PRIVACY POLICY

Privacy Policy

FACTS

WHAT DOES BOW RIVER ASSET MANAGEMENT LLC D/B/A BOW RIVER CAPITAL (“BOW RIVER CAPITAL”) DO WITH YOUR PERSONAL INFORMATION?

WHY?	Financial companies choose how they share your personal information. Federal law gives 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. This Privacy Notice applies to consumers. Consumers do not include institutions. Please read this notice carefully to understand what we do.
WHAT?	The types of personal information we collect and share depends on the products or services you have with us. This information can include: Name, address, telephone number, email address Social security number and income Driver’s license number and/or passport number Copies of utility bills for proof of residency Net worth and assets Wire transfer instructions, email addresses, and physical addresses Capital commitment and account balances
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 Bow River Capital chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Bow River Capital Share?	Can you limit this sharing?
For our everyday business purposes - such as to process your transactions, maintain your accounts(s), administer and operate the fund of which you are a limited partner, or respond to court orders and legal investigations. This includes providing this information to third-party service providers contracted by Bow River.	Yes	No
For our marketing purposes - to offer our products and services to you.	No	We don’t share
For joint marketing with other financial companies	No	We don’t share
For our affiliates' everyday business purposes - information about your transactions and account balances	No	We don’t share
For our affiliates' everyday business purposes – information about your creditworthiness	No	We don’t share
For our affiliates to market to you	No	We don’t share
For non-affiliates to market to you	No	We don’t share
Questions?	Contact James Kerr, Chief Compliance Officer at 303-861-8466 or kerr@bowrivercapital.com

Who we are
Who is providing this notice?	Bow River Capital and its Affiliates.
What we do
How does Bow River 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 office spaces.
How does Bow River collect my personal information?	We collect your personal information, for example, when you: Complete an investor questionnaire or subscription document Give us your contact information Make subscriptions or redemptions from your account Make a wire transfer
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 information to market to you, unless the affiliate has a pre-existing business relationship with you sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing.
Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include our private funds: Bow River Capital Fund II, LP; Bow River Capital Fund III, LP; Bow River Capital Fund IV, LP; Bow River Capital Fund V, LP; Bow River General Partners Investors, LP; Bow River Capital 2011 Fund, LP; Bow River Capital 2011-QP Fund, LP; Bow River Capital 2011-TE Fund, LP; Bow River Capital 2011 Cayman Fund, LP; Bow River General Partners 2011, LP; Bow River Capital Real Estate Fund I, LP; BRCGP Real Estate, LP; Bow River Capital 2017 Fund, LP; Bow River Capital 2017-QP Fund, LP; Bow River Capital 2017 Cayman Fund, LP; Bow River General Partners 2017, LP; Bow River Capital Real Estate Fund II, LP; Bow River Capital Real Estate Fund I, LP; BRCGP Real Estate II, LP; Bow River Capital 2019 Software Growth Equity Fund, LP; Bow River Capital 2019-QP Software Growth Equity Fund, LP; Bow River General Partners 2019 Software Fund, LP; Bow River Capital OZ I, LLC,; Bow River Capital OZ II, LLC; Bow River Capital Evergreen Private Equity Fund, LP, BRC Evergreen Private Equity Fund GP, LP, BRC OZ III, LLC The general partners to those funds: Bow River Capital Partners LLC; Bow River Capital Partners II, LLC; Bow River Capital Partners III, LLC; Bow River Capital Partners Non-US III, Ltd; Bow River Capital RE I, LLC; Bow River Capital Partners IV, LLC; Bow River Capital Partners Non-US IV, Ltd; Bow River Capital RE II, LLC; Bow River Capital 2019 Software GP, LLC, BRC OZ 1, LLC , BRC OZ 2, LLC, BRC Evergreen Private Equity GP, LLC, BRC OZ 3, LLC
Non-affiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Bow River Capital does not share with non-affiliates so they can market to you
Joint Marketing	Bow River Capital does not have any formal agreements with non-affiliated financial companies to jointly market financial products or services to you.

Information for Residents of the European Economic Area
General	Limited Partners who reside in the European Economic Area (EEA) have certain rights pursuant to the General Data Protection Regulation (GDPR). If you are a resident of the EEA and do not agree with Bow River Capital’s use of your personal data as set forth in this Privacy Notice, you should not submit your personal information to Bow River Capital. Please note that if you do not submit your personal information, for example a failure to fully complete the Bow River Capital Subscription Agreement, or if exercise your rights to prevent Bow River Capital from using your data where necessary for us to comply with U.S. securities or other laws or for other reasons stated above, Bow River Capital may be put in a position of not accepting you as an investor in Bow River Capital funds.
Bow River’s Status Under the GDPR	Under GDPR, Bow River Capital is a “controller.” Which means we transfer, use and/or store your personal information outside of the EEA, in the U.S. The U.S. may not afford the same level of data protection as offered by the GDPR. Also, your information will also be processed by personnel whose operations are outside the EEA, for example those who work for Bow River Capital or one of Bow River Capital’s vendors that service the funds.
How Bow River Might Have to Use Your Personal Information	Bow River Capital is entitled to use your personal data in the following ways as set forth in our Privacy Policy above: A contract or agreement must be executed which contains your personal information for you to invest as a limited partner in a Bow River Capital fund; Your personal information must be collected for Bow River Capital to satisfy its own obligations under U.S. securities or other law, such as a subscription agreement and anti-money laundering requirements; You have consented to the use of your personal information for marketing or operational purposes; and/or; Bow River Capital must have access to your personal information to establish, exercise or defend its own legal rights for the purposes of legal proceedings.
Your Rights Under GDPR	Under certain circumstances, the GDPR affords you the right to: Request access to your personal information which is held by Bow River Capital. Upon request, you are entitled to receive a copy of the personal information we hold and to check that we are processing it lawfully under this Privacy Policy and GDPR. Object to the processing of your personal information where Bow River Capital is relying on a legitimate interest and your particular situation is distinguishable. You also have the right to object where we are processing your personal information for direct marketing purposes. Contact Bow River Capital to request that we correct or update your personal information. Request that Bow River Capital delete your personal information from our systems or remove it from our records where there is no good reason for us continuing to hold or process it. Request that Bow River Capital restrict the processing of your personal information. You can request that we suspend the processing of your personal information, for example if you want Bow River Capital to establish its the reason for processing your information. Ask that we transfer of your personal information to another party in a commonly used and structured format.
Retention of Your Personal Information	We will keep your information as long as necessary depending on Bow River Capital’s legal obligations under securities and other laws or for our own protection regarding potential or initiated disputes.
Exercising Your Rights under GDPR	Please contact Bow River Capital’s Chief Compliance Officer, James Kerr if you would like to exercise any of these rights. The various rights described herein are not complete and each is subject to certain exceptions or qualifications. Bow River Capital will respond to your request within 30 business days. In some cases, we may be unable to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request. Please keep your information with Bow River Capital up-to-date. You will not be charged any fees to access your personal information or to exercise any of the other rights. However, Bow River Capital may charge a reasonable fee if your request is unfounded or excessive. If you request access your personal information or opt to exercise any of the other rights, Bow River Capital may take security measures to ensure that personal information is not disclosed to any person who has no right to receive it. If you are not satisfied with how Bow River Capital has handled your information, please contact James Kerr at Bow River Capital. You can also make a complaint to the supervisory authority in your country. For example, in the UK you should contact the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/ or 0303 123 1113.
Inquiries, Complaints or Withdrawing Your Consent	If you choose to not to provide your consent, you can withdraw it at any time by contacting us. Should you have any questions or concerns relating to this Privacy Notice or the processing of personal data we hold about you, please contact us: By mail: Bow River Asset Management LLC 205 Detroit Street, 8th Floor Denver, Colorado 80206 Attn: James Kerr, CCO By phone: +1-303-861-8466 By email: kerr@bowrivercapital.com
Effective Date of Notice	This policy is current as of September 2020. Bow River Capital reserves the right to change this policy at any time, depending on changes in legal or other requirements or as circumstances may dictate. We will notify all limited partners to which this policy may apply of any such amendment.