We obtain certain personal information (such as name and other contact details) directly from you when you fill in forms relating to your involvement in a fund or dealership, send us an email, or otherwise communicate with us. The types of personal information we may obtain include:
Unless we explain otherwise at the time, providing personal information that we request is optional and any disclosures are made voluntarily.
We may also obtain some limited information about you indirectly, for example when your colleagues give us your contact details and information about your role, or from publicly available sources such as the internet and/or subscription based services.
We may use the information described above to:
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
In some countries, we need to identify the legal basis upon which we process your personal information. In general, we can process your personal information lawfully because we have a legitimate interest in doing so, to pursue the purposes that we have set out above. We may also need to process your personal information in order to perform our legal obligations.
We also may disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or other corporate event).
The disclosures of personal information referred to above include transfers of personal information which is subject to UK or European Union data protection laws to countries outside the UK, EU, the Cayman Islands Data Protection Law, California Consumer Protection Privacy (“CCAP”) and various other worldwide privacy regulations. CLNY is an international group of companies, headquartered in the U.S., and it has funds, affiliates and service providers, and relationships with counterparties and governmental authorities, all over the world. This includes transfers to countries, such as the U.S., which are not regarded by the European Commission as ensuring an adequate level of data protection. Where we transfer personal information subject to UK or European Union data protection laws to our service providers, other organizations involved in the management of the relevant fund or affiliated companies in those countries, we do so on the basis of data transfer agreements designed to protect the privacy of your information, in forms approved for this purpose by the European Commission.
The period for which we will keep your personal information varies depending on the information and how we obtained it. Personal information will not be held for longer that it is needed, given the purposes for which it is held. Further information regarding our record-keeping policies is available upon request.
We take all reasonable precautions in accordance with applicable law, including implementing administrative, technical and physical safeguards, to protect your personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
1700 Kraft Drive, Suite 2000
Blacksburg, VA 24060
Telephone: +1 203-927-5750