Privacy Policy

Last Modified: November 3, 2023

At ClearSky Advisors LLC (“ClearSky”) we take your privacy and the security of your information very seriously.  This Privacy Policy (“Policy”) covers our website, www.clear-sky.com, together with all of its sub-domains (the “Site”).   If you have any questions regarding this Policy, please contact us at info@clear-sky.com.

This Policy is incorporated into, and is part of, our Terms of Use, which governs your access to and your use of the Site. If you have entered into a separate agreement with us, that separate agreement shall control, and only those terms within this Policy that do not conflict with such separate agreement shall apply.

The Policy describes the types of information we gather from people visiting our Site and from individual users interacting with our Site and how we use, transfer, and secure such information.  This Policy does not govern data or information we receive from third parties and it does not cover third party products and services.  By accessing the Site, you agree to be bound by this Policy. If you do not agree to the terms of this Policy, please do not use the Site.  Each time you use the Site the current version of this Policy will apply. Accordingly, when you use the Site, you should check the date of this Policy (which appears at the top) and review any changes since you last reviewed the Policy.

Types of Information We Collect

We may collect two types of information from users of our Site: “Personal Information,” which is information that you provide that can be used to identify you (such as name, email address, etc.), and “Aggregate Information,” which is information that cannot be used to identify you (such as frequency of visits to the Site, device type, browser type, etc.)

Personal Information Collected

We collect Personal Information that you voluntarily provide to us when you use our Site.  For example, you may provide us with your email address, first and last name, phone number, email address, or other Personal Information through our Site, via email, through an online form, or other method of communication.

Your Communications With Us

We collect information when you communicate with us.  For example, if you send us an email, we will collect your email address and the content of your email.

Information We May Automatically Collect

When you visit our Site, we may automatically receive and collect certain information from your device.  Such information could include, for example, the following:

1. Your operating system, hardware, system version, Internet Protocol (IP) addresses, device ID, and device language.
2. Your country and general location, time zone and language used.
3. The specific actions that you take when you use our Site, including but not limited to the pages and screens that you view or visit, search terms that you enter, and how you interact with our Site.
4. The time and frequency, connection type, and duration of your use of our Site.
5. Information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message.
6. Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below).
7. The website from which you linked to us, and the website you choose to visit immediately after ours.

Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to “Do Not Track” signals from your browser at this time.

Cookies and Analytics

Like most websites, our Site may use “cookies.”  Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to help us identify you when you come to our Site.

Our Site may use cookies for reasons including, but not limited to:

1. Analyzing our web traffic using an analytics package.
2. Identifying if you are signed into the Site.
3. Testing content on the Site.
4. Storing information about your preferences.
5. Recognizing when you return to the Site.

Overall, cookies help us provide you with a better experience on our Site by enabling us to monitor which pages you find useful and which you do not.

You can choose to accept or decline cookies.  Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.  This setting may prevent you from taking full advantage of the Site.

We may use third parties, or other analytics providers, to analyze traffic to the Site. Aggregate Information Collected

Aggregate Information Collected

Aggregate Information is information that does not identify you.  Aggregate Information may be collected when you visit our Site as described above, independent of any information you voluntarily enter.  Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains.  We may collect, use, store, and transfer Aggregate Information without restriction.

Collection of Personal Information by Third Parties

Some links on our Site may redirect you to third party websites and services that we do not operate.  The privacy practices of these websites and services will be governed by their own policies and are not controlled by us.  We make no representation or warranty as to the privacy policies of any third parties, including the providers of third-party applications.  If you are submitting information to any such third party through our Site, you should review and understand that party’s applicable policies, including their privacy policy, before providing your information to the third party.

We offer you the ability to access an investor portal via the Site (the “Investor Portal”) in order to access materials such as fund financial statements, investor capital account statements, distribution notices, capital call notices, investor tax statements, and quarterly investor updates.  The Investor Portal is hosted by SS&C Intralinks, Inc. (“SS&C”), and your use of the Investor Portal and any data submitted to the Investor Portal is subject to SS&C’s privacy policy.

How We Use Your Information

In general, we collect information and Personal Information from you so that we can provide our Site, operate our business, communicate with you, and provide information that you request from us.  This includes but is not limited to the following purposes:

• Provide, operate, improve, maintain, modify, and protect our Site.
• Provide you with technical and other support.
• Send you updates, marketing communications, and other information about ClearSky, and our products, events, promotions, and our websites.
• Send you notices and alerts.
• Conduct research, analytics, and monitor and analyze trends and usage.
• Contact you and respond to your inquiries and requests, and when needed verify your status and identity in connection with our exchanges.
• Enhance or improve user experience, our business, our products, and our websites, including the safety and security thereof.
• As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request.
• Enforce rights, contracts and our Terms of Use, including investigation of potential violations thereof.
• Detect, prevent, or otherwise address fraud, security or technical issues.

How We Share Your Personal Information with Third Parties

We do not rent or sell your Personal Information.

We may transfer Personal Information to third parties for the purpose of providing the Site.  We may disclose Personal Information to our affiliates or third party service providers.  For example, we may transfer your Personal Information to third-party service providers to provide certain information technology services that assist us with providing you the Site.

We may also elect to transfer your Personal Information to third parties under special circumstances such as: (i) to comply with a legal requirement, judicial proceeding, court order, or legal process served on us; (ii) to investigate a possible crime, such as fraud or identity theft; (iii) in connection with a sale, purchase, merger, reorganization, liquidation or dissolution; (iv) when we believe it is necessary to protect the rights, property, or safety of ClearSky or other persons, or (v) as otherwise required or permitted by law, including in connection with enforcement of any rights and performance of any obligations.

Opt-Out

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each communication.

Children and Privacy

Our Site is not intended for use by children and we do not knowingly collect Personal Information from children under the age of 13 in connection with the features of our Site.  If we become aware that an individual under the age of 13 has provided Personal Information through our Site, we will immediately remove the individual’s Personal Information from our files.

How We Protect Your Information

We take the security of your Personal Information very seriously.  We have implemented administrative, physical, and technical safeguards to secure the Personal Information you share with us. Despite these safeguards and our additional efforts to secure your information, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your Personal Information.

Any email or other communication purporting to be from our Site asking you to provide sensitive information via email, should be treated as unauthorized and suspicious and should be reported to us immediately by emailing info@clear-sky.com.

A Note to Users Outside of the United States

If you are a non-U.S. user of the Site, by visiting the Site and providing us with your Personal Information, you acknowledge and agree that your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country.  By providing your Personal Information, you consent to such processing.

Will We Change This Policy?

Each time you use our Site the current version of the Policy will apply. When you use our Site, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version.  This Policy is subject to change from time to time and we reserve the right to amend this Policy at any time without any prior notice to you.

How To Contact Us

To contact us with your questions or comments regarding this Policy or the information collection and dissemination practices of this Site, please email us at info@clear-sky.com.