Privacy Policy
Last Updated: March 2026
Frontenac collects personal data about you from your use of this website. For the purposes of applicable European privacy laws, we are a controller of Personal Data provided by you through your use of our website. This privacy notice (the “Privacy Notice”) explains how we collect Personal Data obtained from you through your use of our website.
Please read this Privacy Notice carefully. If you do not agree with the processing of your Personal Data in accordance with this Privacy Notice, please do not access or otherwise use this website.
What Personal Data do we collect?
Personal Data is any information relating to you or that we can otherwise link to you. The Personal Data we collect on or via this website may include your name, email address, address and other contact information.
We may also collect information about your use of the website when you enter and browse the website through the use of “cookies,” web server logs and other electronic tools and automated technology. This information may include, without limitation, the number and frequency of your visits to the website, the websites accessed before and after you visit the website, the internet browsers used by you and your IP addresses. Further information regarding our use of cookies is set out in our Cookie Policy.
We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect Personal Data from anyone under the age of 18 without parental consent. If we learn we have collected or received Personal Data from an individual under the age of 18, we will delete that Personal Data.
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
How do we collect Personal Data?
We collect Personal Data that you voluntarily provide to us, such as through forms you choose to submit to contact us to obtain more information about Frontenac. We may also collect Personal Data through the use of automated technology including cookies on our website.
This Privacy Notice does not address our processing of any Personal Data collected from an investor in funds that we sponsor or manage. We address such processing in separate notices to investors as required by law.
How do we use your Personal Data?
We use the Personal Data we collect from you on our website for communication purposes, such as to send you information about Frontenac and to maintain our list of contacts, and for security and fraud prevention. We also process your Personal Data for communication and marketing purposes.
Please see the section “What legal basis do we use to process your Personal Data” for further details on the purposes and legal bases that we rely on to process your Personal Data.
What legal basis do we use to process your Personal Data?
Under European privacy laws, we rely on various legal bases to process your Personal Data, including our legitimate business interests in maintaining business relationships and communicating about Frontenac’s business, contractual necessity and as required by law. We use the Personal Data we collect to operate our business and provide you with the products and services we offer and perform essential business operations.
To the extent that you provide us with any Personal Data, through or in connection with this website, we may use such Personal Data for the following purposes, and on the following legal bases:
| Purpose | Legal Basis |
|---|---|
| To provide you with the services or financial products you have requested. | Contractual necessity |
| To keep a record of your relationship with us. | Legitimate interest |
| To verify your identity. | Legal requirement and legitimate interest |
| To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to. | Legitimate interest |
| Website security, fraud and abuse prevention. | Legal requirement and legitimate interest |
| Litigation management and conducting internal audits and investigations. | Legal requirement and legitimate interest |
| To administer and protect our business and this website | Legitimate interest |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | Legitimate interest |
Note that we may process your Personal Data on more than one legal basis depending on the specific purpose for which we are using your Personal Data. No automated decision making, including profiling, is used when processing your Personal Data.
Do we use your Personal Data for marketing?
We will send you direct marketing communications where we have obtained your prior consent to keep you informed of our products and services in which you might be interested, or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested.
You may opt-in to certain kinds of marketing, and all forms of marketing at any time, by emailing info@frontenac.com. You can also click on the “opt-out” link provided in all our marketing emails.
To whom do we disclose your Personal Data?
We will not disclose your Personal Data to third parties except for affiliates and third party service providers who act as our processors as necessary to fulfil the purposes set out in this Privacy Notice, including software providers, data hosting providers and security providers (e.g., we disclose online identifiers such as IP addresses to service providers to detect malicious traffic, prevent fraud and maintain the technical integrity of our website).
Where required, we will ensure that contractual safeguards are implemented with these third-party data processors to ensure the protection of your Personal Data (including, where European privacy laws apply, entering into an agreement with the relevant third party and making sure that such third party meets our standards of data security). To the extent your Personal Data is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable European privacy laws. For further information about the safeguards used, please contact us using the details below.
We reserve the right to disclose your Personal Data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your Personal Data to the new owner of the relevant business and their advisors.
The website may contain links to other websites which are not hosted, affiliated or operated by us. These websites may use automated means to collect information regarding your use of the websites. Your use of such websites is subject to the privacy policies or notices of the provider’s website.
How long do we retain your Personal Data?
Your Personal Data will be retained for as long as is reasonably necessary for the purposes set out in the Privacy Notice, or longer as required by applicable law. We will not keep more Personal Data than we need for those purposes.
Your Personal Data may be deleted when it is no longer relevant or when you withdraw consent (see the section “What are my rights with respect to my Personal Data?” below), again within the parameters of applicable law. You may unsubscribe at any time from communications from us, and we will cease sending you further communications based on your consent.
What are my rights with respect to my Personal Data?
- You have the right to know what Personal Data we process about you and have the right to obtain specific information about such Personal Data and to request a copy of your Personal Data, free of charge (though we may charge a reasonable fee, if we think that your request is excessive, to help us cover the costs of locating the information you have requested).
- You are also entitled to request that we correct or supplement inaccurate Personal Data without delay, unless the request is excessive or unfounded.
- You have the right to request that your Personal Data be deleted if it is no longer necessary for the purposes it was originally collected or processed, subject to applicable law and legal obligations of Frontenac.
- You have the right to restrict processing of your Personal Data in some circumstances (other than storing it), subject to any legal obligations of Frontenac, if:
- You have the right to receive your Personal Data in a machine-readable format and request a transfer of the Personal Data to another party responsible for data processing to the extent that the processing was carried out by automated means.
- You have the right to object to processing your Personal Data including:
- If you previously gave us your consent (by a clear affirmative action) to allow us to process your Personal Data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You also have the right to lodge a complaint with the relevant data protection authority.
What security do we have in place over your personal data?
Frontenac has implemented appropriate technical and organizational security measures to help protect your Personal Data against loss and to safeguard your Personal Data against access by unauthorized persons. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
What are our procedures in the event of a breach to your Personal Data?
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data, we will notify the applicable supervisory authority in the European Union within 72 hours of discovering the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons. We will also notify each affected subject of a breach without undue delay if the breach is likely to result in a high risk to the rights and freedoms of natural persons.
We are not required to notify you of a breach if the breached data is encrypted, if we have taken measures, such as wiping the data remotely, and such breach is unlikely to result in a material adverse effect, or if providing notice requires disproportionate efforts, in which case a public communication should be made, rather than notice to each person.
Updates to this privacy statement
This Privacy Notice was updated in January 2026. We may amend this Privacy Notice from time to time to reflect changes in our practices with respect to the processing of Personal Data or changes in applicable law. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
If at any point we decide to collect Personal Data or use any collected Personal Data in a manner different from that stated at the time it was collected, we will notify applicable users. We will use Personal Data only in accordance with the privacy notice under which the Personal Data was collected.
Contact
If you have any questions about how we process your Personal Data, please contact us at info@frontenac.com or at 1-800-368-3581.
California Website Privacy Notice
Last Updated: March 2026
This California website privacy notice (the “California Privacy Notice”) supplements the Privacy Notice with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA.
This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this California Privacy Notice is otherwise set forth in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
What does this California Privacy Notice apply to?
This California Privacy Notice applies solely to your interactions with us through our website (as defined below) or as outlined in the Privacy Notice above. If you provide personal information to us through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.
What information do we collect about you?
We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic or physical communications (e.g., physical mail, emails or social media messaging), and the other collection points as described the Privacy Notice above (collectively, the “website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of website personal information we have collected from individuals over the last twelve (12) months include the following:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number). | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets). | YES |
| C. Protected classification characteristics under California or federal law | Date of birth, citizenship and birthplace. | NO |
| D. Commercial information | Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s). | NO |
| E. Biometric information | Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. | NO |
| F. Internet or other similar network activity | Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries | YES |
| G. Geolocation data | Physical location or movements. | NO |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information | Current or past job history or performance evaluations. | YES |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | YES |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
| L. Sensitive Personal Information | Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. | YES, as to the following types of information: account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only. |
We do not collect or use sensitive personal information other than:
- To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
- As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
- As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
- For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
- To perform services on behalf of our business; and
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
How do we use your personal information?
We collect personal information for the business or commercial purposes and from the sources set forth in the Privacy Notice above. We retain the categories of personal information set forth above in the “What information do we collect about you?” section of this California Privacy Notice only as long as is reasonably necessary for those business or commercial purposes set forth in the Privacy Notice above, except as may be required under applicable law, court order or government regulations.
To whom do we disclose your personal information?
We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties. Within the last twelve (12) months, we have disclosed personal information collected in connection with this website for a business or commercial purpose to the categories of third parties indicated in the chart below, and to affiliates and service providers, including, but not limited to, administrators, lenders, banks, auditors, law firms, state and federal governmental agencies or pursuant to legal process, regulatory entities, self-regulatory organizations, consultants, third-party due diligence providers and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
| Personal Information Category | Category of Third-Party Recipients |
|---|---|
| A. Identifiers | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| C. Protected classification characteristics under California or federal law | N/A |
| D. Commercial information | N/A |
| E. Biometric information | N/A |
| F. Internet or other similar network activity | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
| G. Geolocation data | N/A |
| H. Sensory data | N/A |
| I. Professional or employment-related information | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
| K. Inferences drawn from other personal information | N/A |
| L. Sensitive Personal Information | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
How do we keep your personal information secure?
We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
- the categories of personal information we collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties to whom we disclose the personal information;
- the specific pieces of personal information we have collected about you; and
- whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.
Contact
For any requests relating to the exercise of your rights under the CCPA, to access this notice in an alternative format, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the following methods below:
- Call: 312-368-0044. If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number through the below options, and we will call you during business hours.
- Submit a request online using the following online form: https://frontenac.com/contact-us/
- Email us at the following email address: info@frontenac.com
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request.
You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. Please contact us at info@frontenac.com with any questions about this California Privacy Notice.