Revised: September 2026

What Baird Does with Your Personal Information

Why?

Financial companies choose how they share your personal information.  Federal and state laws give consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.  

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Name, address and contact information
  • Demographic information, such as date of birth, gender, and citizenship
  • Social Security number and/or driver’s license, passport or other government ID number
  • Employment and professional information
  • Financial and other information needed to open or maintain an account or use our services, such as account balances, transaction history and credit history
  • Income and assets
  • Files and images/photos (In connection with your use of Baird Online Mobile Application Only)
  • Telephone call information (calls to Baird’s operations department are monitored and recorded for quality assurance and training purposes)
  • Device ID and IP address, OS version and type, browser version and type, geolocation, and information on how you interact with us (In connection with your use of Baird websites and mobile applications)  

How?

All financial companies need to share customers’ personal information to run their everyday business.  In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Robert W. Baird & Co. Incorporated and Baird Trust Company (“Baird”) choose to share; and whether you can limit this sharing.  

Reasons We Can Share Your Personal Information

  Does Baird
share?
Can you limit
this sharing?
For our everyday business purposes—
such as to process your transactions, maintain your account(s), authenticate your identity, track and prevent fraud, comply with anti-money-laundering laws, respond to regulatory inquiries, court orders and legal investigations, or report to credit bureaus  
Yes No
For our marketing purposes —
to offer our products and services to you
Yes No
For joint marketing with other financial companies Yes No
For our affiliates’ everyday business purposes —
information about your transactions and experiences
Yes No
For our affiliates’ everyday business purposes —
information about your creditworthiness
No N/A
For our affiliates to market to you No N/A
For nonaffiliates to market to you—only for financial advisors that leave Baird. Robert W. Baird & Co. Incorporated has signed the Protocol for Broker Recruiting (“Protocol”) which allows the financial advisor servicing your account to take certain limited information in the event he/she leaves Robert W. Baird & Co. Incorporated and joins another firm which has also signed the Protocol. The information your financial advisor can take is limited to your name, your address, your phone number, your email address, and the title of your account. If you choose to limit this sharing, Baird will notify your financial advisor of your decision to keep your personal information confidential and that you do not want your personal information shared by your financial advisor with his/her new firm.   Yes Yes

 

To limit our sharing:

  • Call (toll free) 1-800-792-2473 or email privacy@rwbaird.com

  • If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing as described above.

Questions? Call (toll free) 1-800-792-2473 or go to www.rwbaird.com

Who We Are

Who is providing this notice?

  • Robert W. Baird & Co. Incorporated and Baird Trust Company

What We Do

How does Baird protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law.  These measures include computer safeguards and secured files and buildings.  

How does Baird collect my personal information?

We collect your personal information, for example, when you

  • open an account or seek advice about your investments
    • tell us about your investment or retirement portfolio or
    • tell us about your investment or retirement earnings
  • use Baird’s websites and/or mobile applications
  • give us your contact information
  • become a beneficiary of a trust or an estate

We also collect your personal information from others, such as credit bureaus, affiliates or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

  • sharing for affiliates’ everyday business purposes—information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See “Other Important Information” below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else?

  • Your choices will apply to everyone on your account unless you tell us otherwise. In other words, any account holder may express a privacy preference on behalf of the other joint account holders.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Our affiliates are Baird Financial Group, Inc., Baird Financial Corporation, Robert W. Baird Group Limited, Robert W. Baird GmbH, Baird Funds, Inc., Baird Strategas LLC and Strategas Asset Management, LLC.  

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Nonaffiliates with whom Baird shares your information for the reasons identified above include service providers that provide services on Baird’s behalf, including IT service providers; legal and other professional advisors and auditors; regulators and law enforcement agencies; the new firm of the financial advisor servicing your account.  

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Baird does not currently have any joint marketing partners.

For Nevada residents only. We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by following the directions in the “Can you limit this sharing” section by choosing to limit sharing “For our affiliates to market to you.” Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101; Phone number: (702) 486-3132; e-mail: BCPlNFO@ag.state.nv.us. Robert W. Baird & Co. Incorporated, 777 East Wisconsin Avenue, Milwaukee, WI 53202; Phone Number (800) 792-2473; e-mail: privacy@rwbaird.com. Click on “Contact Us” under the heading “About Us” in the top right corner at https://www.rwbaird.com/help/privacy-notice/ for our mailing address and business hours.

Vermont: In accordance with Vermont law, we will not share information we collect about Vermont residents with companies outside of our corporate family, except as permitted by law, such as with your consent, to service your accounts or to other financial institutions with which we have joint marketing agreements. We will not share information about your creditworthiness within our corporate family except with your authorization or consent, but we may share information about our transactions or experiences with you within our corporate family without your consent.

California: In accordance with California law (to the extent applicable), we will not disclose information we collect about you with companies outside of Baird, unless the law allows. For example, we may disclose information, to service your accounts, to provide rewards or benefits you are entitled to or to provide you with targeted advertising (to the extent you have not opted out of such advertising). We will limit disclosing information among our companies to the extent required by California law. We collect personally identifiable information from online customers when those customers use Baird’s websites and/or online services (including mobile applications). This information includes, but is not limited to, customer names, e-mail and mailing addresses, phone numbers, and social security numbers. Baird also does not Share (as defined by the California Consumer Privacy Act of 2018 (“CCPA”)) personally identifiable information with third-party persons or entities in the event the customer opts-out of such Sharing, unless otherwise authorized by applicable law. Baird has implemented Global Privacy Control to honor opt-out requests of California residents that do not want their personal information ”Shared”. If Baird’s online customers wish to change the contents of the personally identifiable information previously supplied to Baird, those customers may do so by contacting their local Baird entity branch office and requesting the change. Alternatively, some websites and online services offered by Baird permit customers to change the contents of their personally identifiable information online. Baird cannot guarantee protection from web-based criminal conduct that could result in the collection of an online customer’s personally identifiable information by an outside party. Please refer to https://www.rwbaird.com/globalassets/pdfs/help/ccpa-addendum-to-privacy-notice.pdf for additional information specific to CCPA, as amended.

For EU and UK Customers only. Under certain circumstances, you have the right to i) ask for us to correct inaccurate personal information, and to have any incomplete information completed and for us to pass this on to other recipients of your personal information; ii) request erasure of your personal information and for us to pass this on to other recipients of your personal information; iii) request the restriction of processing and for us to pass this on to other recipients of your personal information; iv) obtain from us confirmation as to whether or not your personal information is being processed and where that is the case, access your personal information and details regarding the processing of that information; v) not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you; vi) where the processing is based on your consent, object to processing and/or withdraw your consent without affecting the lawfulness of processing based on consent before its withdrawal; and vii) request us to transfer your information to another party. You may make a complaint if you believe that we have not complied with our data protection obligations. We hope that you will be able to resolve this issue with us directly by contacting us via telephone at 1-800-792-2473 or by email at privacy@rwbaird.com.  However, you also have the right to complain to the Information Commissioner’s Office. We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorized disclosure of information. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your information, and for any additional copies of the personal information you request from us. We endeavor to respond to any requests or complaints within a month or less, although we reserve the right to extend this period for complex requests.

For Insurance Customers in AZ, CA, CT, GA, IL, ME, MA, MN, MT, NV, NJ, NC, OH, OR, and VA only. The term “Information” in this part means customer information obtained in an insurance transaction. We may give your Information to state insurance officials, law enforcement, group policy holders about claims experience, or auditors as the law allows or requires. We may give your Information to insurance support companies that may keep it or give it to others. We may share medical Information so we can learn if you qualify for coverage, process claims, or prevent fraud or if you say we can. To see your Information or to request correction or deletion of your Information, contact the employee who services your account by mail or telephone. You must state your full name, address, the insurance company, policy number (if relevant), and the Information you want. We will tell you what Information we have. You may see and copy the Information (unless privileged) at our office or ask that we mail you a copy for a fee. If you think any Information is wrong, you must write us. We will let you know what actions we take. If you do not agree with our actions, you may send us a statement.

For MA Insurance Customers only. You may ask in writing the specific reasons for an adverse underwriting decision. An adverse underwriting decision is where we decline your application for insurance, offer to insure you at a higher than standard rate, or terminate your coverage.

Baird may change this privacy notice at any time, and any changes or updates will be effective immediately on the date of posting. For a current version, please visit www.rwbaird.com/help/privacy-notice/.  

Baird Capital Management Company LLC
Baird Capital Blue Matter CV GP LP
Baird Capital Global GP III LLC
Baird Capital Global Fund Management II LLC
Baird Capital Global Fund Management I LP
Baird Venture Partners GP VI LLC
Baird Venture Partners Management Company V LLC
Baird Venture Partners Management Company IV LLC
Baird Venture Partners Management Company III LLC


Our Commitment to Your Privacy: Federal law requires us to tell consumers how we collect, share, and protect their personal information. We are sensitive to the privacy concerns of our individual limited partners and clients.  We have a policy of protecting the confidentiality and security of information we collect about you.  We are providing you this notice to help you better understand why and how we collect certain personal information, the care with which we treat that information, and how we use that information. Please read this notice carefully to understand what we do. 

Types of Non-Public Information:

  • Name, address, and contact information;
  • Social Security number and/or driver’s license, passport or other government ID number;
  • Demographic information, such as date of birth, gender, and citizenship
  • Device ID and IP address, OS version and type, browser version and type, geolocation, and information on how you interact with us (In connection with your use of the Baird Capital website);
  • Financial and other information needed to invest in a fund

Sources of Non-Public Information: In connection with forming and operating our private investment funds (or “funds”) and/or performing asset management services for our investors and clients, we collect and maintain non-public personal information from the following sources:

  • Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail and other electronic communications or in subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation);
  • Information about your transactions with us or others; and
  • Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms and any information captured via “cookies.”

Disclosure of Information: We need to share your personal information in order to operate our funds and perform asset management services or otherwise run our everyday business.  In the section below, we list the reasons we may choose to share your personal information; and whether you can limit this sharing. Our policy is to not disclose any non-public personal information about you to anyone, except as permitted by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, tax advisors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

Reasons we can share your personal information

Do we share?

Can you limit this sharing?

For our everyday business purposes —
such as to process your subscription agreement, maintain investment in a fund or funds, authenticate your identity, track and prevent fraud, comply with anti-money-laundering laws, respond to regulatory inquiries, court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes —
to offer our products and services to you

Yes

No

For joint marketing with other financial companies

No

N/A

For our affiliates’ everyday business purposes —
information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes —
information about your creditworthiness

No

N/A

 

For our affiliates to market to you

No

N/A

Why Can’t I Limit All Sharing: Federal law gives you the right to limit only:

  • sharing for affiliates' everyday business purposes—information about your creditworthiness
  • affiliates from using certain information to market to you
  • sharing for nonaffiliates to market to you

Former Investors and Clients We maintain non-public personal information of our former investors and clients and apply the same policies that apply to current investors and clients.

Information Security We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your non-public personal information in our possession or under our control.

Further Information We reserve the right to change our privacy policies and this Privacy Notice at any time.  We will notify you of any changes to our information disclosure policy that would expand the scope of recipients of your non-public information beyond these categories specified in this notice.  The examples contained within this notice are illustrations only and are not intended to be exclusive.  This notice is intended to comply with the privacy provisions of applicable U.S. federal law and certain provisions of other laws.  You may have additional rights under other foreign or domestic laws that apply to you, including as set forth in our additional privacy notices.

Privacy Notice Supplement for California Residents

September 2026

This notice supplements the Privacy Notice set forth above 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.  Additionally, this supplement does not apply to personal information outside the scope of the CCPA, which includes personal information publicly available from government records, deidentified or aggregate consumer information, or personal information covered by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act (“GLBA”), and implementing regulations, or the California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”). This supplement also does not apply to personal information bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living as set forth in the Fair Credit Reporting Act (“FRCA”). 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 CCPA supplement is otherwise set forth above 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.

Categories of Personal Information We Collect and Categories of Service Providers and Third Parties with whom Personal Information is Disclosed: The below chart lists the categories of personal information that we may collect and have collected in the past 12 months and how we disclose such information. We disclose such personal information for the business or commercial purposes described below.

Category of Personal Information

Categories of Service Providers and Third Parties with whom Personal Information is Disclosed

A. Identifiers. This may include a real name, postal address, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Affiliates and subsidiary organizations of ours, service providers, advertising networks and partners, prospective purchasers of our business, entities or persons that we are required to disclose to pursuant to law or for legal proceedings, self-regulatory organizations, and governmental entities.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). This may include a name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, employment information, bank account number, or any other financial information, or medical information.

Affiliates and subsidiary organizations of ours, service providers, prospective purchasers of our business, entities or persons that we are required to disclose to pursuant to law or for legal proceedings, self-regulatory organizations, and governmental entities.

C. Protected classification characteristics under California or federal law. This may include but not be limited to age, citizenship, or marital status.

Affiliates and subsidiary organizations of ours, service providers, prospective purchasers of our business, entities or persons that we are required to disclose to pursuant to law or for legal proceedings, self-regulatory organizations, and governmental entities.

D. Commercial information. This may include records of personal property, business records, property records, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Affiliates and subsidiary organizations of ours, service providers, prospective purchasers of our business, entities or persons that we are required to disclose to pursuant to law or for legal proceedings, self-regulatory organizations, and governmental entities.

E. Internet or other similar network activity. This may include browsing history, device identifier, search history, information on a consumer’s interaction with a website, application, or advertisement.

Affiliates and subsidiary organizations of ours, service providers, advertising networks and partners, prospective purchasers of our business, entities or persons that we are required to disclose to pursuant to law or for legal proceedings, self-regulatory organizations, and governmental entities.

G. Inferences drawn from other personal information. This may include a profile reflecting a person’s preferences as it relates to client relationship references.

Affiliates and subsidiary organizations of ours, service providers, advertising networks and partners, prospective purchasers of our business, entities or persons that we are required to disclose to pursuant to law or for legal proceedings, self-regulatory organizations, and governmental entities.

Within the last twelve (12) months, we have not sold personal information in exchange for money. We collect personal information from the sources set forth in “Sources of Non-Public Information” in the Privacy Notice above.

Purposes for Collecting Personal Information: We may collect or share the personal information we collect about you for one or more of the following business or commercial purposes:

  • performing services to you, including but not limited to:
  • the administrative processes (and related communication) in preparing for the admission of investors to the fund(s);
  • ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund;
  • the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
  • ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
  • keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
  • auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and
  • complying with U.S., state, local and non-U.S. laws, rules and regulations.

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 exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you.  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;
  • Categories of third parties with whom we share 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 so, 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.

Retention Period: We retain the information listed above in accordance with its data retention policies or as otherwise may be required by law. We use the following standards to determine retention periods: the time required to fulfill business purposes, maintain business records, and comply with legal obligations.

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 using any of the methods set forth below.

  • Call using the following toll-free number: 1-800-792-2473
  • Submit a request online using the following online form: https://bol.rwbaird.com/TechSupportForm
  • Email the following email address: FundTeam-BairdCapital@rwbaird.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 your investor portal access credentials 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.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request.  We will inform you in writing if we cannot meet that timeline.  Please contact Nick Pruhs at npruhs@rwbaird.com with any questions about this Privacy Notice.

 

GDPR Privacy Notice

March 2026

This GDPR Privacy Notice (this “GDPR Privacy Notice”) applies to the extent that UK and EU Data Protection Legislation applies to the processing of personal data by an Authorized Entity (as defined below).  If this GDPR Privacy Notice applies, the relevant data subject has certain rights with respect to such processing of their personal data, as outlined below. 

For this GDPR Privacy Notice, “UK and EU Data Protection Legislation” means all applicable legislation and regulations relating to the protection of personal data in force from time to time in the EU, the EEA, or the UK, including (without limitation): (a) Regulation (EU) 2016/679 (the General Data Protection Regulation); (b) the General Data Protection Regulation as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018; and (c) any other legislation which implements any other current or future legal act of the European Union or United Kingdom concerning the protection and processing of personal data and any national implementing or successor legislation, and including any amendment or re-enactment of the foregoing.  The terms “data controller”, “data processor”, “data subject”, “personal data” and “processing” in this GDPR Privacy Notice shall be interpreted in accordance with the applicable UK and EU Data Protection Legislation.

Please contact FundTeam-BairdCapital@rwbaird.com with any queries arising out of this GDPR Privacy Notice.

Categories of personal data collected and lawful bases for processing

In connection with offering, forming and operating private investment funds for potential investors, the Fund, the Parallel Fund, the Fund Manager, the Management Company and each of their respective Affiliates (each capitalized term is defined in the fund offering documents) and, in each case, their administrators, legal and other advisors and agents (each, an “Authorized Entity>” and together, the “Authorized Entities”) collect, record, store, adapt, and otherwise process and use personal data either relating to potential investors or to their partners, officers, directors, employees, shareholders, ultimate beneficial owners or affiliates or to any other data subjects from the following sources (and all references to “potential investor(s)” in this GDPR Privacy Notice shall be to such potential investor(s) and, as applicable, any of these other persons as relate to such potential investor(s)):

  1. information received in telephone conversations, in voicemails, through written correspondence, via e-mail, or on subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification, and verification documentation);
  2. information about transactions with any Authorized Entity or other persons;
  3. information captured on any Authorized Entity’s website(s), fund data room and/or investor reporting portal (as applicable) including registration information and any information provided through online forms and any information captured via “cookies”; and
  4. information from available public sources, including from:
    • publicly available and accessible directories and sources;
    • bankruptcy registers;
    • tax authorities, including those that are based outside the UK and the EEA if the applicable data subject is subject to tax in another jurisdiction;
    • governmental and competent regulatory authorities to whom any Authorized Entity has regulatory obligations;
    • credit agencies; and
    • fraud prevention and detection agencies and organizations.

Any Authorized Entity may process the following categories of personal data:

  1. names, dates of birth and birth place;
  2. contact details and professional addresses (including physical addresses, email addresses and telephone numbers);
  3. account data and other information contained in any document provided by potential investors to the Authorized Entities (whether directly or indirectly);
  4. information regarding your use of an Authorized Entity’s website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history);
  5. risk tolerance, transaction history, investment experience and investment activity;
  6. information regarding a potential investor’s status under various laws and regulations, including such person’s social security number, tax status, income and assets;
  7. accounts and transactions with other institutions;
  8. information regarding a potential investor’s interest in the Fund, including ownership percentage, capital investment, income and losses;
  9. information regarding a potential investor’s citizenship and location of residence;
  10. source of funds used to make the investment in the Fund; and
  11. anti-money laundering, identification (including passport and drivers’ license), and verification documentation.

Any Authorized Entity may, in certain circumstances, combine personal data it receives from a potential investor with information that it collects from, or about such potential investor.  This will include information collected in an online or offline context.

One or more of the Authorized Entities are “data controllers” of personal data collected in connection with the Fund. In simple terms, this means such Authorized Entities: (i) “control” the personal data that they or other Authorized Entities collect from potential investors or other sources; and (ii) make certain decisions on how to use and protect such personal data.

There is a need to process personal data for the purposes set out in this GDPR Privacy Notice as a matter of contractual necessity under or in connection with the Partnership Agreement and associated Fund documentation, and in the legitimate interests of the Authorized Entities (or those of a third party) to operate their respective businesses.  From time to time, an Authorized Entity may need to process the personal data on other legal bases, including the following: with consent; to comply with a legal obligation; if it is necessary to protect the vital interests of a potential investor or other data subjects; or if it is necessary for a task carried out in the public interest.

A failure to provide the personal data requested to fulfill the purposes described in this GDPR Privacy Notice may result in the applicable Authorized Entities being unable to provide the services in connection with the Partnership Agreement, the attached Subscription Agreement and/or any other agreement agreed to in connection with the investor’s investment in the Fund.

Purpose of processing

The applicable Authorized Entities process the personal data for the following purposes (and in respect of paragraphs (c), (d) and (f), in the legitimate interests of the Authorized Entities):

  1. The performance of obligations under the Partnership Agreement and/or the attached Subscription Agreement (and all applicable anti-money laundering, know-your-customer and other related laws, rules and regulations) in assessing suitability of potential investors in the Fund.
  2. The administrative processes (and related communication) carried out between the Authorized Entities in preparing for the admission of investors to the Fund.
  3. Ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the Fund.
  4. The ongoing administrative, accounting, reporting and other processes and communication required to operate the business of the Fund in accordance with the Partnership Agreement and other applicable documentation between the parties.
  5. Any legal or regulatory requirement.
  6. Keeping investors informed about the business of the Fund Manager and its Affiliates generally, including offering opportunities to make investments other than to the Fund.
  7. Any other purpose that has been notified, or has been agreed, in writing.

The Authorized Entities monitor communications where the law requires them to do so.  The Authorized Entities also monitor communications, where required to do so, to comply with regulatory rules and practices and, where permitted to do so, to protect their respective businesses and the security of their respective systems.

Sharing and transfers of personal data

In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where not prohibited by UK and EU Data Protection Legislation, to other service providers, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfill the purposes described in this GDPR Privacy Notice.  In addition, any Authorized Entity may share personal data with regulatory bodies having competent jurisdiction over them, as well as with the tax authorities, auditors and tax advisors (where necessary, advisable or required by law, rule, regulation or controller).

Any Authorized Entity may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfil the purposes described in this GDPR Privacy Notice and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer the attached Subscription Agreement and Partnership Agreement, and to implement requested pre-contractual measures.  We will ensure that any international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679, the UK GDPR or other relevant laws. This may include entering into the EU Standard Contractual Clauses. For information on the safeguards applied to such transfers, please contact Nick Pruhs at npruhs@rwbaird.com.  For the purposes of this GDPR Privacy Notice, “Non-Equivalent Country” shall mean a country or territory other than (i) a member state of the EEA; (ii) the United Kingdom or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the United Kingdom in accordance with UK and EU Data Protection Legislation to ensure an adequate level of protection for personal data.

Retention and security of personal data

The Fund Manager and its Affiliates consider the protection of personal data to be a sound business practice, and to that end, employ technical and organizational measures it believes are appropriate, including robust physical, electronic and procedural safeguards to protect personal data in their possession or under their control.

Personal data may be kept for as long as it is required or appropriate for legitimate business purposes, to perform contractual obligations, or where longer, as long as is necessary or advisable to comply with applicable legal or regulatory obligations.  Personal data will be retained throughout the life cycle of any investment in the Fund. However, some personal data will be retained after a data subject ceases to be an investor in the Fund.

Data subject rights

It is acknowledged that, subject to applicable UK and EU Data Protection Legislation, the data subjects to which personal data relates, have the following rights under UK and EU Data Protection Legislation: to obtain information about, or (where applicable) withdraw any consent given in relation to, the processing of their personal data; to access and receive a copy of their personal data; to request rectification of their personal data; to request erasure of their personal data; to exercise their right to data portability; and the right not to be subject to automated decision-making.  Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal or regulatory obligation.  In addition, erasure of the personal data requested to fulfill the purposes described in this GDPR Privacy Notice, may result in the inability to provide the services required pursuant to the attached Subscription Agreement, the Partnership Agreement and/or any other agreement agreed to in connection with the investor’s investment in the Fund.

In case the data subject to whom personal data relate disagrees with the way in which his or her personal data is being processed in relation to the attached Subscription Agreement and/or the Partnership Agreement, the data subject has the right to object to this processing of personal data and request restriction of the processing.  The data subject may also lodge a complaint with the competent data protection supervisory authority in the relevant jurisdiction.  The data subject may raise any request relating to the processing of his or her personal data at FundTeam-BairdCapital@rwbaird.com.

Our use of cookies and other information-gathering technologies.

Visitors may browse the Baird websites to learn about our history, our services, obtain market insights, find career opportunities, and more. Baird uses cookies, pixel tags, tracking pixels and other tracking technologies (“tracking technologies”) to collect information about website visitors and their behavior on our websites. Personal information may be collected. For example, visitors may enter their contact information when requesting to be matched with a financial advisor (FA). This information is then sent to the financial advisor who has been matched with the visitor. Additionally, information entered into our websites may be processed by third parties to provide requested services (e.g., if a ZIP code is entered into the Find a Baird Financial Advisor search field, Google will process the ZIP code to provide the closest Baird FA).

Website visitor information is collected by Baird websites with the use of computer IP addresses. This information is used to help measure advertising performance, measure website usability and user experience, improve website design and content, the use of our website content, optimize the configuration of our websites, build our ads’ and websites’ audience, and administer our websites. 

You can learn more about each type of cookie we use on our website below and choose which cookie categories you wish to allow by clicking “Cookie Settings” at the top of this page.

Unless otherwise indicated, you agree to the Baird Cookies Policy and you consent to our use of cookies in accordance with the terms of the policy by using our website.

If you do not agree to the use of cookies, you can do one of the following:

  • Stop using our website and delete any cookies that may have been stored on your computer on your arrival to our site;
  • You can also block all cookies or block only third party cookies, or alternatively, clear all cookies once you have closed your browser;
  • You can change your cookie settings for the website by clicking the “Cookie Settings" button at the top of this page;
  • You can browse the site using your browser's anonymous usage setting ("Incognito in Chrome, "InPrivate" in Internet Explorer, "Private Browsing" in Firefox and Safari etc). The help section of your specific browser will aid you in selecting these settings.

If you block or delete any cookies, you may have to manually adjust some preferences every time you visit the site and some services and functionalities may not work.

Additionally, Baird has implemented Global Privacy Control (“GPC”) to respond to signals that a user has a GPC “do not track” setting. You may opt out of online targeted advertising by broadcasting the GPC opt-out preference signal from your browser and/or a browser extension supporting the GPC signal. To download and use a browser supporting the GPC signal, see here: https://globalprivacycontrol.org/orgs. As a reminder, if you disable or refuse cookies or similar tracking files, some features on our websites may be inaccessible or not function properly. Additionally, because there are multiple versions of opt-out preference signals, our websites may not respond to signals other than GPC. To ensure your choices take effect, you may need to also adjust your privacy choices with third-party sites.

Supplemental Definitions

In addition to the definitions provided under Cookie List, please note the following:  

Session Cookies

Session cookies are used to temporarily store information about logged in users. These cookies do not collect information from the user's computer, and do not identify the user.

First-Party Cookies

First-Party Cookies are created and stored by the Baird websites.

Third-Party Cookies

Third-Party Cookies are created by a third-party website that integrate with the Baird websites.

Targeting Cookies

You may see advertising on Baird websites tailored to how you browse or shop, or you may see advertising for Baird on other websites based on your browsing behavior across websites. Some websites where we may advertise belong to ad networks that use your web browsing history to choose which ads to display on their network websites; these ads include advertising for Baird. Other websites where you see our ads may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you.