Privacy Policy

Last Updated and Effective March 18, 2025

This Privacy Policy sets forth the privacy practices of Harlan Capital Partners LLC (“HCP” “we,” “our,” or “us”) with respect to our collection, use, sharing, and disclosure of Personal Information, including, but not limited to, Personal Information collected through this website (the “Site”), how it is used, and the circumstances under which it may be shared and disclosed.  This Privacy Policy constitutes a legally binding agreement between you and HCP that conditions your use of the Site, where and as permitted by applicable law.

Personal Information We Collect

When you visit the Site and during our ordinary business activities, HCP may collect or ask you to provide certain nonpublic personal information (“Personal Information”) in order to help us manage our relationship with you and serve your investment needs.  The Personal Information we may collect from you may include personally identifiable information including names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under applicable law, that may be contained in the relevant materials, documents, or obtained through background searches.

Sources of Personal Information

We may collect Personal Information from:

  • Your communications with us;
  • Your transactions with us;
  • Services providers;
  • Affiliates;
  • Nonprofit organizations; and
  • Government entities.

How we Use Personal Information

We use Personal Information for the following business purposes:

  • To provide our products and services;
  • To process your requests and inquires;
  • To offer new products and services;
  • To process transactions;
  • For account maintenance;
  • To confirm your identity;
  • To communicate with you;
  • To improve the Site;
  • To protect the security and integrity of the Site;
  • To prevent or investigate fraud or other unlawful activity, and detect security incidents; and
  • To comply with and enforce applicable legal requirements.

How we Share Personal Information

Your privacy is important to us. HCP does not share any Personal Information to nonaffiliated third parties, except to service or manage a client’s account or as permitted by law. We do not sell any Personal Information.

How we Protect Personal Information

HCP seeks to carefully safeguard Personal Information. We will use commercially reasonable efforts to ensure that Personal Information is kept secure and safe from any loss or unauthorized disclosure or use. We restrict access to our client’s Personal Information to employees requiring that Personal Information to provide our products or services.

Use of Cookies

We may send text files (e.g., “cookies” or other cached files) or images to your web browser to collect and/or store information on your computer. Such text files and images are used to support the operation of our digital offerings and for the technical convenience to store information on your computer. We may use information stored in such text files and images to customize your experience on our Site and to monitor use of our Site. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts or use all features of our Site. You can disable cookies from your computer system by following the instructions on your browser or at http://www.allaboutcookies.org/.

We may also collect and use other information to administer this Site, determine usage levels, diagnose any technical issues relating to this Site, to improve and optimize this Site, to improve the security of this Site and to ensure that this Site otherwise functions properly.

Notice to Residents of the EEA/UK

HCP does not market or otherwise offer its products or services to natural persons who are residents of the European Economic Area or the United Kingdom (collectively, the “EEA/UK”) and, accordingly, does not seek to be subject to the requirements of the EU General Data Protection Regulation (Regulation (EU) 2016/679) or the UK General Data Protection Regulation (together, the “GDPRs”).

If you are a natural person resident in the EEA/UK and provide personal data to HCP in connection with an investment in any HCP-managed fund or related vehicle, we will process such personal data in accordance with applicable law and the terms of the relevant fund documentation. Your personal data may be processed in the United States or in other jurisdictions outside the EEA/UK that may not provide the same level of protection as is afforded under the GDPRs.

Contact Us

If you have any questions or comments about this Privacy Policy, please feel free to contact Maryam Irizarry at maryam@harlancapital.com.