GLOBAL PRIVACY NOTICE
Autonomy Capital (“Autonomy”) collects nonpublic personal information (“NPI”) from current, former and prospective Clients primarily to process requests and transactions, provide customer service, and communicate information about advisory products and services. Autonomy respects the privacy of its Clients and will not use or disclose NPI for any purpose other than in connection with the servicing of Clients accounts and as required or authorized by law.
The NPI that Autonomy collects about investors includes:
– information Autonomy receives from an investor on managed account agreements, fund subscription documents and related forms or through its website, such as name, address, Social Security number, birth date, assets, income, and investment experience; and
– information about an investor’s transactions with Autonomy, its affiliates, or others, such as account activity and balances.
Clients should note that this privacy notice does not prevent Autonomy from disclosing to appropriate third parties such information that Autonomy or the third party may, in its sole discretion, deem necessary or advisable in order to comply with applicable anti-money laundering and other applicable United States or foreign laws and regulations or as may be required by regulatory authorities with jurisdiction over Autonomy’s activities.
Autonomy restricts access to NPI that Autonomy collects about a Client to its personnel who need to know that information in order to provide products or services to the investor and to administer the firm as referenced above. Autonomy maintains physical, electronic and procedural controls in accordance with regulations of the Securities and Exchange Commission and other pertinent regulatory bodies, to safeguard NPI.
Autonomy will not market to any consumer based on any “eligibility information” about such consumer received from its affiliates, or share with any affiliate for marketing purposes any investor’s “eligibility information”, unless such consumer or investor has (i) received notice of the potential marketing use of such information; (ii) been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitation; and (iii) has not opted out.
If you have questions or concerns about our use of the data and information you provide, please contact Autonomy at email@example.com.
Autonomy Capital – Privacy Notice for Investors in Europe and/or Jersey
This notice sets forth the privacy practices of Autonomy Capital its affiliates (collectively, “Autonomy”) with respect to the personal data of investors (each, an “Investor”) (i.e. information which directly or indirectly identifies Investors) in the funds for which Autonomy serves as investment adviser or general partner or in some similar capacity. This Data Privacy Notice only applies to Investors in the European Economic Area (“EEA“) and/or Jersey. For the purposes of applicable data protection laws, Autonomy is the data controller. For EEA investors, in the event of any conflict between this Privacy Notice and Autonomy’s general Privacy Notice, this Privacy Notice shall prevail.
Data That May Be Collected. Autonomy may collect certain personal data with respect to Investors, including, without limitation, (a) information received from an Investor, such as social security number, tax identification number, account information and wire transfer instructions and (b) information about an Investor’s transactions with any affiliates of Autonomy or non-affiliated third parties, such as account balances, account numbers and account activity. Autonomy may obtain such personal data when the Investor makes an investment in an Autonomy fund, provides information on the Investor’s subscription documents and related forms, gives contact information, makes a wire transfer, provides government-issued ID, makes an additional contribution to an Autonomy fund or requests a redemption.
Use of Investor Personal data. Autonomy will use Investors’ personal data in the course of business for tasks such as, processing transactions, maintaining investor accounts and responding to court orders and legal investigations. Autonomy may also use Investors’ personal data to communicate with Investors and offer products and services to Investors. The provision of personal data by an Investor may be necessary in order for Autonomy to provide the Investor with the requested services, for the performance of any contractual relationship with the Investor and for the other purposes as set out in this Notice where in Autonomy’s legitimate interests.
Disclosure to Certain Third Parties. Autonomy may disclose certain personal data: (i) to its affiliates, service providers, such as transfer agents, fund administrators, custodians, broker-dealers, accountants and lawyers; (ii) to fraud prevention agencies and law enforcement agencies; (iii) to courts, governmental and non-governmental regulators and ombudsmen; (iv) to any third party that acquires, or is interested in acquiring or securitizing, all or part of Autonomy’s assets or shares, or that succeeds Autonomy in carrying on all or a part of its business, whether by merger, acquisition, reorganization or otherwise; or (v) as required or permitted by law, including to comply with a subpoena or similar legal process or government request, or when Autonomy believes in good faith that disclosure is legally required or Autonomy has a legitimate interest in making a disclosure, such as where necessary to protect Autonomy’s rights and property.
Transfer of Personal Data Outside Europe and/or Jersey. Autonomy may disclose Investor’s personal data to recipients (including affiliates) located in countries outside of Europe and/or Jersey, including in the U.S., which may not have data privacy laws equivalent to those in Europe and/or Jersey (as applicable). In such a case, Autonomy will take all necessary steps to ensure the safety of Investors’ personal data in accordance with applicable data protection laws.
Rights of Investors. Under applicable EU data protection laws, Investors may have a right to: (i) request access to and rectification or erasure of their personal data; (ii) obtain restriction of processing or to object to processing of their personal data; and (iii) the right to data portability. Investors also have the right to lodge a complaint about the processing of their personal data with their local data protection authority.
Security. Autonomy will take steps to protect Investors’ personal data against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification, regardless of the format in which it is held. All Investor personal data will be retained in accordance with Autonomy’s record-keeping policies and procedures.
Inquiries, Requests or Concerns. All inquiries, requests or concerns regarding this Notice or relating to the processing of Investor personal data including all requests as detailed in the Rights of Investors Section above, should be sent to firstname.lastname@example.org