Welcome to www.clovercapitalinc.com (“website”), which is owned and operated by Clover Capital Fund I, L.P and its affiliates (“Clover Capital,” “we,” “our,” or “us”). We have developed this Website Privacy Policy (“Privacy Policy”) to provide you with information about the types of information we may collect from you when you visit our website or otherwise contact us. 

Please note that if you are an investor in one of our funds, you should review the privacy notice(s) provided with your investment documents for additional information on our data collection and use.



If you are a California Resident (as defined below), please review the below section, Additional Information for California Residents, for additional disclosures, our Notice at Collection, and a description of your rights under the California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time, “CCPA”).

What Information We Collect

In general, we or our service providers collect information, including personal information, when you communicate with us and when you use the website. When we use the term “personal information” we mean any information about an individual from which that person can be identified. When you visit and browse the website or communicate with us, you may directly provide us with information, including personal information, and we will collect certain information automatically or through other sources. 

Personal Information You Provide to Us

Depending on how you interact with us, we may collect the following categories of personal information from or about you: 

• identifiers and similar information such as you name, address, email address, online identifiers; 
• audio, electronic, visual, or similar information;
• internet or other electronic network activity information, including interactions with our website or use of certain online tools, and IP addresses; and
• inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds. 

Information Collected Automatically & Use of Cookies 

When you visit our website, certain information about your visit may be automatically logged through the use of cookies and similar tools (collectively “cookies”). Cookies are small text files that are stored in your computer’s memory and hard drive or in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website or other third parties that receive data obtained from that website.

Our website, which is powered by our service provider, may use necessary cookies in order to make our website function and to collect certain analytics information about your visit. We may use service providers, including Google Analytics to collect such information. For more information on (a) how Google Analytics collects and processes such information, please click here, and (b) how to prevent the use of Google Analytics relating to your use of our Website by downloading and installing a browser plug-in, please click here.  You can change your cookie preferences by changing the setting on your web browser to delete or reject cookies.  If you delete or reject cookies, some portions of our website may not function properly.

Our website may also include social media features, such as the Facebook Like button, and widgets, such as the Share This. These features may collect your IP address, which page you are visiting on the website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy statement of the companies that provide them. 

Some web browsers may transmit “do not track” (“DNT”) signals.  Our website will respond to DNT settings in your web browser.

How We Collect Information

We may collect personal information about you directly from you and/or your intermediaries through sources such as: 

• your interactions with our website (e.g., when you create an account and log-in or navigate on the website); 
• when you sign up to receive communications from us; and 
• written, electronic, or verbal correspondence with us or our service providers. 

In addition, we may collect personal information from different sources, such as: 

• our affiliates and service providers; 
• third-party partners; and
• public websites or other publicly accessible directories and sources. 

We may also collect personal information through our use of cookies, as described above in Information Collected Automatically & Use of Cookies.

Why We Collect Information

We may collect or use personal information for any of the following business or commercial purposes: 

• provide our website, products and services; 
• communicating with you, including communications to support our business development and marketing initiatives; 
• managing and administering our services, including establishing and managing business relationships; 
• detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity; 
• complying with our legal obligations and to protect our rights, your rights, and the rights of others, as this may be necessary to meet our own high standards of business practice, as well as establish, exercise or defend legal claims; 
• administering and improving our website; and 
• internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you.  For example, we may prepare aggregated reports about how visitors tend to interact with website for research about the use of website and how it could be improved, from which your interactions with the website cannot be singled out. 

We also may use the personal information we collect about you in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law.

How We May Disclose Information

We may disclose all of the personal information that we collect in the following ways: 

• to service providers, such as administrators, banks, auditors, law firms, consultants and placement agents; 
• at your request or direction or with your consent; and/or 
• as otherwise permitted or required by law or regulation, including, but not limited to, governmental organizations and self-regulatory organizations. 

Additionally, we may share personal information in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Security of Personal Information

We will take reasonable steps to use security measures appropriate to the nature of the information to protect personal information against unauthorized access, exfiltration, acquisition, theft, or disclosure. Given the nature of information security, there is no guarantee that such safeguards will always be successful.

How Long We Keep Information

How long we keep your personal information will vary depending on the type of personal information and our reasons for collecting it. In general, we will retain your personal information for as long as we require it to perform our contractual rights and obligations or for periods required by our legal and regulatory obligations.

Where We Process Your Information

We are based in the U.S. When you provide personal information to us from outside of the U.S., please be aware that we will receive and process it in the U.S. and that U.S. data protection laws may be different from those of your country of residence.

Children’s Information

This website is not intended for use by those over 18, and minors under the age of 13 may not use the website. We do not knowingly solicit or collect personal information on the website from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personal information to us, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).

Your Rights

You can request to receive a copy of the personal information we hold about you, including any data you have provided to us. You can also request that we erase any personal information we hold about you. Please note that this does not include any data we are obliged to keep for administrative, legal, or security purposes.

Additionally, we may send communications about our services and events to you. You can opt-out of these communications through the “unsubscribe” option in our email communications to you or by contacting us using the details in How to Contact Us. 

If you are a California Resident, please review Additional Information for California Residents below for a description of your California-specific rights regarding your personal information. 

Links to External Websites

Our website may contain links to third party websites. Any access to and use of such third party websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

Additional Information for California Residents

The CCPA imposes certain obligations on us and grants certain rights to California residents (“California resident,” “you” or “your”) with regard to “personal information” (as defined in the CCPA). If you are a California resident, please review the following information about our privacy practices surrounding how and why we collect, use and disclose your personal information and your potential rights with regard to your personal information under the CCPA. The rights described in this section are subject to exemptions and other limitations under applicable law and the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal GLBA and its implementing regulations. Terms used in this section have the meaning ascribed to them in the CCPA. We are a “business.” 

Notice at Collection and Use of Personal Information 

Information We Collect 

Depending on how you interact with us, we may collect the categories of personal information listed in What Information We Collect. 

Purpose for Collection and Use of Information 

We also may collect and use personal information from California resident clients for the purposes described in Why We Collect Information. 

Sale or Sharing of Personal Information

We do not sell or share your personal information (as such terms are defined under the CCPA).

How Long We Keep Information

We retain your personal information as described in How Long We Keep Information.

For more information about our privacy practices, please review this entire Privacy Policy.

Our Collection, Use, and Disclosure of Personal Information and Sensitive Personal Information

What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information

In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information listed in What Information We Collect. We may have collected personal information from all or some of the categories of sources listed in How We Collect Information. We may have collected all or a few of these categories of personal information for the business or commercial purposes identified in Why We Collect Information.

Our Disclosure of Personal Information



We do not sell or share your personal information as defined under the CCPA (as those terms are defined under the CCPA). We do not knowingly sell or share the personal information of California residents under 16 years old.  In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as described in the following chart:

In addition, we may have disclosed all of the categories of personal information identified in What Information We Collect, to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in Why We Collect Information. Additionally, we may disclose your personal information to third parties upon your request, at your direction or with your consent.

We may disclose or make available your personal information with our service providers such as our website provider, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in. or as otherwise permitted by, the CCPA. 

Use and Disclosure of Sensitive Personal Information

Under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not collecting or using your sensitive personal information for purposes that would require that we provide you with a right to limit.

California Residents’ Rights under the CCPA

If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: 

• Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used. 
• Not be discriminated against because you exercise any of your rights under the CCPA. 
• Request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”). 
• Opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not). 
• Opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not). 
• Limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit). 
• Correct inaccurate personal information (“Request to Correct”). 
• Request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”). 

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.

How to Submit a Request under the CCPA 

You may submit a Request to Know, Request to Correct or a Request to Delete (“Consumer Rights Request”), as described above, through the following toll-free telephone number [insert toll-free telephone number], by emailing the use at clovercapital@clovergroupinc.com with “CCPA Rights Request” in the subject line, or through our website at the following link www.clovercapitalinc.com/contact-us. 

We are only required to respond to verifiable Consumer Rights Requests made by you or your authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only. 

You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the provided methods. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

Additional Information for California Residents

We may update this Privacy Policy from time-to-time at our sole discretion. If you do not agree to any changes we make to this Privacy Policy, you must not continue to use our services.

How to Contact Us

This Privacy Policy is available in alternative formats upon request. If you have any questions or concerns about this Privacy Policy, or to request this Privacy Policy in an alternative format, please contact us at clovercapital@clovergroupinc.com.

Clover Capital Management, LLC ("Clover Management") is a limited liability company registered in Delaware. Clover Management is seeking registration with the United States Securities and Exchange Commission ("SEC") as an investment adviser under the US Investment Advisers Act of 1940, as amended.  Registration with the SEC does not imply a certain level of skill or training.

Information contained on this website is not an advertisement and does not constitute an offer of any securities or investment advisory services. Any offering may only be made pursuant to applicable securities laws, an offering document and related subscription materials all of which must be read and completed in their entirety. This is not an offering of investment services or any interest in any fund or product managed or advised by Clover Management. 



Any market prices, data and other information are not warranted as to completeness or accuracy and are subject to change without notice. Any comments or statements made herein do not necessarily reflect those of Clover Management.

Please see the important information, including regarding the processing of personal data by Clover Management, at [ ]