Privacy Policy – Recreational

Recreational, LLC ("Recreational," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit www.VenueCreate.com, correspond with us, or engage as an investor, prospective investor, or vendor.

Information we collect

We collect personal information you provide directly (through forms, subscription documents, and email), information collected automatically (device and usage information when you visit the Site), and information from third‑party sources (our fund administrator, KYC/AML providers, custodians, and public databases).

Categories of personal information we may collect include:

Identifiers — name, address, phone, email, government ID, taxpayer identification
Financial information — accreditation and qualified purchaser status, source of funds, wire instructions, capital account activity, K‑1 information
Professional information — employer, title, investment experience
Internet and network activity — IP address, browser type, pages viewed, time on site, referring URL
Inferences — investor profile derived from the above, used to tailor communications

How we use it

To evaluate investor eligibility, complete subscriptions, and maintain capital accounts
To perform KYC, AML, sanctions screening, and tax reporting
To deliver fund reporting, capital call notices, K‑1s, and other investor communications
To respond to inquiries and provide requested materials
To operate, secure, and improve the Site
To comply with legal, regulatory, and contractual obligations

How we share it

We share personal information only as necessary and only with the following categories of recipients:

Fund administrator, auditor (PwC), legal counsel (LePore Law Group), and custodians — to perform their contracted functions
Regulators, tax authorities, and courts — as required by law
Service providers — cloud hosting, email, analytics, and secure document exchange, each subject to written confidentiality obligations
Successors — in a merger, sale of assets, or reorganization affecting Recreational

We do not sell your personal information. We do not share your personal information with third parties for their own marketing purposes.

Cookies & analytics

The Site uses a small number of essential cookies for session security and a first‑party analytics provider to understand aggregate site usage. We do not use cross‑site advertising trackers. You can control cookies through your browser settings; blocking essential cookies may impair Site functionality.

Data retention

We retain investor and prospective‑investor records for the periods required by the Investment Advisers Act, IRS regulations, and applicable state law — generally the life of the fund plus seven years. Marketing and Site‑visitor data is retained for no longer than 24 months absent an active investor relationship.

Data security

We maintain administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, multi‑factor authentication for the Investor Portal, role‑based access controls, and vendor security review. No system is perfectly secure; if you suspect unauthorized access to your account, contact us at [email protected] immediately.

Your rights

Depending on your state of residence, you may have the right to request access to, correction of, deletion of, or portability of your personal information, and to opt out of certain uses. California residents have additional rights under the CCPA/CPRA; Virginia, Colorado, Connecticut, Utah, and other state residents have rights under their respective privacy laws. To exercise a right, contact [email protected]. We will verify your identity before acting on your request and will respond within the timeframes required by applicable law.

GLBA notice

To the extent Recreational is a "financial institution" subject to the Gramm‑Leach‑Bliley Act, this Privacy Policy also serves as our GLBA privacy notice. Consistent with GLBA, we restrict access to nonpublic personal information about you to those employees and service providers who need it to provide products and services to you, and we maintain physical, electronic, and procedural safeguards.

Children

The Site is not directed to children under 16, and we do not knowingly collect personal information from children.

International visitors

The Site is operated from the United States. If you access it from outside the United States, your information will be transferred to and processed in the United States, which may have different data protection standards than your country.

Changes

We may update this Privacy Policy from time to time. Material changes will be identified by an updated effective date and, where required, direct notice to investors.

Contact

For privacy inquiries or to exercise your rights, contact:

Recreational, LLC
Attn: Privacy Officer
1910 Pacific Avenue
Suite 2000
Dallas, TX 75201
[email protected]