CCPA PRIVACY POLICY

Effective March 20, 2023

This CCPA Privacy Policy provides information required under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”) and describes how Foxhaven Asset Management, LP (the “Company,” “we,” “us,” or “our”) collects, uses, shares and discloses personal information we collect from service providers, independent contractors, and individuals affiliated with our institutional investors, such as their employees or beneficiaries of trust accounts.  The CCPA does not apply to the information we collect from natural persons in their capacity as current or former investors in our funds.  Individual investors should refer to our separate investor privacy notice, which is supplied to them in the subscription materials at the time of their investment (our “Investor Privacy Notice) for information about our privacy practices as applicable to them.  In the event of any conflict between this CCPA Privacy Policy and our Investor Privacy Notice, the terms of our Investor Privacy Notice will control. 

We do not collect any personal information through your use of the websites owned and operated by the Company (“Sites”).  Like most sites, our website will collect certain log data for security and functionality purposes, but we do not associate such information with any individual person as part of our normal business operations. 

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your personal information, we will notify you by posting the revised notice on the Sites and updating the effective date above.

If you have any questions or comments about this Privacy Policy or other privacy-related matters, please contact us at: cp@foxhavencap.com.

If you are a California resident, please read our Privacy Notice for California Consumers below:

CCPA PRIVACY NOTICE

This Privacy Notice was last updated on March 20, 2023.

If you are a resident of the State of California, this CCPA Privacy Notice may apply to you. This CCPA Privacy Notice for California Consumers is only relevant to residents of California, applies only to the collection or other use of “personal information” and “sensitive personal information” that is subject to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”) and is intended to describe your rights under the CCPA and our data collection practices.  Consumers with disabilities may access this notice by requesting a printed copy using the contact information below.  For purposes of this Privacy Notice, “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Personal Information We Collect About You

The information we collect from you depends on your relationship to us, as described further below.

Service Providers and Independent Contractors

In the course of providing business services to us, we may collect or receive personal information from you.  In most cases, we will receive your business contact information.  Where you are an independent contractor or enter into a contract directly with us, in certain situations as required by law, we may also receive certain personal information via your W-9, such as your social security number.

In the past 12 months, we may have collected the following categories of sensitive personal information or other personal information about California consumers who are service providers and independent contractors, in accordance with the following chart:

Category	Examples of personal information we may collect
A. Identifiers.	A real name, alias, postal address, email address, Social Security number, or other similar identifiers.
B. Personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, address, telephone number, education, or employment history.  Some personal information included in this category may overlap with other categories.
C. Commercial information.	Information such as your PayPal account number where we use that information to pay you.
D. Internet or other similar network activity.	Log files, which may collect IP address or similar information.
E. Professional or employment- related information.	Current or past job history and other employment related data.

Individuals Associated With Institutional Investors

Current or former natural person investors in our funds should refer to our Investor Privacy Notice for information about our privacy practices.  In addition to natural person investors, we may receive personal information about individuals associated with our institutional investors, such as their employees, account holders, or beneficiaries, for a number of purposes, including to provide our investment services and conduct Know Your Customer (“KYC”) diligence.  We typically receive this information directly from our institutional investor, who may be your employer, but may also receive this information from other publicly available sources or third parties.

In the past 12 months, we may have collected the following categories of sensitive personal information or other personal information about California consumers, in accordance with the following chart:

Category	Examples of personal information we may collect
A. Identifiers.	A real name, alias, postal address, email address, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment history, resume, cover letter or background check application.  Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	Information classified as personal or protected information by state, federal or other applicable law, including your nationality, age, race, marital status, date of birth, gender, veteran or military status. With your permission or as permitted by applicable law, information obtained through background checks.
D. Commercial information.	Information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity.	Log files, which may collect IP address or similar information, if you visit our Site.
F. Professional or employment- related information.	Current or past job history.
G. Inferences drawn from other personal information.	Profile reflecting a characteristics, such as information used for KYC purposes.

Sensitive Personal Information We Collect About You

We may collect personal information that is also considered “sensitive personal information” under the CCPA. As described, the information we collect will depend on our relationship with you.  The sensitive personal information may include social security, driver’s license, or passport numbers.  We use sensitive personal information only for limited, lawful purposes in compliance with the CCPA and do not use sensitive personal information collected from Service Providers and Independent Contractors to infer characteristics about you.  We may use some information about individuals associated with individual investors for KYC purposes or otherwise to comply with law or regulations.

Sources of Personal Information

We may obtain personal information, including sensitive personal information, from the following sources:

• Your communications with us; 
• Service providers;
• Affiliates; and
• Directly from you.

Business or Commercial Purposes for Collecting, Using, and Disclosing Personal Information

The above personal information may be processed for the following purposes:

• Processing that is necessary for compliance with applicable legal or regulatory obligations and to comply with requests from regulatory, governmental, tax, and law enforcement authorities;
• Managing and operating our business and managing investor accounts, including through the use of third party service providers;
• Sending updates, information, and notices or otherwise corresponding with you;
• To comply with applicable laws and regulations, including without limitation, any anti money-laundering law and the USA PATRIOT ACT, employment laws, tax laws, and related laws and regulations;
• Protecting against fraud, breach of confidence or theft of proprietary materials; and
• Facilitating business asset transactions.

We will not process any personal information where not permitted by law.  We respect and comply with applicable rights under that National Labor Relations Act.

Third Parties to Whom We May Disclose Personal Information 

To carry out the processing purposes outlined above, we may disclose personal information with our affiliates as well as third parties such as information technology vendors, outside legal counsel, and all governmental agencies as required for legal or regulatory purposes. We may also disclose personal information to third parties as needed to protect the legitimate interests of Company, including to establish or defend the Company’s legal rights, as well in the event that we sell any part of our business, reorganize, liquidate, and/or combine with another organization.

Sale, Sharing, and Retention of Personal Information

We do not sell personal information, nor do we share such information for purposes of cross-context behavioral advertising and have not done so within the past 12 months.  We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. 

Your Privacy Rights Under California Law 

Residents of California have certain rights regarding their personal information. Those rights include:

• The right to know what personal information we collect, including (1) the right to request information regarding the categories of personal information we collect along with other information such as the categories of sources from which the information is collected and third parties with whom it is shared and (2) the right to request a copy of the specific pieces of personal information we collect (sometimes referred to as the right to access personal information);
• The right to delete personal information that we collect from you, subject to certain exceptions;
• The right to correct inaccurate personal information that we maintain about you;
• The right to opt-out of the sale or sharing of personal information—since we do not sell or share personal information, as those terms are defined under the CCPA, you are already opted-out;
• The right to limit the use of sensitive personal information in some circumstances; and
• The right not to be retaliated or discriminated against for exercising any of these rights in good faith; however, we reserve all rights we may have under law with respect to requests made in bad faith or that are manifestly unfounded or excessive.

If you want to exercise any of these rights, please submit a request by contacting cp@foxhavencap.com. We will review your request and respond accordingly. The rights described herein are not absolute and we reserve all our rights available to us at law in this regard. If you make a request with respect to your personal information, you may be required to validate your identification as a security precaution.  If it is necessary to collect additional information, the Company will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.  We will process your request within the time provided by applicable law.

Contact Us

If you have any questions or concerns about this CCPA Privacy Policy, please contact us at: cp@foxhavencap.com.