Effective 8 March 2017
We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of investor personal information, and the information we gather over the Site is protected by those policies and procedures. Generally, we collect non-public personal information about investors from the following sources:
* Information we receive from investors on applications or other forms, including the information we collect on the Site, and
* Information about investors’ transactions with us, our affiliates or others.
Our policy is that:
* We do not disclose any non-public personal information about current or former investors to anyone, except as permitted by law. We may voluntarily disclose non-public personal information about our current or former investors to regulatory authorities in connection with our business or our affiliates (such as any of our funds). In addition, we share non-public personal information with certain service providers, to the extent permitted by law, and we require those service providers to keep the non-public information confidential. For example, we may provide such information to prime brokers, ISDA counterparties, attorneys, third-party marketing firms, fund administrators and auditors.
* We restrict access to non-public personal information about investors to employees and service providers who need to know that information to provide services to investors.
* We maintain physical, electronic and procedural safeguards that comply with federal standards to guard investors’ personal information.
Collection of Information
In general, you can browse any non-password protected section of the Site without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users’ demographics, interests and behavior to better understand, protect and serve you and our clients. This information may include the URL from which you just came (whether this URL is on the Site or not), which URL you go to next (whether this URL is on the Site or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services.
Use and Disclosure of Information
We may use personal information about you to analyze Site usage, improve our content and product offerings and customize the Site’s content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site.
We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.
Control of Personal Information
You can review and change the information you submit to us by contacting us at firstname.lastname@example.org. On your request, we will deactivate any password you have and remove your information from our active databases. To make this request, email email@example.com. Any password you have will be deactivated promptly based on your account activity and in accordance with our deactivation policy and applicable law.
Your information is stored on our servers located in Australia. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls” and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company.
It is possible, however, that a third party will circumvent such security measures. We do not guarantee that our security measures will successfully prevent third parties from accessing the information we collect. In the event of a security breach involving your personal information, we will make any legally required disclosures to you, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your username, password, credit card information or national identification number in an unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Persons under the age of 18 are not eligible to use the Site and, therefore, we do not knowingly collect any personal information from persons under the age of 18.
Conditions Of Use
Changes to this policy