At Private Advisors, LLC (“PA”) maintaining our customers’ trust and confidence is of paramount importance. We are committed to safeguarding your personal information and providing you with facts and options about how this information may be shared. Please read this notice to learn more about our privacy policies and the options available to you.
Information That We Collect. As part of providing you with our services, we obtain nonpublic personal information about you, which may include the following:
Information That We Share & Why It Is Important. We use or share information in a limited and carefully controlled manner. We do not disclose any nonpublic information about our customers or former customers to anyone, except as permitted by law, unless authorized by you. Instances in which we may share your information with nonaffiliated third parties include:
(NOTE: The Representative Client List includes language stating that the names on the list are not to be construed as an endorsement or recommendation of PA’s services.)
Collection of Information
In general, you can browse the non-password-protected sections of the Website 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 Website or not), to which URL you next go (whether this URL is on the Website or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services.
If you apply for a password to access password-restricted areas on this Website, you must provide to us your name, mailing address, email address, phone number, personal financial data, investment portfolio and other investment information.
Use and Disclosure of Information
The security of your account information is important to us. Only those persons who need your information to perform their job have access to it. In addition, we maintain physical, electronic and procedural security measures that comply with federal regulations to protect your information. Our employees have limited access to your personal information based upon their responsibilities. All employees are instructed to protect the confidentiality of your personal information as described in these policies, which are strictly enforced.
You agree that we may use personal information about you to analyze Website usage, improve our content and product offerings and customize the Website's content, layout, and services. These uses improve the Website and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Website.
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.
If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties (through our Representative Client List), you may “opt out” of those disclosures. This means that you may direct us not to include your name on our Representative Client List (other than disclosures permitted by law). If you wish to opt out of disclosures to nonaffiliated third parties, you may call our Chief Compliance Officer at PA’s main number: (804) 289-6000. You may exercise this right to opt out at any time.
Control of Your Password and Personal Information
You are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your user name or password to access or use any part of this Website. If your password has been compromised for any reason, you should contact us immediately for a new password.
You can review and change the information that you submit to us by contacting us at firstname.lastname@example.org. You can change your User ID, email address, contact information, financial information, other personal information and user preferences. You must promptly update your personal information if it changes or is inaccurate.
On your request, we will deactivate your password and remove your contact information and financial information from our active databases. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy.
Your information is stored on our servers located in the United States. 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. However, "perfect security" does not exist on the Internet.
Persons under age 18 are not eligible to use the Website.
Conditions Of Use
Changes to this policy
If you have any questions about this Privacy Notice, you may call us at (804) 289-6000.
Private Advisors LLC
Cayman Islands Privacy Notice
Private Advisors and its subsidiaries (referred to collectively as Private Advisors or “we” or “our”) are committed to respecting the privacy of all individuals.
This Privacy Notice (“Notice”), our website notice, your subscription agreement, and any other agreements between you and us, set out the basis by which Private Advisors processes personal data with respect to the private investment funds we manage domiciled in the Cayman Islands. Please read the following carefully to understand our views and practices regarding how we handle personal data.
For purposes of applicable data protection law (in particular, the Cayman Islands Data Protection Law, 2017 (Law 33 of 2017) (the “DPL”)), Private Advisors is the “data controller” of your personal data.
Personal Data We collect
We collect and process the following personal data:
- Information you give us:
- Information we receive from other sources:
Purposes and Legal Basis
We will ask you for consent to collect or process your personal data on certain occasions, for example, and as stated below, where necessary in order to contact you with information about products and services that might be of interest to you.
We also process your personal data when we need to do this to fulfil a contract with you, such as to give effect to your investment in a Private Advisors fund or separately managed account (including verifying your identity), or when required by law, such as if we receive a request from law enforcement or other government officials.
We also process your personal data when it is in our legitimate interest to do this and when this interest is not overridden by your data protection rights. In particular:
- we will use your personal data to provide services to you, and to respond to any comments or requests you may send us;
- we monitor use of our website, and use your personal data to help us monitor, improve and protect our services and website, both online and offline;
- we monitor investor accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and regulation; and
- we will use personal data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
For example, we have a legitimate interest in the effective administration of the Private Advisors funds and separate accounts we manage and our business, and in ensuring the security and integrity of our website.
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Notice.
Disclosure of Your Personal Data
We may share your personal data with our subsidiaries and/or affiliates:
- to administer and service private investment funds in which you are invested; and
- to the following individuals employed by such subsidiaries and affiliates on a need to know basis, including without limitation, their respective attorneys, compliance professionals, human resources personnel, internal auditors, accountants, and members of senior management.
We will also share your personal data with trusted third parties including:
- Banks and other financial institutions which, for example, act as administrators, trustees, brokers or custodians on behalf of the Private Advisors funds and separate accounts we manage;
- Firms conducting Anti-Money Laundering, “Know Your Customer” and FATCA tax review with respect to Private Advisors’ onboarding of new investors with respect to its funds and separate accounts we manage;
- Legal, accounting, and other advisers, consultants and professional experts, correspondents, and suppliers and service providers of any of the above, and each of their associated businesses;
- Business partners, suppliers and sub-contractors only for the purposes of performance of any contract we enter into with them or you. We take reasonable steps to ensure that our staff protect your personal data, and are aware of their information security obligations;
- Placement agents and introducers; and
- Analytics and search engine providers that assist us in the improvement and optimization of our site.
We may disclose your personal data to third parties:
- If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If Private Advisors, its business, or its assets are acquired by a third party, in which case personal data held by it about its users, suppliers, or customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions (Legal) and other agreements; or if we reasonably consider this necessary; or to protect the rights, property, or safety of Private Advisors, our users, our customers, or others; and
- For the purposes of crime prevention and fraud protection.
We, or trusted third parties on our behalf, may contact you by email or post with information about products and services that might be of interest to you. Where necessary, at the time that you provide your personal data to us, you will be given the opportunity to indicate whether or not you are happy for us to use your personal data in order to tell you about such products or services.
Where We Store Your Personal Data and How We Protect it
Some of the Private Advisors subsidiaries and/ or affiliates and third parties to whom Private Advisors discloses your personal data (as described above) are located in countries outside the EU that do not provide a level of protection to personal data equivalent to that provided by your home country.
The DPL permits the transfer of personal data to countries that have not be recognized as providing adequate protection where such transfer is necessary for the performance of a contract between the data subject and data controller. Because we are located in the United States of America, such transfers are necessary for you to invest in our products.
While we take reasonable steps to protect your personal data from loss or destruction, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
You have various rights with respect to our use of your personal data:
- Access: You have the right to request a copy of the personal data that we hold about you. Please note that there are exceptions to this right, so that access will be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.
- Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
- Objecting: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us using the contact details provided below.
- Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint to the applicable supervisory authority or to seek a remedy through the courts.
Please note that there are exceptions to these rights, if, for example, we are under a legal obligation to continue to process your personal data.
When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.
How Long We Keep Your Personal Data
We will retain your personal data, whether or not your account is active, for as long as we believe it necessary or desirable to fulfil our business purposes and to comply with applicable law and regulation, audit requirements, regulatory requests or orders from competent courts.
Personal Data collected will be retained pursuant to our record retention policy, and in most instances will not be retained longer than nine (9) years from the date you cease to be an investor in a Private Advisors fund or a separately managed account.
Changes to our Privacy Notice
Any changes we make to our Privacy Notice in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Notice.
Questions, comments and requests regarding this Notice are welcomed and should be addressed to email@example.com.
California Consumer Protection Act
Click here to learn about our practices regarding the collection, use and disclosure of personal information about California residents who are covered by the California Consumer Privacy Act, and how covered individuals can exercise their rights.