Privacy Policy

Overview

The privacy of your personal information matters to Dimension Credit (“Dimension Credit,” “we,” “us,” or “our”). We maintain policies designed to protect the confidentiality and security of the information we hold about you. At the same time, to provide the services you request and to let you know about investment opportunities, we need to collect and use certain personal information. Without some of that information, we may be unable to offer or administer our services.

This notice explains the types of personally identifiable information (“PII”) we collect, why we collect it, the circumstances in which we may share it, your rights regarding your information, and how to contact us. It is provided to comply with applicable data protection laws, including Regulation S-P (“Privacy of Consumer Financial Information”) under the Gramm-Leach-Bliley Act (“GLBA”) and the privacy regulations of the Federal Trade Commission. If you are a California resident, see “California residents.” If the GDPR applies to you, see “EU and UK residents.” If you invest in a Cayman-domiciled Dimension Credit entity, see “Cayman Islands investors.”

We may update this notice from time to time. When we do, we will post the current version on our website. Any examples in this notice are illustrative, not exhaustive.

Dimension Credit never sells the personal information it collects.

Information we collect

Depending on your relationship with us, we may collect the following categories of personal information:

Where we get your information

We collect personal information from several sources:

Directly from you — through telephone calls, voicemails, written correspondence, email and other electronic communications, and on subscription agreements, investor questionnaires, applications, and other forms (including AML, identity, and verification documentation).

From your transactions and activity — information about your transactions with us or with others, and information captured through our website, data rooms, and investor portal, including via cookies.

From third-party and public sources — including publicly available directories, bankruptcy registers, tax authorities (including those outside the U.S. if you are taxable in another jurisdiction), governmental and regulatory authorities to whom we have reporting obligations, credit agencies, and fraud-prevention and detection organizations.

We may combine information we receive from these sources with information you provide us — for example, to correct our records or to help prevent and detect fraud.

How we use your information

We use your personal information to evaluate your suitability and eligibility as an investor, and perform our KYC, AML, and other legal and contractual obligations; administer your onboarding and admission, including setting up the account(s) that allow you to purchase interests; communicate with you and your representatives, advisors, and agents during admission and to execute the relevant agreements; operate the fund and our business, including accounting, reporting, customer service, verifying your information, and processing contributions and distributions; facilitate transfers of funds and other transactions between you and us; perform audits and verifications relating to the quality, effectiveness, and compliance of our services; maintain the security and integrity of our systems, products, and services, including detecting security incidents and protecting against fraudulent, malicious, or illegal activity; facilitate business transactions involving Dimension Credit, including enabling an actual or proposed assignee, transferee, or participant to evaluate a transaction; comply with applicable U.S., state, local, and non-U.S. laws, rules, and regulations; keep you informed about Dimension Credit and its affiliates, including other investment opportunities; and carry out any other purpose we have notified to you or agreed with you in writing.

Where the law requires or permits, we monitor communications to comply with regulatory obligations and to protect our business and the security of our systems. Where the GDPR applies, the legal bases on which we rely for these purposes are described in “EU and UK residents.”

How we share your information

We do not sell your personal information.

We may share your information, where permitted by applicable law, among our affiliated entities and with the service providers and other parties who help us operate our business and serve our investors. These may include administrators, banks, custodians, lenders, auditors, law firms, professional and financial advisors, consultants, placement agents, technology and back-office providers, data processors, and other contractors and agents. We may also disclose information to governmental, regulatory, and self-regulatory bodies, or in response to legal process or regulatory inquiries, where required or permitted by law.

Where appropriate, we put contracts in place with third parties that handle your information to help protect its privacy and integrity.

Cookies and online tracking

When you use our website, fund data rooms, or investor portal, we and our service providers may collect information through cookies and similar technologies. We use these to enable core site functionality, remember your preferences, understand how our sites are used, and support security. You can manage cookies through your browser settings, though disabling some may affect how parts of our sites function.

How long we keep your information

We retain each category of personal information only as long as reasonably necessary for the purposes described above, except where a longer period is required by applicable law, court order, or regulation. In general, we retain your information throughout the life of your investment. As a matter of principle, we do not keep your information longer than we need it.

How we protect your information

We treat the protection of personal information as a core part of how we operate. We maintain appropriate technical and organizational measures — including physical, electronic, and procedural safeguards — designed to protect the personal information in our possession or under our control against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Your privacy rights

Subject to applicable law, you may have the right to request access to the personal information we hold about you, to ask us to correct inaccurate information, and to request deletion of your information. Depending on where you live, you may have additional rights, described in the sections below.

To exercise any of these rights, contact us using the details in “How to contact us.” We verify requests by matching the information you provide against our records; depending on the sensitivity of the request, we may ask for additional information or, where applicable, your investor portal credentials to confirm your identity. We will tell you in writing if we cannot comply with a request and explain why.

California residents (CCPA)

This section supplements the notice above and applies if you are a natural-person California resident. It describes your rights under the California Consumer Privacy Act (“CCPA”). Where this notice conflicts with the privacy requirements of the GLBA or Regulation S-P, those requirements control.

Information we collect

In the past twelve months, we have collected the following categories of personal information defined under the CCPA:

We collect sensitive personal information only for purposes permitted under the CCPA — such as providing our services, detecting and resisting fraud and security incidents, and verifying or maintaining service quality — and not to infer characteristics about you.

How we share it

We do not sell your personal information or share it for cross-context behavioral advertising, and have not done so in the past twelve months. We may disclose the categories above for business purposes to the recipients described in “How we share your information” — including administrators, banks, auditors, law firms, governmental agencies, consultants, and placement agents — and as required by law.

Your rights

You have the right to know what personal information we collect and how we use and disclose it; to request access to and deletion of your information; to request correction of inaccurate information; and not to be discriminated against for exercising your rights (consistent with Cal. Civ. Code §1798.125). To exercise these rights, contact us as described below; we will verify your request before responding. A disclosure request can cover the twelve months preceding it, and we are not required to respond to such a request more than twice in a twelve-month period.

EU and UK residents (GDPR)

This section applies to the extent the GDPR governs the processing of your personal information. Where it does, one or more Dimension Credit entities act as “controllers” of that information — meaning they control the information collected in connection with your investment and make decisions about how it is used and protected.

Legal bases

The categories of information we process and our sources for it are described above. We rely most commonly on the following legal bases: that processing is necessary to perform a contract with you; that it is necessary to comply with a legal obligation; or that it is in our legitimate interests (or those of a third party), where those interests are not overridden by your interests and fundamental rights. We may occasionally rely on other bases, including your consent, the protection of vital interests, or performance of a task in the public interest. If you do not provide certain information when requested, we may be unable to perform all or part of our contract with you.

Recipients and transfers

We may share your information with the recipients described in “How we share your information,” as well as with regulators, tax authorities, auditors, and tax advisers where necessary or required by law. We may transfer your information to a country that has not been recognized as providing an adequate level of protection where necessary to enter into or perform our agreement with you, applying appropriate safeguards as required by law. You can request information about those safeguards using the contact details below.

Your rights

Subject to applicable law, you have the right to access and receive a copy of your information; to request its correction or erasure; to restrict or object to its processing; to withdraw any consent you have given; to data portability; and not to be subject to a decision based solely on automated processing. The right to erasure is not absolute, and we may be required to retain information to meet a legal obligation. You also have the right to lodge a complaint with the data protection authority in your jurisdiction.

Cayman Islands investors (DPA)

If you invest in a Dimension Credit entity domiciled in the Cayman Islands, this section describes how we handle personal data under the Cayman Islands Data Protection Act (as amended) (the “DPA”). If you are a corporate investor providing information about individuals connected to you, this section is relevant to those individuals, and you should pass this notice on to them.

We process your information to perform our contractual rights and obligations; to comply with legal and regulatory obligations (including AML and counter-terrorist-financing requirements, sanctions, tax-information exchange, beneficial-ownership and statutory-register obligations, and requests from authorities); and for our legitimate interests, such as corresponding with you about your investment, assessing your requests, handling complaints and disputes, obtaining professional advice, meeting our audit and reporting obligations, and protecting our business and systems — where those interests are not overridden by your rights. We apply appropriate technical and organizational measures consistent with the DPA, retain your information for as long as needed for these purposes or as legally required, and will not make decisions producing legal or similarly significant effects about you based solely on automated processing unless permitted under the DPA. Under the DPA you have rights including to access your information, to have it corrected, to restrict or stop its processing, and to require its deletion in certain circumstances.

Changes to this notice

We may revise this notice from time to time. The current version will always be available on our website, and the “last updated” date above reflects the most recent changes.

How to contact us

You can contact us about this notice, or to exercise any of your rights, by:

• Email investor@dimensioncredit.com
• Phone +1 (345) 743 · 4667
• Mail
  20 Genesis Close, George Town, Grand Cayman, KY1-1208
• Website dimensioncredit.com