Last Updated: March 27, 2025

This Privacy Policy describes the privacy practices of Turner Impact Capital, L.P. (“we”, “us”, or “our”) and how we handle personal information that we collect in connection with your use of our public website or our investor portal (also referenced in this Privacy Policy together as “Websites”), and through other interactions with us.

Please note that while this Privacy Policy applies to our investor portal, which is accessible through our public website, it does not apply to the investment management services we provide to our investors. These services are governed by a separate privacy notice, which is provided at or before the point of collecting, including as part of our subscription agreements.

Personal Information We Collect

Information you provide to us, including through forms, questionnaires and applications, your use of our Websites, and through our business relationship with you.

  • Investment information, such as personal information included in subscription documents, quarterly reports, capital statements, and capital call notices stored on the investor portal.
  • Account information, such as the username, email and password used to access our investor portal, your account settings, details of how you use your account and communications related to account support.
  • Business representatives’ contact data, such as name, company, job role, contact information and communications exchanged with us when engaging as a supplier or investor representative.
  • Other data. We may collect other personal information not specifically listed here, but which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from third parties.

  • Social media. We may maintain pages on social media platforms, such as X, LinkedIn, Facebook, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
  • Other sources. We may obtain your personal information from other third parties, such as publicly available sources, data providers, financial institutions, professional advisors, credit reference agencies, and financial crime databases.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Websites, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our emails or clicked links within them.

We use the following tools for automatic data collection:

  • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns. For more information, please read the “How We Use Cookies” section below.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
How We Use Cookies

We use both persistent cookies and session cookies. Persistent cookies stay on your device for a set period of time or until you delete them, while session cookies are deleted once you close your web browser. The cookies placed through your use of our Websites are either set by us (first-party cookies) or by a third party at our request (third-party cookies).

We use the following categories of cookies:

Analytics Cookies. We use cookies for analytics, for example cookies set by Google Analytics. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Websites. They help us to know which pages are the most and least popular and see how visitors move around the Websites. If you do not allow these cookies we will not know when you have visited the Websites and will not be able to monitor their performance.

Functional Cookies. These cookies enable the Websites to provide enhanced functionality and personalization. If you do not allow these cookies, then some or all of these services may not function properly.

Strictly Necessary Cookies. These cookies are necessary for the Websites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Websites may not work.

For more information on how to reject or opt out of cookies, please read the “Your Rights and Choices” section below.

How We Use Personal Information

We use your personal information for the following purposes:

Operate our Websites. It is in our legitimate business interest to use personal information to ensure you can use our Websites. Where we have entered into a contract with you, we will use your personal information as required for us to perform our contractual obligations towards you.

Communicate with you. To perform our contractual obligations, or when it is in our legitimate business interests, we use personal information to respond to your requests, questions, and feedback, and to communicate with you, including by sending you announcements, surveys, questionnaires, reminders, updates, security alerts, and support and administrative messages.

Improve, monitor, personalize, and protect our Websites. It is in our legitimate business interests to improve and keep our Websites safe for our users, which includes: (i) Understanding your needs and interests and personalizing your experience with our Websites; and (ii) troubleshooting, testing and research and to keep our Websites secure.

Research and development. We process personal information in our legitimate business interests to carry out research and development. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Websites, and promote our business.

Business representative relationships. Where you are a supplier or investor representative, it is in our legitimate business interests to use your personal information to contact you and to manage our relationship with you and/or your company. If we have entered into a contract with you/your company, we will use your personal information as required for us to perform our contractual obligations under the relevant contract.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes where it is in our legitimate business interests to do so, including to: (i) protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims); (ii) audit our internal processes for compliance with legal and contractual requirements and internal policies; (iii) enforce the terms and conditions that govern our Websites; (iv) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and (v) comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

Cookies. We use cookies to collect personal information when you visit our Websites. For non-necessary cookies, such as those used for website analytics, depending on your location, we may rely on your consent to use these cookies. If consent is required, you will see a cookie consent banner where you can manage your preferences. In cases where consent is not requires under applicable law, or where we use necessary cookies (which are essential for providing and securing our Websites), we rely on our legitimate business interests. For more information on how we use these technologies, please read the “How We Use Cookies” section above.

We do not sell your personal information or use your personal information for targeted advertising purposes.

How We Share Personal Information

We may share your personal information with:

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate our business (such as hosting, information technology, user support, email delivery, and website analytics services).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Turner Impact Capital LP (including, in connection with a bankruptcy or similar proceedings).

Your instruction or permission. We share your personal information with other relevant third parties, where you give us permission to do so in the course of your relationship with us from time to time.

Your Rights and Choices

Limit cookies. Depending on your location, you may be presented with a cookie banner or other tool that asks for your permission before setting cookies that are not strictly necessary. In this case, we only set cookies that are not strictly necessary with your consent. You can limit cookies as follows:

  • Blocking cookies in your browser. Most browser settings let you delete and reject cookies placed by websites. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of the Websites and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. Use the following links to learn more about how to control cookies and online tracking through your browser: Firefox; Chrome; Microsoft Edge; Safari (Mac); Safari (Mobile/iOS)
  • Google Analytics. We use Google Analytics to help us better understand how people engage with our Websites by collecting information and creating reports about how users use our Websites. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track”, please visit http://www.allaboutdnt.com.

Personal information requests. Depending on your location and the nature of your interactions with us, you may request the following in relation to your personal information:

  • Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
  • Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
  • Correction of personal information that is inaccurate or out of date.
  • Deletion of personal information we hold about you.
  • Objection to us processing your personal information where we rely on our legitimate business interest to do so.
  • Additional rights, such as to request that we restrict our use of personal information, and where we rely on consent for our processing, you may withdraw your consent to our processing of your personal information. This won’t affect anything we have used your personal information for before you withdraw your consent.

To exercise the above rights, contact us at info@turnerimpact.com or 1702 Olympic Boulevard, Santa Monica, CA 90404. We will not discriminate against you for exercising any of these rights. Prior to responding to your requests, we may verify your identity by matching any requested identifying information you provide against the information we have about you. Depending on your jurisdiction, you may designate an authorized agent to make a request on your behalf. We will require the authorized agent to have a written authorization confirming that authority.

In some instances, your rights and choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information to perform our contractual obligations, if you do not provide this information when requested (or you later ask to delete it), we may not be able to fulfill our obligations. We will indicate any required information at the time of collection or through other appropriate means.

Right to complain. Depending on where you reside, such as if you reside in the European Economic Area (EEA) or United Kingdom (UK), you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. If reside in the EEA click here to find your local supervisory authority. If you reside in the UK, the Information Commissioners Office (ICO) is your data protection regulator.

Other Sites and Services

Our Websites may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Retention

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes described in this Privacy Policy, including to provide access to our Websites and where we have a legitimate business need to do so, such as where the retention is required by law or regulatory obligations (e.g. tax, legal, regulatory or accounting record keeping purposes), to enforce and prevent violations of our terms and conditions of service, or to defend against legal claims. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, any permissions you give us with regards to your personal information and the applicable legal and regulatory requirements.

Data Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe, and we cannot guarantee the security of your personal information.

International Data Transfers

You will provide personal information directly to us in the United States. We may also transfer personal information to our affiliates and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “How to Contact Us” section below.

Children

The Websites are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Websites from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website.

How to Contact Us

Responsible entity. Turner Impact Capital LP is the entity responsible for the processing of personal information under this Privacy Policy (as a controller, where provided under applicable law).

Contact us. If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at info@turnerimpact.com or at the following mailing address:

1702 Olympic Boulevard
Santa Monica, CA 90404