Privacy Policy

This policy sets out the privacy practices of Kimmeridge Energy Management Company, LLC and Kimmeridge Active Engagement, LLC (“Kimmeridge”, “we”, “our” or “us”) for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data you may provide to us either through this website (the “Site”) or otherwise. 

References to “you” or an “investor” in this policy mean any investor who is an individual, or any individual connected with an investor who is a legal person, as applicable.

Please contact [email protected] with any questions about this policy or requests with regards to the personal data we hold.

The Types of Personal Data We May Collect

When you visit the Site you may be asked to provide certain non-public personal information (“Personal Information”) in order to help us manage our relationship with you and serve your needs. The Personal Information we may collect may include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable law, that may be contained in the relevant materials, documents, or obtained through background searches.

How We Collect Personal Data

We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; or (ii) information that we obtain in relation to any transactions between you and us.

We also may receive your personal information from third parties or other sources, such as our affiliates, service providers, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

How We May Use Personal Information

We may process your personal data for the purposes of administering the relationship between you and us (including subscription processing, investment related services, communications and reporting, account maintenance, identity and data confirmation), marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities, or law enforcement agencies). 

How We Share Personal Information 

We may process and share your Personal Information with unaffiliated entities in compliance with applicable law, to provide services to you, administer, maintain or manage an account or perform our obligations as an investment manager or to comply with contractual requirements.  

How We Protect Personal Information

We will not retain Personal Information for longer than is necessary in relation to the purpose for which it is collected, subject to applicable law. 

To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with applicable law. These measures include electronic and physical safeguards and secured files and buildings.