Privacy Policy
This privacy policy explains the manner in which the Partnership collects, utilizes and maintains
nonpublic personal information about the Partnership’s investors, as required under federal
legislation. This privacy policy only applies to nonpublic information of investors who are
individuals (not entities).
How We Collect Personal Information
The Partnership collects personal information about its investors mainly through the following
sources:
- Subscription forms, investor questionnaires and other information provided by the investor in
writing, in person, by telephone, electronically or by any other means. This information
includes name, address, nationality, tax identification number, and financial and investment
qualifications; and - Transactions within the Partnership, including account balances, investments and withdrawals.
With Whom We May Share Personal Information
The Partnership does not sell or rent investor information. The Partnership does not disclose
nonpublic personal information about its investors to nonaffiliated third parties or to affiliated
entities, except as permitted by law. For example, the Partnership may share nonpublic personal
information in the following situations:
- To service providers in connection with the administration and servicing of the Partnership,
which may include attorneys, accountants, administrators, auditors and other professionals. The
Partnership may also share information in connection with the servicing or processing of
Partnership transactions; - To affiliated companies in order to provide you with ongoing personal advice and assistance with
respect to the products and services you have purchased through the Partnership and to introduce
you to other products and services that may be of value to you; - To respond to a subpoena or court order, judicial process or regulatory authorities;
- To protect against fraud, unauthorized transactions (such as money laundering), claims or other
liabilities; and - Upon consent of an investor to release such information, including authorization to disclose
such information to persons acting in a fiduciary or representative capacity on behalf of the
investor.
How We Protect Personal Information
- The Partnership’s policy is to require that all employees, financial professionals and companies
providing services on its behalf keep client information confidential. - The Partnership maintains safeguards that comply with federal standards to protect investor
information. The Partnership restricts access to the personal and account information of
investors to those employees who need to know that information in the course of their job
responsibilities. Third parties with whom the Partnership shares investor information must agree
to follow appropriate standards of security and confidentiality. - The Partnership’s privacy policy applies to both current and former investors. The Partnership
may disclose nonpublic personal information about a former investor to the same extent as for a
current investor. - The Partnership may make changes to its privacy policy in the future. The Partnership will not
make any change affecting you without first sending you a revised privacy policy describing the
change.
For California Residents Only
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy
Policy and applies solely to users who reside in the State of California (“you”). We adopt this
notice to comply with the amended California Consumer Privacy Act of 2018 (“CCPA”), The California
Privacy Rights Act (the “CPRA”) and other California privacy laws. Any terms defined in the CCPA
and/or the CPRA have the same meaning when used in this notice.
Categories of personal information that we collect –
During our communication with you via texts, calls, emails we might collect the below mentioned
categories of personal information. This information might also be collected if you visit our
website. Note that the categories listed below are defined by California state law. Inclusion of a
category in the list below indicates only that, depending on the services we provide you, we may
collect some information within that category. It does not necessarily mean that we collect all
information listed in a particular category.
Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data.
Physical location or movements.
Professional or employment-related information.
Current or past job history or performance evaluations.
Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
How We Use the Information We Collect
We may use the information we collect from you to:
- provide services to you;
- bill/invoice you;
- complete corporate transactions;
- manage any accounts that you may have with us;
- validate your identity;
- send personalized marketing messages via email, post and telephone to you. Where required by
applicable law, we will send these messages with your consent, and you have the right to opt out
of receiving marketing by contacting us; - serve relevant advertising on our site and third-party sites related to our products and
services which are personalized to your interests; - provide you with notice of product releases, special events, trainings, promotions or other
matters relevant to you; - respond to your inquiries;
- improve the services you receive from us;
- solicit your feedback;
- prevent you from having to re-enter personal information about you on future visits to our
websites or subsequent use of our applications; - process your payments and purchases;
- operate, evaluate and improve our business (including developing new products and services;
enhancing and improving our services; managing our communications; performing data analytics;
and performing accounting, auditing and other internal functions); - provide technical support/ answer your questions via Zoom calls;
- detect and prevent fraud and other unauthorized activity and enforce our terms of use; and
- comply with applicable legal requirements, relevant industry standards and our policies.
We will only use your personal information for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with the
original purpose.
How Long We Keep Personal Information
At a minimum, we will keep personal information about you for as long as we have a relationship with
you, for example as long as you are a customer (and for a reasonable period thereafter). When
determining how long to retain personal information after we no longer have a relationship with you,
we take into account how long our customers usually want to continue hearing from us, our legal and
regulatory obligations, the expectations of regulators, as well as the length of time information is
needed for internal audit purposes and to exercise or defend our legal rights.
- Retention in case of queries – We may retain your personal information for a
reasonable period in case of follow up queries from you. - Retention in case of claims – We may retain your personal information for the
period in which you might legally bring claims against us (this means we will retain it in line
with relevant limitation periods, which are applicable to your jurisdiction). - Retention in accordance with legal and regulatory requirements – We will
consider whether we need to retain your personal information after the period of retention in
the case of queries or claims because of a legal or regulatory requirement. - Retention permitted under applicable law – We will continue to retain personal
information where necessary to provide our services to you and the retention of such personal
information is necessary for the purposes of pursuing our legitimate interests or where it is
necessary for public interest purposes.
We review our retention periods for Personal Information on a regular basis, and all data is retained
in compliance with applicable data protection law. We will only permanently retain certain basic
Personal Information, for limited purposes. This is in relation to retaining basic contact details,
to keep a record that you were a customer, in case you return in future, or where you have asked us
not to contact you again.
Your Rights
Subject to our regulatory and legal obligations, you may be entitled to certain rights, which can
include:
- Where our use of your personal information requires consent, you may withdraw this consent at
any time; - You may request access to your personal information we hold about you and obtain information
about how we process it. Depending on the applicable privacy laws, you may be entitled to
request the categories and specific pieces of personal information that we have collected about
you, the categories of sources from which the personal information was collected, the purposes
of collecting the personal information, the categories of third parties we have shared the
personal information with, and the categories of personal information that have been shared with
third parties for a business purpose; - You may update, correct or amend the personal information we hold about you if it is wrong;
- You may ask us to change, restrict or stop the way in which we communicate with you or process
personal information about you; - You may ask us to delete your personal information;
- You have rights in relation to automated decision making, including profiling which has a legal
effect, or which causes a significant effect; - You may ask us to move, copy or transfer your personal information;
- You may object to our processing of your personal information; and
- You may opt out of the sale of personal information—however, for purposes of California law, we
do not sell your personal information to third parties, nor do we intend to, as those terms are
defined by California privacy law. In addition, we have contracts with our service providers to
prohibit any sale of the personal information we provide them; but if you have any concerns that
our third parties might be selling your information, please contact us.