Automated Decision Making

We do not use automated processing, including profiling, to make decisions.

To Whom We Disclose Your PI

Within the last twelve (12) months, we may have disclosed each of the categories of PI we have collected to service providers and as described below.

In the regular course of business, we do not disclose any information collected from the publicly available areas of the Site to any parties outside of First Reserve other than service providers, professional advisors and affiliates pursuant to applicable law.  We may disclose PI otherwise voluntarily provided by you (e.g., via email or through other interactions with us) to our affiliates, service providers, prospective or current investors in applicable funds, agents, contractors, professional advisors, business partners, lenders, data processors and persons employed and/or retained by them, and other third parties for the purposes of operating our business, delivering and improving the Services we provide to you, helping to facilitate transactions (including processing orders, event registrations, data storage, marketing communications and customer support), performing functions on our behalf and for other legitimate purposes permitted by applicable law and in order to fulfill the purposes described in this Privacy Policy. [For example, we may use third-party service providers in connection with the Site, such as Altvia Solutions, LLC, which we use as a service provider for our investor portal. More information on how Altvia Solutions, LLC uses your PI can be found at

These entities and individuals may have access to the PI we collect from you as permitted by law and as needed to perform their functions, in compliance with our privacy practices and policies. We require that these entities and individuals otherwise keep this information confidential.

We may disclose your PI to third parties for the following additional purposes:

  • To applicable third parties (i) to protect your safety or security or the safety or security of tangible or intangible property that belongs to us, to you or to third parties or (ii) in connection with a potential or actual reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding or other disposition of all or any portion of our business, assets or shares.
  • First Reserve may share PI with regulatory bodies having competent jurisdiction over them, as well as with tax authorities, auditors and tax advisors (where necessary or required by law, rule or regulation).

To the extent that we request PI from you and you refuse to communicate that PI to us, this may affect our ability to maintain a business relationship with you or to comply with our legal obligations.

We do not use or disclose sensitive PI for purposes other than those specified in Section 7027(m) of the implementing regulations (the “CCPA Regulations”) of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together with the CCPA Regulations, collectively, the “CCPA”). We do not “sell” or “share” (as such terms are defined by the CCPA) any of your PI that we collect to third parties.

How Long We Retain Your PI

For each of the categories of PI that we collect (listed above), we retain such PI only for as long as reasonably necessary to fulfill the purposes we collected it for, including for purposes of satisfying any legal, regulatory, accounting or reporting requirements, unless a longer retention period is otherwise required or permitted by law.

Transfers of PI

Your PI may be transferred, processed and/or stored in a country other than the one in which your PI is collected. When transferring your PI to the US or other countries, we have implemented procedures to ensure that appropriate safeguards are in place to protect the PI regardless of where it is being transferred to.

First Reserve may transfer PI to a non-equivalent country (a country or territory other than (a) a member state of the EEA; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU law to ensure an adequate level of protection for PI), in order to fulfill the purposes described in this Privacy Policy and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer agreements, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact

Your EU Data Subject Rights

The European Union’s General Data Protection Regulation (“GDPR”) is a sweeping piece of legislation that grants EU residents increased control over their PI. The GDPR allows consumers to access their PI and find out details of how that data is processed, to rectify inaccurate PI, to have their data erased (when certain conditions are met), to restrict processing of their data, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to ensure that PI is secured.

Specifically, the GDPR and other national privacy laws provide data subjects with certain rights regarding their PI. If you are an individual who resides in the EU and whose PI is collected and processed by First Reserve, you have the right to:

  • Request access to your data
  • Rectify your data
  • Take your data (in a readable, “portable” format) to another service provider
  • Erase your PI
  • Restrict or object to the processing of your PI
  • Lodge a complaint with a Member State Supervisory Authority
  • Withdraw previously given consent to collect and process PI (which will not impact PI processed before the withdrawal)
PI Rights for California Residents

The CCPA requires us to make certain additional disclosures and provides California residents with certain rights with respect to their PI. These disclosures and rights apply to you only if you are a California resident as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection and processing of their PI that is not set forth below is otherwise set forth in the Privacy Policy [above].

Please note that the below rights under the CCPA do not apply to (i) any PI we collect that is subject to the Gramm-Leach-Bliley Act (Public Law 106-102) or (ii) certain PI we collect that is subject to the Fair Credit Reporting Act (12 CFR 1022) under certain circumstances.

Only if you are a California resident (as determined in accordance with the CCPA) whose PI is collected or processed by First Reserve, you have the following rights with respect to such PI:

  • Disclosure and Access Rights:  You have the right to request that we disclose to you, free of charge,  certain information regarding our collection and use of PI specific to you over the last twelve (12) months. Such information includes:
    • the categories of PI we collected about you;
    • the categories of sources from which the PI was collected;
    • the categories of third parties to whom we disclosed the PI;
    • our business or commercial purpose for collecting such PI;
    • the specific pieces of PI we have collected about you; and
    • whether we disclosed your PI to a third party and, if so, the categories of PI that each recipient obtained.
  • Correction Rights:  You have the right to request that we correct inaccurate PI about you.
  • Deletion Rights:  You have the right to request that we delete any of your PI that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S. state and local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Non-Discrimination:  We will not discriminate against you for exercising your rights under the CCPA, including by denying Services, suggesting that you will receive (or charging) different rates for Services or suggesting that you will receive (or providing to you) a different level or quality of Services.

Questions or Concerns and Exercising Your CCPA Rights

If you have any questions or concerns regarding the information in this Privacy Policy, or would like to exercise any of your rights under the CCPA as set forth in this Privacy Policy, please calls us toll-free at + 1 833 450 1282 or email us at Please include a description of what right you want to exercise (if applicable) and the information to which your request relates. Please note that you may only make a PI disclosure request twice within a 12-month period.

Verifying Your Identity

If you choose to contact us with a request under the CCPA, we will contact you to confirm receipt of your request and to request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (e.g., the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, to verify your request.

Authorized Agent

You have the right to appoint an authorized agent to make requests under the CCPA on your behalf if you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

California’s Shine The Light Law

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our website users who are California residents to request and obtain from us a list of their PI (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.  Requests may be made only once a year and are free of charge.  [We currently do not disclose any PI to third parties for their direct marketing purposes.]

Accessibility Information

For consumers with disabilities who need to access this policy in an alternative format, please contact: