Privacy Policy
Updated July 15, 2025
Introduction
Wind River Capital Strategies, LLC and its affiliates (collectively referred to as "Wind River Capital Strategies," "WRCS," "we," "us," or "our" herein) provide non-discretionary investment advisory, consulting, and portfolio oversight services to endowments and foundations. WRCS and its employees place a high priority on protecting sensitive personal and financial information. We do not disclose clients' confidential information, or that of former clients, except as permitted by you, required by law, or as otherwise detailed in this Privacy Policy.
This Privacy Policy describes what personal information we collect, how we use and share that information as data controllers, and your choices concerning our data practices.
What Personal Information We Collect and From Where We Get It
We may collect personal information about you from your discussions and correspondence with us, from legal documents, from information you supply about your investments or portfolio, from your incoming wire transfers or invoice payments, and from applications and other forms completed by you on our website or provided to us by your authorized representatives and other fiduciaries. This may include contact details, biographical data, transaction history, investment data, and account numbers.
For those visiting our website, we may collect IP addresses and browser metadata through cookies or similar technologies. See our Cookies Policy for more.
How We Use Personal Information
We use personal information to:
Provide investment consulting and advisory services;
Maintain and improve our website;
Respond to inquiries and send administrative communications;
Fulfill legal and compliance obligations;
Protect our rights, systems, and users.
Basis for Processing Your Personal Data
We may process your data on the basis of:
Your consent;
Performance of a contract;
Legal obligations;
Our legitimate interests (where such interests do not override your rights).
Sharing and Disclosure of Personal Information
We may disclose personal data to custodians, fund administrators, investment managers, legal advisors, and nonaffiliated service providers to support our operations. These parties are required to handle your data responsibly.
International Transfer of Personal Information
If we transfer your personal data outside your jurisdiction, we will do so in compliance with applicable laws, including the use of appropriate contractual protections.
Your Rights and Choices
You may have certain rights depending on your location, including:
Access to your data;
Rectification or erasure;
Objection to processing;
Data portability;
Withdraw consent (where applicable).
To exercise these rights, email us at privpol@windrivercs.com.
Retention and Destruction of Personal Information
We retain data only as long as necessary to fulfill the purposes outlined here, unless a longer retention period is required by law. Once no longer needed, data is securely destroyed or anonymized.
Children
Our services are not intended for children under 16, and we do not knowingly collect their data.
Security
We implement reasonable security measures to protect your data but cannot guarantee absolute protection due to the nature of the internet.
Changes to This Policy
We may update this policy periodically. The current version will always be available at www.windrivercs.com.
Contact Us
If you have questions or concerns about our privacy practices, please contact us at:
Email: privpol@windrivercs.com
Address: 25 Broadway, New York, NY 10004
Additional Privacy Disclosures for Investment Funds and Qualified Investors
1. Regulatory Recordkeeping and Investor Qualification Data
In connection with any private fund investment, we may collect and maintain additional personal information, including:
• Tax identification numbers
• Financial qualification information (e.g., net worth, income, AUM)
• Documentation supporting Accredited Investor or Qualified Purchaser status
• Citizenship and residency status
• Source of wealth and AML/KYC documentation
• Beneficial ownership information
Such information is maintained to comply with:
• The Securities Act of 1933
• The Investment Company Act of 1940
• The Bank Secrecy Act
• The USA PATRIOT Act
• The Investment Advisers Act of 1940
• Applicable state and foreign securities laws
We may retain such information for regulatory purposes even after any relationship ends.
2. Anti-Money-Laundering and Sanctions Screening
We may screen personal data provided by you against:
• OFAC Sanctions Lists
• U.S. Treasury and other governmental watch lists
• Internationally recognized AML databases
We may disclose your information to service providers and legal authorities to comply with AML/CTF obligations, including suspicious activity reporting where mandated by law. You consent to these compliance activities as a condition of accessing our investment-related services.
3. Data Sharing with Fund Service Providers
For investors in any WRCS-sponsored investment vehicle, we may disclose personal information to:
• Independent fund administrators
• Custodians and prime brokers
• Auditors and legal counsel
• Portfolio managers and due diligence partners
• Transfer agents and tax reporting providers
Each such party is contractually obligated to protect the confidentiality and security of your information and to use it only for lawful and authorized purposes.
4. Marketing Rule and Performance Presentation Data
Where legally permitted, WRCS may use anonymized or aggregated data:
• In marketing materials
• To demonstrate operational or investment results
• For internal analytics and service improvement
We will not publicly attribute any investment, performance, testimonial, or endorsement to any client or investor without express written consent, consistent with SEC Marketing Rule requirements.
5. Cross-Border Data Transfers and GDPR Compliance
If you are located outside the United States, including the European Economic Area, you acknowledge that your personal data may be transferred to the U.S., where data protection laws may differ. We will take steps consistent with applicable law to ensure adequate protections, which may include:
• Standard contractual clauses
• Regulatory authorizations
• Certifications or binding organizational rules
You may request information about cross-border safeguards by contacting us.
6. Rights of California Residents (CPRA/CCPA Notice)
If you are a resident of California, you may have additional rights, including:
• Right to know what categories of personal information we collect and why
• Right to request deletion of personal information (subject to regulatory exceptions)
• Right to correct inaccurate personal information
• Right to limit use of sensitive personal information
• Right to opt out of any “sale” or “sharing” of personal information (not applicable to WRCS)
Requests may be submitted to:
privpol@windrivercs.com
WRCS does not:
• Sell personal information
• Share personal information for cross-context behavioral advertising
We are exempt from certain CPRA obligations as a registered (or exempt reporting) investment adviser and private fund sponsor, but we continue to honor all applicable individual data rights.
7. Retention to Satisfy Legal Obligations
To comply with federal securities and AML laws, we may retain specific data elements for a minimum of five (5) years after the latest date of:
• Subscription or investment activity
• Capital withdrawal
• Termination of advisory or client relationship
In certain cases, longer retention periods may be required.
8. Updates; Priority of Fund Documents
This Privacy Policy supplements and is to be read together with any Offering Documents provided in connection with a WRCS Fund. If this Privacy Policy and any Offering Documents conflict, the Offering Documents will govern with respect to the subject matter of the investment. We will update this policy periodically without prior notice, and the most current version will always control.
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