The Funds and the Adviser (collectively referred to as "we") consider customer privacy to be fundamental to our relationship with our customers. In the course of operating and acting as trading advisor to the private investment fund in which you have invested (the “Fund”) or acting as trading advisor over your individual account (the “Account”), we collect personal information about you (“nonpublic personal information”). We collect this information to know who you are and to meet our obligations under the laws and regulations that govern us.
Information We Collect
We collect nonpublic personal information about you from three sources:
- Information on subscription agreements or other forms. This category may include your name, address, tax identification number, age, marital status, number of dependents, assets, debts, income, employment history, beneficiary information and personal bank account information;
- Information from your transactions with us, such as your investment history in the Fund and/or the Account and your account balance; and
- Information obtained from others, such as our affiliates and consumer credit reporting agencies.
Information We Disclose
We will not disclose any non-public personal information about you except to our affiliates such as our affiliated pooled investment vehicles, investment sub-advisers and general partners, and to nonaffiliated third parties for our everyday business purposes, such as to process your transactions, maintain your account(s) and respond to court orders, regulatory examinations and legal investigations. Nonaffiliated third parties we share with can include our accountants, attorneys and auditors.
We may also disclose your nonpublic personal information to our affiliates for marketing purposes, such as to offer our products and services to you.
Protecting Your Information
To protect this information, we permit access only by authorized employees who need access to that information in order to perform their jobs. To protect your nonpublic personal information from unauthorized access and use, we use security measures that comply with U.S. federal and international law. These measures include computer safeguards and secured files and buildings.
We treat information concerning our former customers the same way we treat information about our current customers.
Keeping You Informed
EU GDPR Information
Please note that for our European Union (“EU”) resident individual investors, it is necessary that your personal data be transferred to the United States, Bermuda and Canada so that we may perform the agreed upon services for you. The EU’s General Data Protection Regulation (“GDPR”) requires us to disclose to you that no adequacy decision has been rendered by the European Commission as to the protection of your personal data when transferring it to the United States or Bermuda. However, we do take the security of your personal data/information seriously. Any party that receives this information pursuant to the foregoing will be authorized to use it only for the services required and as allowed by applicable law or regulation, and will not be permitted to share or use this information for any other purpose. To protect this information, we permit access only by authorized employees who need access to that information in order to perform their jobs. To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings. You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please contact Investor Relations, at (615) 823-8505 or firstname.lastname@example.org. We shall retain your personal data for as long as you are an investor, or as long as you express and interest in the Funds, and thereafter only as long as necessary to comply with applicable laws that require us to retain your personal data, such as data retention rules. The GDPR provides EU resident investors with additional rights such as: (1) the right to receive from us your personal data that you have provided to us in a structured, commonly used and machine-readable format (right of portability), as well as the right to have us transmit your personal data that you have provided us to others, upon your request, in such a format; (2) the right to rectify any of your personal data that is inaccurate or incomplete; (3) the right to lodge a complaint of an alleged infringement of the GDPR with an EU supervisory authority in a member state of your habitual residence or place of work; (4) the right to the erasure of your personal data under certain conditions specified in the GDPR, such as when your personal data is no longer necessary for us to perform the services for you, your consent has been withdrawn or when your personal data is no longer legally required to be retained by us; and (5) the right to restrict the processing or object to the processing of your personal data by us under certain conditions specified in the GDPR, such as if you don’t want us to market our products and services to you. We may disclose your personal data to our affiliates, such as Nephila Advisors LLC and to third parties such as MUFG Fund Services Limited in its capacity as administrator. You may opt-out/object to our marketing to you by contacting Investor Relations, at (615) 823-8505 or email@example.com. Please note that we have designated Nephila Advisors (UK) Limited at 53 New Broad Street, London EC2 1JJ, United Kingdom as our designated representative in accordance with the GDPR.