Privacy Policy

Last Updated: August, 2026

This privacy policy (this “Policy”) describes the information that we may collect about you when you visit the website (the “Site”) of Rubicon Technology Management L.L.C. (“Rubicon,” “we” or “us”) and how we use, store, share and process that information. Rubicon is the controller and responsible for the Site.

By visiting the Site, you affirm your agreement to this Policy, which we may update from time to time. If we update our Policy, we will post the updated version here. Any such changes will be effective upon posting. We urge you to review this Policy each time you visit the Site. If you do not agree with any provision of this Policy, you should not visit or use the Site.

As used in this Policy, “personal data” means information that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, any information relating to an identified or identifiable natural person, or that otherwise meets the definition of “personal data” or “personal information”, under, as applicable, the California Consumer Privacy Act (Cal. Civ. Code §§ 1798.100 et seq.) as amended, and its implementing regulations (the “CCPA”), the General Data Protection Regulation (Regulation (EU) 2016/679) and the equivalent law in the United Kingdom as incorporated into applicable United Kingdom law under section 3 of the European Union (Withdrawal) Act 2018 or any other applicable data protection or privacy law.

This Policy only addresses data that we collect when you use the Site. This Policy does not address our privacy practices when you interact with us in other ways, including in your capacity as an investor in investment vehicles managed or advised by Rubicon. This Policy also does not address our privacy practices with respect to employees, contractors, or job applicants. We address these practices in separate notices to investors, potential investors, employees, contractors or job applicants, as applicable. For clarity, while the Site, located at www.rubicontp.com, includes a link to our private, password-restricted investor portal, it does not include that portal.

What Information We Collect

We collect, and have collected over the past 12 months, the following categories of information, including personal data, in the following ways:

Information You Provide

In general, the Site is for informational purposes only. The Site does not include any opportunities for you to input, upload or otherwise voluntarily provide personal data or other information, and the Site never requests that you provide any personal data. For example, the Site does not include any webforms, registration forms, signup pages or other such opportunities for visitors to volunteer information about themselves.

Information We Collect Automatically

We collect (and have collected over the past 12 months) certain information automatically when you visit the Site, pertaining to how you access and use the Site. We use cookies, software known as JavaScript and other technologies to capture that information, which may include any of the following:

  • website traffic data,
  • geolocation information (such as information about the location of the device accessing the Site),
  • information about the type of device,
  • operating system and browser you use to interact with the Site,
  • when you access the Site,
  • how many and which pages of the Site you viewed,
  • what URL you clicked on, and what pages you visited before navigating to the Site,
  • identifiers and Internet or other electronic network activity information (including the IP address from which you accessed webpages, 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 a page of the Site.

We use Google Analytics to collect some of this information. Google Analytics collects information such as how often users visit the Site, what pages users visit, and what other sites they visited prior to or after coming to the Site. More information on how Google Analytics uses your data can be found at www.google.com/policies/privacy/partners/.

We use a cookie consent banner to manage cookies on the Site. Cookies that are strictly necessary for the Site to function are always active. All other cookies, including analytics cookies used in connection with Google Analytics, are not activated unless and until you provide your affirmative consent through the cookie banner. You may accept, decline, or manage your cookie preferences by category when you first visit the Site, and you may change your choices at any time using the cookie preferences link available on the Site.

One of the technologies we use to collect this information is “cookies.” Cookies are small text files that may be placed on your browser when you visit the Site. Using the settings of your Internet browser, depending on the browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Consult your browser’s HELP menu to learn your options with respect to cookies. If you choose to turn off cookies, you may not have access to many features that make your browsing of the Site smoother. You may at any time delete any cookies by using the relevant option of your Internet browser or by deleting the cookies on your hard drive. To find out more about cookies please visit: www.allaboutcookies.org or www.youronlinechoices.eu.

Although we do not associate any of this automatically collected information with particular individuals or otherwise use it to identify specific individuals, some jurisdictions consider the information we collect from the Site, such as IP addresses, geolocation information, and internet or other electronic network activity information to be personal data.

How We Use Information

We use your personal data for our legitimate business interests, such as to carry out and improve our business. In particular, we use this information for the following business or commercial purposes:

  • to improve the Site,
  • for website analytics purposes,
  • to facilitate your access to and use of the Site,
  • to help us maintain, improve, protect and secure the Site and our business,
  • as otherwise specified in this Policy, and
  • as otherwise required or permitted by applicable law.

Legal Bases

Certain data protection laws require us to have a legal basis for collecting and using your personal data. Where required by applicable law, we process your personal data on the following legal bases: (a) your consent, where you have provided it; (b) our legitimate interests in operating and improving the Site, provided such interests are not overridden by your data protection rights; or (c) compliance with a legal obligation.

When We Disclose Information

We may disclose, and have disclosed over the past 12 months, the categories of information we collect as described in this Policy to the following entities:

  • to our affiliates;
  • to our service providers, to help us perform the functions described in this Policy;
  • if we believe that such disclosures are required to comply with applicable laws, regulations, subpoenas, legal process, governmental investigations, regulatory requests or inquiries, to cooperate with law enforcement, to assert or defend legal claims, to protect our and others’ rights, property, or safety, or for the purposes of crime and fraud prevention and remediation;
  • to our acquirers or successors, if Rubicon, or any of our assets or businesses, are acquired by, transferred to, or merged with another entity, or in connection with a bankruptcy or similar transaction, for use in a manner consistent with this Policy; or
  • if you otherwise provide consent or as otherwise required or permitted by applicable law.

We do not use or disclose personal data for direct marketing purposes.

We do not sell personal information for monetary consideration. We may collect information from visitors to the Site through the use of cookies or similar technology, as described in this Policy above under “Information We Collect Automatically.” For example, we use Google Analytics on our Site. Google Analytics functions as our service provider under Google’s data processing terms, and we have configured it so that this does not constitute a “sale” or “share” of personal information for cross-context behavioral advertising.

Data Transfers

We may transfer the personal data we collect about you to countries other than the one in which you reside for the purposes described in this Policy, some of which may have different standards of protection for personal data compared to the country in which you reside. Where required, we will put appropriate safeguards in place, for example contractual protections, to ensure the lawfulness of the transfer. Please contact us using the contact details in the "Contact Information" section below if you would like further information about this.

Your Rights and Choices

Depending on where you reside, you may have the following rights with respect to our use, processing and sharing of your personal data, as described below. There may be exceptions to these rights under applicable law. If you wish to exercise any of these rights, please contact us using the contact details in the “Contact Information” section at the end of this Policy.

  • Access: You may request a copy of the personal data that we have collected, used, disclosed or otherwise processed about you, and why we collected, used, disclosed, or otherwise processed that personal data, including the categories of personal data collected, the specific items of personal data collected, the categories of sources from which we collected personal data, the purposes for which we use the personal data, the categories of third parties with whom we share the personal data, and the categories of information that we sell or disclose to third parties.
  • Correction: You may have the right to request that we correct any inaccurate information that we maintain about you.
  • Opt-out of Sharing (for Cross-Context Behavioral Advertising, including Targeted Advertising) or the Sale of Personal Data: You have the right to opt-out of the processing of your personal data for the purposes of targeted advertising or the sale of your personal data.
  • Deletion: You may have the right to ask us to delete your personal data subject to certain exceptions.
  • Restriction: You may have the right to request that we suspend the processing of your personal data.
  • Objection: You may have the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data.
  • Portability: You may have the right to request that your personal data be provided to you, or to another data controller, in a commonly used, machine-readable format.
  • Withdraw Consent: Where we are relying on consent to process your personal data, you may withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
  • Complaints: You may have the right to lodge a complaint with us or the applicable data protection supervisory authority.

Only you, or a person whom you authorize to act on your behalf, may make a request related to your personal data. Except for requests to opt-out, the request must:

  • provide sufficient information for us to reasonably verify you are the person about whom we collected personal data or an authorized representative of such person; and
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Except for requests to opt-out, we cannot respond to your request or provide you with personal data if you do not take the foregoing actions. Making a request does not require you to create an account with us. We will use personal data provided in a request only to verify your identity or authority to make the request or as required by law.

How Long We Keep Your Personal Data

We will retain each category of personal data for as long as we deem reasonably necessary in connection with the purposes for which it was collected as described in this Policy or as otherwise permitted under applicable law. Specifically, we retain cookie and analytics data for up to 14 months; and we retain records related to privacy requests for 24 months, as required by law. We may retain personal data for longer periods where required by law or to establish, exercise, or defend legal claims.

Sensitive Personal Data

We do not collect sensitive personal information (as defined by the CCPA) through the Site for purposes other than those permitted under the CCPA without your consent. To the extent we collect sensitive personal information (as defined by the CCPA), you have the right to limit our use and disclosure of such information to uses necessary to perform the services or provide the goods you request, or as otherwise permitted by law.

Children’s Privacy

Our Site is not intended for use by children under the age of 16. We do not have actual knowledge that we sell or share the personal data of children under the age of 16.

Protection of Information and Network Security

We endeavor to protect your personal data. We use technical, administrative and physical methods to maintain the integrity and security of our databases, including firewalls. Please be aware though that there is no such thing as “perfect security” on the Internet, and third parties may unlawfully intercept or access transmissions or private communications. We will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personal data. You use the Site and send us information at your own risk.

Do Not Track

We do not track visitors of the Site over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals.

Global Privacy Control

We recognize the Global Privacy Control (“GPC”) universal opt out preference signal. You may request to opt out of the sale, sharing (for cross context behavioral advertising, including targeted advertising) of your personal data by broadcasting the GPC on your browsers and/or browser extensions that support GPC. Where required by applicable law, we treat such signals as a valid request to opt out of the sale or sharing of personal data for the browser or device that communicates the signal.

California's Shine the Light Law

California Civil Code Section 1798.83, known as the “Shine the Light” law, permits California residents to request and obtain from us a list of their personal data (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties, subject to applicable exemptions under law. Requests may be made only once a year and are free of charge. To make such a request, California residents may contact us using the contact details in the “Contact Information” section below.

The Site contains links to websites controlled and maintained by our current or former portfolio companies and other third parties. We provide these links solely as a convenience for you. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites is used. This Policy does not govern the use of information collected on such third party websites. In addition, the Site contains a link to a password-restricted investor portal reserved for our investors. The investor portal is governed by a separate privacy policy. Should you choose to visit any of these other sites, you should review their applicable privacy policies to ensure that you understand and are comfortable with their practices concerning your personal data.

Contact Information

If you wish to reach us concerning this Policy or any data that we collected about you when you visited the Site, please email us at privacy@rubicontp.com or write to us at Rubicon Technology Management L.L.C., 1470 Walnut Street, Suite 400, Boulder, CO 80302, Attn: Chief Compliance Officer. You may also call us toll free at: (888) 794-4410

Governing Law

The laws of the State of Colorado govern this Policy. Any dispute relating to this Policy or your use of the Site shall be resolved solely in the state or federal courts located in Denver, Colorado. You agree to waive trial by jury in any such action.