PRIVACY POLICY NOTICE
INTRODUCTION
Your privacy is very important. This "Privacy Policy Notice" is provided by Manager, its affiliates and the Company and sets forth the policies of Manager, its affiliates and the Company for the collection, use, storage, sharing, disclosure (collectively "processing") and protection of personal data relating to current, prospective and former Investors, as applicable.
This Privacy Notice is being provided in accordance with the requirements of data privacy laws, including the US Gramm-Leach-Bliley Act of 1999, as amended, or any other law relating to privacy or the processing of personal data and any statutory instrument, order, rule or regulation implemented thereunder, each as applicable to Manager, its affiliates and the Company (collectively “Data Protection Laws”). References to "you" or "Investor" in this Privacy Notice means any Investor who is an individual, or any individual connected with an Investor who is a legal person (each such individual a “data subject”), as applicable.
Capitalized terms used herein but not defined herein shall have the meanings assigned to them in the PPM as may be supplemented, updated or modified from time to time.
TYPES OF PERSONAL DATA
The categories of personal data the Company may collect include names, residential addresses or other contact details, signature, nationality, tax identification number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds details or other sensitive information, such as data contained in the relevant materials or documents.
COLLECTION OF PERSONAL DATA
The Company may collect personal data through: (i) information provided directly by you or another person on your behalf; (ii) information obtained in relation to any transactions between you and the Company; and (iii) recording and monitoring of telephone conversations and electronic communications as described below. The Company also may receive your personal information from third parties or other sources, such as our affiliates, Manager, Avestor, 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.
LEGAL BASIS & PURPOSE OF PERSONAL DATA USE
The Company may process your personal data for the purposes of administering the relationship between you and the Company (including communications and reporting), direct marketing of Company products and services, monitoring and analyzing Company activities and complying with applicable legal or regulatory requirements (including AML, fraud prevention, tax reporting, sanctions compliance or responding to requests for information from supervisory authorities with competent jurisdiction over Company business). Your personal data will be processed in accordance with Data Protection Laws and may be processed with your consent, upon your instruction or for any of the purposes set out herein, including where Company or a third-party considers there to be any other lawful purpose to do so.
Where personal data is required to satisfy a statutory obligation (including compliance with applicable AML or sanctions requirements) or a contractual requirement, failure to provide such information may result in your subscription being rejected or compulsorily redeemed or withdrawn, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.
PERSONAL DATA SHARING
The Company may disclose information about you to our affiliates or third parties, including Avestor, prime brokers and executing brokers, lenders and other counterparties of the Company for our everyday business purposes, such as to facilitate transactions, maintain your account(s) or respond to court orders and legal investigations. It may also be necessary, under AML and similar laws, to disclose information about Investors in order to accept subscriptions from them or to facilitate the establishment of trading relationships for the Company with executing brokers or other counterparties. We will also release information about you if you direct us to do so.
The Company may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you. You may prevent this type of sharing by contacting us at the contact below. If you are a new Investor, the Company can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date of your initial investment in or commitment to the Company. When you are no longer an Investor, we may continue to share your information with our affiliates for such purposes. We may also disclose information about your transactions and experiences to our affiliates for their everyday business purposes.
The Company may disclose information you provide to companies that perform marketing services on our behalf, such as any placement agent retained by the Company.
COMMUNICATIONS MONITORING
The Company may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crimes.
RETENTION PERIODS AND SECURITY MEASURES
The Company will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Laws. Personal data will be retained for the duration of your investment in the Company, as applicable, and for a minimum period of five to seven years after a redemption or withdrawal, as applicable, of an investment from the Company, as applicable, or liquidation of the Company. The Company may retain personal data for a longer period for the purpose of marketing products and services or compliance with applicable law. The Company will periodically review the purpose for which personal data has been collected and decide whether to retain or delete if it no longer serves any purpose.
To protect your personal information from unauthorized access and use, the Company applies technical and organizational security measures in accordance with Data Protection Laws. These measures include computer safeguards and secured files and buildings. We will notify you of any material personal data breaches affecting you in accordance with the requirements of Data Protection Laws.
CHANGES TO PRIVACY POLICY
In the unlikely event there are changes to our Privacy Policy that would permit or require additional disclosures of your confidential information, the Company will provide written notice to you, and you will be given an opportunity to direct us as to whether such disclosure is acceptable.