Privacy Policy

Effective 20/01/2023

ACW Drainage, (“ACW ”, “us”, “our”, and “we”) is committed to respecting your privacy.  This Privacy Policy describes how we collect, use, share, and disclose personal data we collect on the websites owned and operated by ACW (“Sites”).  Users of our financial services should refer to our investor privacy notice, which is supplied to you in the subscription materials at the time of your investment.  BY PROVIDING YOUR PERSONAL DATA TO ACW OR OTHERWISE USING OUR SITE, YOU AGREE TO THE TERMS OF THIS POLICY AND OUR WEBSITE TERMS OF USE. 

The Sites may link to third party websites or services not owned or controlled by ACW.  Please note that this Privacy Policy does not apply to those third-party websites and ACW is not responsible for the data collection practices of any third parties.  

If you are a California resident, please read our Privacy Notice for California Consumers below.

1.  The Information We Collect and Use

When we use the term “Personal Data” we mean nonpublic information that can be used to identify you as an individual person.  We collect the following categories of Personal Data:

  • Identifiers:  Identifiers such as your real name, postal and residential address, email address, Internet Protocol (IP) address, account name, social security number, contact details, driver’s license number, passport number, corporate contact information, and other similar identifiers.
  • Commercial Information:  Account activity, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other Similar Network Activity:  Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  • Professional or Employment Information:  Professional or employment-related information, including your employment and employer’s name.
  • Inferences:  Inferences that we draw from your Personal Data in connection with a determination as to your suitability to make an investment, your capacity to evaluate the merits and risks of investments and your qualification to make an investment according to the terms of such investment.
  • Other Personal Data Categories:  A signature, physical characteristics or description, telephone number, bank account number, credit card number, debit card number, or any other financial information,.

2.  How We Collect Your Personal Data

We may collect Personal Data in various ways and from various sources, including:

  • your communications with us;  
  • your transactions with us;
  • service providers;
  • affiliates and portfolio companies;
  • advisors and other business partners;
  • social media networks or other publicly accessible directories and sources; and
  • government entities.

Information Collected Automatically on Our Sites and Use of Cookies:

We use various technologies to collect data on our Sites.  As is true of most websites, we gather certain information automatically and store it in log files.  This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data.  We and our service providers may also use cookies, scripts, and similar technologies to manage our websites and to collect information about you and your use of our Sites.  These technologies help us to recognize you and customize or personalize your experience. 

Most Internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences.  For information on how to do this, access the “help” menu on your Internet browser, or visit  Please note, however, that disabling our cookies may result in your inability to take full advantage of all of the features of our Sites.  To learn more about the use of Cookies by Google for analytics and to exercise choice regarding those Cookies, please visit the Google Analytics Opt-out Browser Add-on.

Our website does not respond to Do Not Track Signals.

3.  Purpose for Collection and How We Use Your Personal Data

We collect, store, and use your Personal Data for business or commercial purposes including to pursue our legitimate interests, or those of a third party to whom your Personal Data is disclosed, including without limitation:

  • processing that is necessary for compliance with applicable legal or regulatory obligations and to comply with requests from regulatory, governmental, tax, and law enforcement authorities;
  • managing, operating, and growing our business and managing investor accounts, including through the use of third party service providers;
  • assessing and processing requests you make;
  • evaluating potential candidates for employment;
  • sending updates, information, and notices or otherwise corresponding with you;
  • investigating any complaints, or pursuing or defending any claims, proceedings or disputes;
  • providing you with, and informing you about, investment products and services;
  • managing our risk and operations;
  • complying with audit requirements;
  • ensuring internal compliance with our policies and procedures;
  • protecting against fraud, breach of confidence or theft of proprietary materials;
  • seeking professional advice, including legal advice;
  • facilitating business asset transactions;
  • monitoring communications to/from us (where permitted by law);
  • creating, improving, and developing our Sites and other products and services; and
  • protecting the security and integrity of our Sites and IT systems.

4.  Sharing Your Personal Data

We do not sell any Personal Data to unaffiliated third parties or share it for purposes of cross-context behavioral advertising and have not done so in the past 12 months.

We may share your Personal Data with other entities within ACW including with ACW funds or related entities for any of the purposes set forth above or with our agents and service providers.  In certain circumstances we may be legally obliged to share your Personal Data with relevant regulatory authorities such as the U.S. Securities and Exchange Commission.  They, in turn, may exchange this information with foreign authorities, including tax authorities and other applicable regulatory authorities.

Our agents and service providers may process your Personal Data on our behalf, including with our banks, accountants, auditors, and lawyers, which may be data controllers in their own right.  Our service providers are generally processors acting on our instructions.  Additionally, a service provider may use your Personal Data if necessary for compliance with a legal obligation to which it is subject (for example, to comply with applicable anti-money laundering and counter terrorist financing laws).

We may share your Personal Data with prospective creditors of ACW and its funds or related entities or of a future or present portfolio company, with portfolio companies directly, or with a third party that acquires, or is interested in acquiring, all or a substantial part of our assets or equity interests, or that succeeds us in carrying on all or a part of our business.  In certain circumstances, we may share your Personal Data in connection with the investigation and assertion of legal rights.

5.  International Transfers

If you are located outside of the United States, please be aware that the Personal Data we collect will be processed and stored in the United States. The European Commission has deemed that the United States does not offer the same level of data protection as the European Union. Other jurisdictions where you reside or are a citizen or where a Fund is established may similarly determine the same with respect to the data protection and privacy laws of that jurisdiction.

6.  Retention Periods and Security Measures

We will keep your Personal Data for as long as is consistent with the purposes for which we are processing it.  For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to.  We will retain some Personal Data after your relationship with us ends.

We apply technical, physical, and administrative information security measures designed to protect against unauthorized or unlawful processing of Personal Data, and against accidental loss or destruction of, or damage to, Personal Data, although we cannot guarantee that these will always be effective.

7.  Children’s Privacy

Our services are not intended for children under the age of 18.  We do not knowingly collect information from children under the age of 18, and we do not target children under the age of 18.

8.  Data Subject Rights

Individuals in Australia, California and certain other US states, Canada, Cayman Islands, Europe, Hong Kong, Israel, Japan, Singapore, South Korea, Switzerland, the United Kingdom, and certain other jurisdictions may have certain data subject rights.  These rights vary, but may include a right to:

  • be informed about the purposes for which your Personal Data are processed;
  • access your Personal Data, including requesting us to disclose to you the Personal Data we have collected, used and disclosed about you during the past 12 months;
  • stop direct marketing;
  • restrict or object to the processing of your Personal Data;
  • have incomplete or inaccurate Personal Data corrected;
  • ask us to stop processing your Personal Data;
  • obtain a copy of your Personal Data in a portable format;
  • opt out of the sale of Personal Data; and
  • require us to delete your Personal Data in some limited circumstances.

Depending on your jurisdiction, you may also be entitled to direct any complaints in relation to our processing of Personal Data to your national or local data protection supervisory authority, or to the Cayman Islands Ombudsman, if the complaint is in relation to a Cayman Islands fund.  Please consult local authorities.

The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.  Individuals who submit requests for access or erasure of Personal Data and certain other rights will be required to verify their identity by answering questions.  For requests related to particularly sensitive information, we may require additional proof of identification.  We will not disclose or delete any information until such individual’s identity is verified.  If you are making a request for access, we may not be able to provide specific pieces of Personal Data if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your Personal Data or our systems or networks.  If you are making a request for erasure, we will ask that you confirm that you would like us to delete your Personal Data again before your request is submitted.  In certain circumstances, we may not erase all Personal Data, as permitted by applicable law.  We will process your request within the time provided by applicable law.

You may submit requests relating to your exercise of these rights to us using the contact information below. 

You may designate an authorized agent to submit a request on your behalf by providing that agent with your signed permission to do so.  In addition, we may still ask that you verify your identity directly with us or directly confirm with us that you provided the authorized agent permission to submit the request before we can honor the request.  We will not honor any requests from agents until authorization is verified.

9.  Privacy Notice for California Consumers

In the preceding 12 months, we have collected and used Personal Data in the manner described above in the sections titled, “The Information We Collect and Use”, “How We Collect Your Personal Data”, “Purpose for Collection and How We Use Your Personal Data”, and “Sharing Your Personal Data”. 

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what Personal Data is disclosed to third parties for direct marketing purposes in the preceding calendar year.  We do not share Personal Data with outside parties for their direct marketing.

10.  Managing Your Communication Preferences

We want to communicate with you only if you want to hear from us.  If you wish to opt out of receiving any communications, you may do so at any time by contacting us using our contact information below.

11.  Changes to this Policy

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by posting the revised notice on the Sites and updating the effective date above.

12.  How to Contact Us

If you have any questions or comments about this Privacy Policy or other privacy-related matters, please contact us at: