Privacy Policy

RoundTable Healthcare Partners III, L.P./RoundTable Healthcare Investors III, L.P. (Fund III) and
RoundTable Healthcare Partners IV, L.P./RoundTable Healthcare Investors IV, L.P. (Fund IV) and
RoundTable Healthcare Partners V, L.P./RoundTable Healthcare Investors V, L.P. (Fund V) and
RoundTable Healthcare Partners VI, L.P./RoundTable Healthcare Investors VI, L.P. (Fund VI) and
RoundTable Healthcare Capital Partners III, L.P. (Cap Fund III) and
Santa Cruz Nutritionals Investors LLC and
TIDI Products Investors LLC and
Isiah LLC

Commitment to Privacy

The aforementioned entities (collectively, “we,” “us” or “our”) consider privacy to be fundamental to our relationship with our current and former investors and individuals who visit our website (the “Website”) or otherwise communicate or engage with us (“investor,” “you” or “your”). We respect your right to privacy. We also know, however, that you expect us to conduct our business in an accurate and efficient manner. To do so, we must collect, use and otherwise process certain personal information about you.

This privacy policy discusses how we collect, use and otherwise process your personal information. We have also developed internal policies designed to help maintain the confidentiality, integrity and security and protect such information while allowing your needs to be met. Your right to privacy extends to all forms of contact with us, including telephone, written correspondence and electronic media, such as the Internet.

Collection of Personal Information

The types of personal information collected by or on behalf of us about you varies based on our interactions with you (for example, whether you are an investor or an individual visiting the Website).

Personal information collected by or on behalf of us about individuals visiting the Website is obtained directly from you or certain third parties. The personal information we collect about you in the course of your interaction and correspondence with us via the Website using Google Analytics includes, but is not limited to, the following:

• IP address and other online identifiers/web beacons;
• Details of your online browsing activities on the Website, including, but not limited to, the full Uniform Resource Locators (URL), clickstream to, through and from the site (including, but not limited to, date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
• Your browser type and version, relevant plug-ins, operating system and platform; and
• Your time zone settings.

Please visit the following link for more details on Google Analytics Data Collection: https://support.google.com/analytics/answer/11593727?hl=en

If you are an investor, additional personal information collected by or on behalf of us about you is obtained directly from you, your professional advisors or other third parties, and generally comes from sources such as subscription agreements, questionnaires and other related documents. The personal information we collect from or about you as an investor in the course of your interaction and correspondence with us and our representatives includes, but is not limited to, the following:

• Basic personal details, including your name and address (and proof of name and address), email address, telephone number, any other contact details you may supply, social security number, driver’s license, state identification card, passport number, tax identification number and other tax details, nationality, citizenship, tax residency, date of birth and family connections;
• Details of your company’s directors, shareholders, secretaries, authorized signatories and other comparable officers and/or beneficiaries, and identification documents;
• Banking details, debit card number, credit card number and other financial account information;
• Information regarding your assets, income and/or financial dealings, including investment history and the types and amounts of investments held by you;
• Details of business advisers you may employ, including wealth managers and independent financial advisers;
• Account log-in information;
• Records of communications, including recordings of your attendance (or their representative’s attendance) at certain meetings/phone calls, and electronic communications with our staff and meeting notes; and/or
• Personal information about transactions with us, our affiliates or others, such as ownership of certain types of accounts or other account data.

Of the above categories of personal information that we may collect about you, the following may be considered “sensitive” categories under certain applicable laws: social security number, driver’s license, state identification card, passport number, account log-in, financial account information, debit card number, and credit card number. This privacy policy, and the practices described herein, applies equally to our collection, use, disclosure and other processing of such “sensitive” personal information.

Please see the section entitled “Cookies” below for a discussion of our use of cookies on the Website.

The Website is not intended for children and we do not knowingly collect data relating to children (including any minors under the age of 16).

Provision of certain of your personal data is a legal and contractual requirement necessary to becoming an investor in any of our sponsored funds or other pooled vehicles. We also may request your consent with respect to certain processing of your personal data. If you choose not to provide such personal data or such consent, or if you withdraw your consent (which you may do at any time by contacting us), you may be unable to invest with us or we may be unable to perform certain of the tasks required in order to provide certain products or services to you.

Use of Personal Information

We use your personal information to operate our business, including as follows:

• To provide you with services that you have requested and to fulfill our contractual obligations, including any contractual obligations as the general partner(s) and/or the investment advisor to a fund in which you have subscribed;
• To fulfill our contractual obligations to other third parties to whom you have provided your information;
• For our internal business administration, and record keeping purposes;
• To operate the Website and our other IT systems and safeguard their security;
• For legal and regulatory compliance purposes, including as necessary to respond to governmental, regulatory or law enforcement agency requests;
• Where required or considered appropriate, including prior to admitting you to a fund, prior to accepting capital contributions or making a capital distribution, carrying out “know-your-client” (KYC) checks and other procedures that we undertake in the course of our ongoing business relationship with you; and/or
• To provide information to future purchasers or merger partners of all or a portion of our business or any of our funds, or to provide information as may be necessary in connection with other corporate transactions, such as financings or restructurings.

We generally do not send marketing messages; however, from time to time, we will provide you with information on sponsored funds that we may be raising. You have the right to ask us not to send you marketing messages by post, telephone or e-mail or any combination of these at any time; however, you acknowledge that such information may be included in general update letters and while you may choose not to receive such updates, we are under no obligation to provide redacted versions of such letters or otherwise create separate reports on your behalf excluding such marketing information. You can also let us know at any time that you wish to change your mind and to start receiving such messages. You can do this at any time by contacting us.

We do not use or otherwise process your personal information, including “sensitive” personal information, for purposes of automated decision-making, including profiling.

We do not use or otherwise process your “sensitive” personal information other than as described herein.

Disclosure of Personal Information

We do not disclose any personal information about you, except as detailed in this privacy policy. We disclose your personal information to the following categories of third parties:

• Our employees and affiliates, for purposes of operating our business;
• Companies that perform various types of services (including services needed to operate the fund(s) associated with you) in order for such companies to provide services to us, including, but not limited to: (i) legal counsel, (ii) accountants, (iii) audit firms, (iv) banks, (v) administrators, (vi) tax consultants, (vii) tax preparers, (viii) placement agents, (ix) transfer agents, (x) custodians, (xi) persons or entities that are assessing our compliance with industry standards, (xii) attorneys, (xiii) investor portal service providers and (xiv) vendors supporting the Website or our other IT systems;
• Any person or entity, including without limitation any governmental agency, regulatory authority or selfregulatory organization having jurisdiction over us or our affiliates, if (i) we determine in our discretion that such disclosure is necessary or advisable pursuant to or in connection with any United States federal, state or local, or non U.S., law, rule, regulation, executive order or policy, including without limitation any anti-money laundering law, the USA PATRIOT Act of 2001 or any subpoena, court order or judicial process; and (ii) such disclosure is not otherwise prohibited by applicable law, rule regulation, executive order or policy;
• Law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. (including the U.S. Securities and Exchange Commission) or of other countries with whom a fund (or a fund’s portfolio companies) transacts who request or require such information in order to issue business or regulatory licenses or permits;
• Third parties with whom a fund (or a fund’s portfolio companies) transacts which require information to comply with local anti-money laundering laws, including banks and other financing counterparties;
• To future or potential purchasers or merger partners (i) for due diligence purposes on a need to know basis, (ii) as necessary for pre-closing integration planning, or (iii) in connection with the consummation of a sale or merger transaction; and/or
• On a need to know basis to current, future or potential lenders or other relevant persons as necessary in connection with other corporate transactions, such as financings or restructurings.
• In addition, we may disclose personal information as follows:
  
  • To law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. (including the U.S. Securities and Exchange Commission) or of other countries, where we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation, or if we reasonably consider that this is necessary or advisable to help prevent or detect fraud or other crime or to protect our rights, property, or safety, or that of our clients, investors or others. Such disclosure (including tax status, identity or residency or other personal or payment information, documents or self-certifications) may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
  • If we are under a duty to disclose or share your personal information with tax authorities, such information requested by such tax authorities, who may transfer such information to the government or the tax authorities in another country where you may be subject to tax. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
  • Subject to any contractual confidentiality obligations, we may disclose investor names, participation on any limited partner advisory committee, jurisdiction of the investor and/or commitment size to other limited partners or prospective investors of a sponsored fund; and
  • If you use a financial or other adviser (as indicated on your subscription agreement or subsequently communicated to us), the details of your investments and valuations may also be provided to such adviser(s).

We permit access to such information only by authorized employees and representatives of our affiliates or service providers who need access to the information to provide services to us and our investors or otherwise in accordance with this privacy policy.

Data Security

We acknowledge that the personal information you provide may be confidential, and we maintain policies and procedures designed to maintain the confidentiality of and protect your personal information in accordance with our normal procedures and applicable law. We maintain physical, electronic, and administrative measures designed to safeguard your personal information and prevent unauthorized access thereto.

Unfortunately, the storage and transmission of electronic information is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of information stored on our or our vendors’ servers or transmitted via email or through the Website; you transmit personal information to us at your own risk. In addition, links on the Website may take you to third-party websites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies or cookie policies on those linked websites. We are not responsible for any linked websites.

Further, you may have created or may in the future create an account with our third-party fund administrator(s) (including through its service provider(s)). We are not responsible for the websites of our third-party fund administrator(s) or its service provider(s), and you should review any separate privacy policies or cookie policies that they provide to you or that they post on their websites.

Data Retention

We will keep your personal information only for as long as necessary depending on the purpose for which it was provided and otherwise in order to meet our statutory, regulatory, or other obligations under applicable law. Further details of our data retention policies and procedures are available in our retention policy, information about which you can request by contacting us. When determining the relevant retention periods, we take into account factors, including, but not limited to, the following:

• Our contractual and business relationships with you;
• Legal obligations under applicable laws to retain data for a certain period of time;
• Statute of limitations under applicable laws;
• Potential disputes; and
• Guidelines issued by relevant regulatory authorities.

Cookies

What are Cookies?

Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit a website. A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e., how long it will remain on your device) and a value, which is usually a randomly generated unique number.

How we use Cookies

When you visit the Website, one or more “cookies” are generated and deployed with your consent (if required) using Google Analytics. We use cookies to make the Website easier to use and to better tailor our web presence and products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on the Website. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our web properties and to help us improve web structure and content. These cookies do not identify you as an individual. All data is collected and aggregated anonymously.

Two types of cookies may be used on the Website – “session cookies” and “persistent cookies.” Session cookies are temporary cookies that remain on your device until you leave the Website. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings).

Google may adjust its cookies from time to time. Please visit the following website to review its latest details on cookies: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#analyticsjs.

Your choices with respect to Cookies

If you do not agree to our use of cookies, you should set your browser settings accordingly or not use the Website. Most internet browsers are initially set up to automatically accept cookies. You can change the settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. For one way to opt out of the aggregation and analysis of data collected about you on the Website by Google Analytics, if you so choose, visit https://tools.google.com/gaoptout and download and install the Google Analytics Opt-out Browser Add-on. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.

If you disable the cookies that we use, this may impact your experience while using the Website. For example, you may not be able to visit certain areas of the Website.

If you use different devices to view and access the Website (e.g., your computer, smartphone, tablet), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.

Additional Information for Individuals Whose Personal Data is Subject to the GDPR and the UK GDPR

Residents of the European Economic Area (“EEA”) or the United Kingdom (“UK”) (such residents, “EEA/UK Residents”) have certain rights with respect to their personal data pursuant to the General Data Protection Regulation (EU) 2016/679 (“GDPR”) or the UK General Data Protection Regulation (“UK GDPR”), as applicable, as further described in this section. If you are an EEA/UK Resident and do not agree with our use of your personal data as set forth in this privacy policy, you should not submit your personal data to us. However, if you do not submit certain personal data to us, or if you exercise your rights to prevent us from using such personal data, you should be aware that we may not be able to do business with you.

For the purposes of applicable data privacy legislation, we are a “controller” of EEA/UK Residents’ personal data. We and our employees, affiliates and service providers may transfer, use, store and/or otherwise process your personal data outside of the EEA or the UK, primarily in the U.S., and the laws of the U.S. and certain other destination countries may not offer the same standard of protection for personal data as countries within the EEA or the UK. Your personal data also may be processed by staff operating outside the EEA or UK who work for us or for one of our vendors (for example, those who supply support services to us). In cases of cross-border transfers to countries outside of the EEA or the UK, as applicable, if your personal data will be processed in a country with laws that may not be equivalent to, or as protective as, the laws of your home country, we will take appropriate steps, in accordance with applicable laws, to require or maintain an adequate level of protection and security for your personal data. For

Additional information regarding such steps, please contact us using the details set forth at the end of this privacy policy.

We use your personal data in the ways set out in this privacy policy on the following bases:

• The use of personal data is necessary for the performance of a contract with you for provision of our products and/or services or to take steps at your request prior to entering into such a contract;
• We have legal obligations that we have to discharge;
• The use of your personal data is necessary for our legitimate interests in marketing to prospective investors for the fund in which you are invested, successor funds or other of our sponsored funds;
• You have consented to such use; and/or
• To establish, exercise or defend our legal rights for the purposes of legal proceedings.

We do not expect to process “sensitive” or “special” categories of personal data under the GDPR or UK GDPR; however, if we were to process such personal data, we would do so only where we have asked for your explicit consent, or where necessary for the establishment, exercise or defense of legal claims, or as otherwise may be permitted under applicable laws.

Under certain circumstances, under the GDPR, the UK GDPR and other applicable data privacy legislation you may have the right to:

• Object to processing of your personal data;
• Request access to your personal data;
• Request correction of your personal data;
• Request erasure of your personal data;
• Request the restriction of processing of your personal data; and/or
• Request the transfer of your personal data to another party in a machine-readable, commonly used and structured format.

If you want to exercise any of these rights, please contact us using the details set forth at the end of this privacy policy. The various rights are not absolute and each is subject to certain exceptions or qualifications.

To exercise any of the above-listed rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the above-listed rights.

If you wish to request further information about any of the above-listed rights, or if you are unhappy with how we have handled your personal data, please contact us using the details set forth at the end of this privacy policy. If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with the GDPR, the UK GDPR or other applicable data privacy legislation, you can make a complaint to the supervisory authority in your country.

Additional Information for Individuals Whose Personal Information is Subject to the CCPA

Residents of the state of California have certain rights with respect to their personal information5 pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), as applicable and as further described in this section. Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed subject to the Gramm-Leach-Bliley Act (Public Law 106-102), the Fair Credit Reporting Act (12 CFR 1022) and/or the California Financial Information Privacy Act.

Under certain circumstances, under the CCPA you may have the right to:

• request that we disclose, free of charge, the categories and specific pieces of personal information we collect about you (and, if applicable, sell or otherwise disclose to a third party and the categories of such third parties), the sources from which such personal information was collected, and the business purpose for collecting, selling or disclosing such personal information;
• choose to opt out of the sale of your personal information. Currently, we do not sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising;
• request that we delete the personal information we have collected about you; and
• request that we correct any inaccurate personal information we have collected about you.

We will not discriminate against any California resident who exercises the rights set forth in this section.

You have the right to appoint an authorized agent to exercise these rights on your behalf. If you want to exercise any of these rights, or have your authorized agent exercise any of these rights on your behalf, then please contact us using the details set forth at the end of this privacy policy. To exercise any of these rights, we may need to request specific information from you or your authorized agent to help us confirm your identity and ensure your right to exercise these rights.

These rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you are currently an investor in one of our funds and you request that we delete the personal information we have collected about you, the CCPA permits us to deny such request and retain your personal information to the extent necessary to manage the applicable fund and our business relationship with you in connection with that fund.

For consumers with disabilities who need to access this privacy policy in an alternative format, please contact us using the details set forth at the end of this privacy policy.

Contact Us

This privacy policy is current as of April, 2024.We reserve the right to change this privacy policy at any time, as circumstances or requirements change.

If you have any questions regarding this privacy policy or the processing of personal information we hold about you, please contact us at:

• By phone: 847-739-3200
• By email: lpinvestors@roundtablehp.com

¹ For the purposes of this privacy notice, the term “investor” includes any individual who provides personal information to us.
² For the purposes of this privacy policy, the term “personal information” has the meaning given to such term (or to terms of similar intent, such as “personal data”) under applicable law, as and to the extent applicable to your rights and our obligations with respect to such information, including (as and to the extent applicable): (i) “personal information” as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, (ii) “non-public personal information” as defined under the Gramm-Leach-Bliley Act (Public Law 106-102), and/or (iii) “personal data” as defined under the General Data Protection Regulation (EU) 2016/679 or the UK General Data Protection Regulation (i.e., the GDPR as implemented into the laws of the United Kingdom).