trust in fund administration is earned one quiet, careful answer at a time. This policy is provided by the developer CGP Fund and is a true reflection of how the office and its systems are designed to behave.