Privacy Policy

Last Updated: May 02, 2024.

At GoldenTree ONE (hereinafter referred to as “the Fund”), we recognize the importance of protecting the privacy of our investors, clients, and website users. This Privacy Policy outlines how we collect, use, disclose, and safeguard personal information, in compliance with applicable privacy laws and regulations, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and relevant U.S. federal and state laws.

By accessing our website or engaging with our services, you consent to the terms of this Privacy Policy and our practices regarding the collection and use of your personal information.

1. Information We Collect

To provide our services effectively and in compliance with regulatory requirements, we collect various types of personal and non-personal information from clients, investors, and visitors to our website. This information may be collected directly from you, through automated means, or from third-party sources. Below is a detailed overview of the types of information we may collect.

1.1. Personal Information

“Personal Information” refers to data that identifies, relates to, or is capable of being associated with a specific individual. The types of personal information we may collect include but are not limited to:

Contact Information: This includes your name, email address, phone number, physical address, mailing address, and any other information needed to communicate with you.
Identity Verification Information: This may include government-issued identification numbers (such as a Social Security Number, Taxpayer Identification Number, passport number, or driver’s license number), date of birth, nationality, and copies of identification documents.
Financial Information: To assess your eligibility as an investor and to manage your account, we may collect information such as your bank account details, income, net worth, investment history, and other financial details required for determining your suitability to invest in the Fund. This may also include your tax residency status and any tax-related documents required by applicable law (e.g., W-9 or W-8 forms).
Employment and Professional Information: This includes your job title, current and former employers, professional qualifications, and any other information related to your professional background that may be relevant for regulatory or due diligence purposes.
Investment Experience and Objectives: We may collect details regarding your prior investment experience, including your investment risk appetite, objectives, and preferences, to tailor our services and ensure compliance with applicable suitability requirements.
Communication Preferences: Information related to your preferences for receiving updates, reports, and marketing communications, including details of any opt-in or opt-out preferences.
Transaction and Account Information: This includes your investment holdings, transaction history, subscription details, redemption information, and other details related to your interactions with the Fund.
Legal and Compliance Information: This may include any information required to comply with Anti-Money Laundering (AML) laws, Know Your Customer (KYC) regulations, the Foreign Account Tax Compliance Act (FATCA), and other legal or regulatory obligations. This may also include details about any potential conflicts of interest, related party disclosures, or other legal or regulatory information.

1.2. Non-Personal Information

“Non-Personal Information” refers to data that cannot, by itself, be used to identify a specific individual. We may collect such information to enhance user experience, improve our website, and monitor the performance of our services. The non-personal information we collect may include:

Device Information: This includes data about the device you use to access our website, such as your IP address, browser type, operating system, hardware model, and mobile network information. This information helps us ensure that our website functions properly across different platforms and devices.
Usage Data: We automatically collect information about your interactions with our website, such as pages viewed, links clicked, time spent on the site, and the referring website from which you arrived. This data helps us understand user behavior, improve navigation, and enhance the overall user experience.
Cookies and Similar Technologies: We use cookies, web beacons, and other tracking technologies to collect information about how you use our website and to remember your preferences for future visits. Cookies may store non-personal information such as your browser type, operating system, and session data. For more information on our use of cookies, please refer to our relevant Cookies section(s) below.

Cookies are small text files stored on your device by your browser. They allow us to identify repeat visitors and offer personalized experiences based on previous interactions with our website. You can choose to accept or decline cookies through your browser settings, but please note that declining cookies may impact the functionality of our website.

Geolocation Data: If you access our website through a mobile device or a web browser with geolocation services enabled, we may collect location information (such as your IP address or GPS data) to customize content and improve the quality of our services. You can disable location services through your device settings at any time.
Aggregated Data: We may collect and aggregate data about your use of the website or our services, such as overall traffic patterns and usage statistics, in a way that does not personally identify you. This aggregated data is used to evaluate the performance of our services and website.

1.3. Information Collected from Third Parties

In some instances, we may receive personal information about you from third-party sources, including but not limited to:

Financial Institutions and Brokers: We may receive information from your bank, broker-dealer, or other financial institutions to verify your account, facilitate transactions, and maintain compliance with applicable financial regulations.
Third-Party Due Diligence Providers: As part of our commitment to complying with KYC, AML, and other regulatory requirements, we may engage third-party service providers to conduct background checks and verify information related to your identity, financial status, and legal history. These providers may collect information from public records, government databases, or credit reporting agencies.
Marketing and Advertising Partners: We may receive information from marketing and advertising partners about your interactions with their services, particularly if you clicked on an advertisement or link that led you to our website.
Publicly Available Sources: We may collect information from publicly available sources such as social media profiles, websites, and publicly accessible databases. This information may be used to enhance our understanding of your investment background and preferences or to verify information you have provided.

1.4. Sensitive Personal Information

In certain limited circumstances, we may collect “sensitive personal information,” which includes data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic or biometric data, or information concerning health or sexual orientation. However, we only collect such information when it is directly relevant to our services and in strict compliance with applicable laws. For example, we may collect sensitive personal information to fulfill specific legal requirements for tax reporting or identity verification purposes. We will always obtain your explicit consent before collecting sensitive personal information, where required by law.

1.5. Minors' Personal Information

Our services are not intended for individuals under the age of 18. We do not knowingly collect or solicit personal information from minors. If we become aware that we have inadvertently collected personal information from a minor, we will take steps to delete such information as soon as possible. If you believe that we may have collected personal information from a minor, please contact us immediately.

1.6. Legal Basis for Collecting Personal Information

We may collect and process your personal information based on one or more of the following legal grounds:

Consent: Where you have provided your explicit consent for the processing of your personal information, particularly when it involves sensitive data or marketing communications.
Contractual Necessity: When the processing of your information is necessary to perform the contract or agreement you have entered into with us, such as for managing your investments or providing updates on your account.
Legal Compliance: We may be required by law to collect and process certain personal information to fulfill our legal obligations, such as complying with KYC, AML, or tax regulations.
Legitimate Interests: We may process your personal information to pursue our legitimate business interests, such as improving our services, managing risks, or preventing fraud, provided such interests are not overridden by your privacy rights.

2. How We Collect Information

At the Fund, we collect personal and non-personal information through a variety of methods. These methods are designed to ensure that we obtain accurate and up-to-date information necessary for providing our services, complying with legal and regulatory requirements, and improving the user experience on our website. Below is a detailed breakdown of how we collect information.

2.1. Information You Provide Directly

We may collect personal information directly from you when you voluntarily provide it to us in various contexts, including but not limited to:

Account Registration and Subscription Forms: When you express interest in investing with the Fund, you may be required to provide personal and financial information through account registration forms or subscription agreements. This includes your contact details, financial information, and legal documentation required to assess your eligibility and suitability as an investor.
Correspondence and Communication: We collect personal information when you communicate with us via email, phone, or written correspondence. This includes any questions, requests for information, or feedback you provide. For instance, when you contact our support team or send inquiries regarding our services, we may collect information such as your name, contact details, and the content of your communication to respond effectively to your request.
Meetings and Events: When you attend meetings, webinars, or in-person events organized by the Fund, we may collect information such as your name, job title, contact details, and any other information you voluntarily provide during such interactions.
Surveys and Feedback: Periodically, we may send surveys to investors and clients to gather feedback on our services or to assess satisfaction. Participation in these surveys is voluntary, but if you choose to respond, we will collect the information you provide, which may include opinions, preferences, and additional personal details.
Application and Due Diligence Processes: When applying to invest in the Fund, you may be required to provide detailed personal and financial information as part of our due diligence and know-your-customer (KYC) processes. This information is collected to verify your identity, assess your financial status, and ensure compliance with applicable legal and regulatory standards. We may request supporting documentation such as tax forms, identification documents, and proof of financial assets as part of this process.

2.2. Information Collected Automatically

In addition to information you provide directly, we may also collect certain information automatically when you visit our website or engage with our online services. This type of information helps us understand how users interact with our website and allows us to improve its functionality and security. Automated data collection methods include:

Cookies: We use cookies, which are small text files placed on your device, to collect information about your browsing activity. Cookies allow us to remember your preferences, track your use of our website, and provide you with a more personalized experience. Cookies can also help us track session data, such as login status, and ensure the security of your interactions with our website. You can choose to accept or reject cookies via your browser settings, but rejecting cookies may limit certain functionalities of our website. For more information, please refer to our relevant Cookies section(s).
Web Beacons and Tracking Pixels: Web beacons, also known as tracking pixels, are small graphic images embedded in web pages or emails that allow us to monitor user activity. These tools help us track website traffic, the effectiveness of our email campaigns, and user engagement with content. For example, if you click on a link in one of our emails, a tracking pixel may record that activity so we can assess the effectiveness of the communication.
Log Files: Our servers automatically collect information known as log files when you access our website. These files include details such as your IP address, browser type, operating system, pages viewed, and timestamps of your visit. Log files are used for monitoring website performance, troubleshooting issues, and enhancing security. This data also helps us analyze user trends and improve the overall functionality of our website.
Analytics Tools: We may use third-party analytics tools such as Google Analytics or similar technologies to collect information about user behavior on our website. These tools track and report user interactions, such as pages visited, time spent on the site, and referral sources. The data collected through these tools is aggregated and anonymized to provide insights into how our website is used and to guide decisions on improving user experience.
Device Information: When you access our website or use our services, we automatically collect information about the device you are using, including your IP address, browser type, operating system, and device identifier. This information helps us optimize the website for different devices and ensures that our security measures function properly across platforms.
Geolocation Data: If your device's location services are enabled, we may collect geolocation data from your device when you interact with our website. This data helps us tailor content and services to your location. You can disable location services at any time through your device settings.

2.3. Information Collected from Third-Party Sources

In certain cases, we may obtain information about you from third-party sources. This information may supplement the data you provide directly or the data we collect automatically. These third-party sources include:

Financial Institutions and Brokers: We may receive information about you from financial institutions, brokers, or intermediaries who assist with the facilitation of your investment in the Fund. This can include account information, financial status, and transaction history that help us manage your investment and comply with legal obligations.
Service Providers: We work with third-party service providers to conduct certain business functions, such as performing background checks, verifying your identity, and providing compliance services. These service providers may provide us with information such as credit scores, criminal records, or information derived from public records to help us fulfill our legal and regulatory obligations, such as Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements.
Regulatory and Government Agencies: In some cases, we may receive personal information from regulatory bodies, law enforcement agencies, or government entities in the course of fulfilling our legal obligations. For example, if we are required to conduct reporting under the Foreign Account Tax Compliance Act (FATCA), we may collect information related to your tax status from relevant authorities.
Publicly Available Sources: We may also collect information from publicly accessible sources, including social media platforms, news articles, public databases, and online directories. This information may be used for research, due diligence, and verification purposes. For example, we may check publicly available information to confirm the details you provide or assess your qualifications for investing in the Fund.
Marketing Partners and Advertising Networks: We may receive information from marketing partners and advertising networks that help us promote our services and attract new investors. This may include data about your interactions with advertisements, your browsing activity on partner websites, or demographic information that helps us tailor our marketing strategies.
Referral Programs: If you were referred to the Fund by another investor or partner, we may collect information about the referral source, as well as any personal information shared by the referrer as part of the referral process. This could include your contact details and any communications made in connection with the referral.

2.4. Social Media Platforms and Interactions

We may collect personal information when you engage with our content on social media platforms or interact with us through social media accounts. This information may include your username, profile picture, the content of your interactions, and any additional information that you make publicly available on those platforms. Social media platforms may also share data with us in accordance with their own privacy policies, and we encourage you to review their privacy settings to control the information you share.

For example, if you follow our social media pages or comment on our posts, we may use that information to engage with you and provide updates about the Fund’s activities. We may also use aggregated social media analytics to assess the effectiveness of our social media campaigns.

2.5. Information Collected Through Third-Party Links and Integrations

Our website may contain links to third-party websites, services, or applications that are not owned or controlled by the Fund. If you interact with these third-party sites, they may collect information about you independently of us, and their privacy practices may differ from ours. We are not responsible for the privacy practices of these third parties, and we encourage you to review their privacy policies before providing any personal information.

Similarly, if you use third-party services (e.g., payment processors, financial portals) that integrate with our services, those providers may collect and share information with us as part of facilitating your use of their services. For example, if you use a third-party financial service to execute transactions or access your investment account, they may share transaction details or account information with us.

2.6. Consent for Data Collection

In certain jurisdictions, we may be required to obtain your explicit consent for the collection and use of personal information. When necessary, we will seek your consent before collecting sensitive information or before engaging in certain types of processing activities, such as using cookies for marketing purposes. You may withdraw your consent at any time by contacting us directly or by changing your preferences in your account settings or browser.

3. Use of Information

At the Fund, we may use the personal and non-personal information we collect for a wide range of purposes, all aimed at facilitating our business operations, providing you with exceptional service, complying with legal and regulatory obligations, and improving your experience with the Fund. Below is a detailed breakdown of the various ways in which we may use the information we collect.

3.1. To Provide and Manage Our Services

We may use the information you provide and the information we collect to:

Administer and Manage Your Account: When you invest in the Fund, we use your personal information to establish and maintain your investment account. This includes processing account registration, managing your portfolio, providing investment statements, and addressing any inquiries you may have regarding your account.
Facilitate Investment Transactions: We use your financial and personal information to facilitate investment transactions and related activities. This includes processing subscription agreements, verifying your identity, conducting due diligence, and ensuring compliance with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations.
Execute Investment Strategies: Information about your investment profile, risk tolerance, and financial goals helps us to execute the Fund's systematic macro trading strategies on your behalf. We use this information to ensure that your investments align with your objectives, and to make decisions regarding the allocation of capital across global currency and commodities markets.
Customer Support and Communication: We use your contact information to communicate with you regarding your account, provide customer support, and respond to any questions or concerns you may have. This includes sending you important notices, such as changes to your account, updates on fund performance, or changes to our policies or investment strategies.
Provide Access to the Website and Online Portal: Your information is used to authenticate your identity and manage your access to our website and online investor portal. This ensures that only authorized users can access sensitive information related to your account and investment performance.

3.2. To Improve Our Services and Offerings

We strive to continuously improve the quality of the services we offer, and to that end, we may use your information for the following purposes:

Data Analytics and Research: We use both personal and non-personal information to conduct data analysis and research to improve the performance and efficiency of our AI/ML models and trading strategies. By analyzing aggregated data, we refine our trading algorithms, identify new investment opportunities, and enhance our overall service offering. The information we use for analytics is often anonymized or aggregated to protect your identity and privacy.
Personalization: Your preferences, browsing history, and past interactions with the website are used to personalize your experience, ensuring that the information and resources you see are relevant to your interests. For example, we may provide customized content based on your investment preferences, location, or interactions with our website.
Website and Service Optimization: We use collected information, such as browsing patterns, device information, and user feedback, to optimize the functionality, security, and performance of our website and online services. This includes troubleshooting issues, improving user experience, and developing new features to enhance the value of the Fund’s online presence.
Surveys and Feedback: We may use your feedback from surveys and other forms of communication to improve our services and customer support. Your input helps us identify areas for improvement and enables us to tailor our services to meet the evolving needs of our investors.

3.3. For Marketing and Communication Purposes

We may use your information to engage with you for marketing and communication purposes, subject to applicable regulations and your preferences:

Direct Marketing: With your consent (where required by law), we may use your contact information to send you marketing materials, newsletters, or updates regarding the Fund’s services, products, or new investment opportunities. These communications may include insights into market trends, updates on our AI/ML-driven trading strategies, or information on new funds or financial products offered by the Fund.
Event Invitations: We may use your contact details to invite you to webinars, investor meetings, educational events, or other gatherings that may be of interest to you based on your investment profile or preferences. These events are designed to provide valuable information about the markets, investment strategies, or the performance of our AI/ML models.
Tailored Advertising: Based on your browsing behavior, interactions with our website, and engagement with our services, we may use third-party advertising platforms to display tailored advertisements related to our hedge fund or other financial services. These platforms may use cookies or similar technologies to target relevant ads to you across various online channels. You can control your preferences for receiving these ads through your browser settings or opt-out mechanisms provided by the third-party platforms.
Referral Programs: If we offer referral programs, we may use your information to track participation and reward successful referrals in accordance with the terms of the program. For example, if you refer another investor to the Fund, we may use your information to verify the referral and communicate with you regarding the status of the referral.

3.4. Compliance with Legal and Regulatory Obligations

As a regulated entity, the Fund is required to collect and use certain information to comply with applicable laws and regulations. Specifically, we use your information for the following compliance purposes:

Know Your Customer (KYC) and Anti-Money Laundering (AML): We use your personal information, including identification documents and financial details, to conduct due diligence, verify your identity, and ensure compliance with KYC and AML requirements. This includes cross-referencing your information with government databases or other third-party verification services.
Tax Reporting and Withholding: We collect and use your tax-related information to comply with various tax reporting and withholding obligations, including requirements under the Foreign Account Tax Compliance Act (FATCA), the Common Reporting Standard (CRS), and other tax laws applicable to your jurisdiction.
Regulatory Reporting: We may be required to share your personal information with regulatory authorities, government agencies, or other competent bodies to comply with reporting obligations under financial services laws. This includes submitting reports related to the Fund’s performance, investor activities, and any potential violations of law.
Legal Proceedings and Dispute Resolution: In the event of legal disputes or claims involving the Fund, we may use your personal information as necessary to defend against legal actions, respond to subpoenas or court orders, or enforce our legal rights. We may also share your information with external legal advisors or insurance providers in connection with such proceedings.

3.5. Risk Management and Fraud Prevention

To safeguard the interests of both the Fund and its investors, we may use your information to manage risk, detect fraud, and protect against security threats:

Risk Profiling: We use personal and financial data to assess your investment risk profile, ensuring that our trading strategies align with your risk tolerance and investment goals. This helps us mitigate potential losses and enhance portfolio performance.
Fraud Detection: We use automated tools and analytics to detect suspicious activities, prevent fraud, and protect your personal information. This includes monitoring account activity for unusual patterns, conducting identity verification, and employing security measures to guard against unauthorized access to your account.
Security Monitoring: To ensure the safety and integrity of our systems, we use technical data (e.g., IP addresses, log files, browser information) to monitor for security threats, such as hacking attempts, data breaches, or unauthorized access. We employ encryption, firewalls, and other security technologies to protect your personal data and the operations of the Fund.

3.6. Internal Business Purposes

We may also use collected information for general internal business purposes, which may include:

Record-Keeping and Administration: We maintain records of investor information, account details, transaction history, and communications to fulfill administrative functions, comply with legal obligations, and improve operational efficiency.
Audit and Compliance: We may use your information to conduct internal audits, ensure compliance with internal policies, and assess the Fund’s overall operational and financial health. This process helps us maintain regulatory compliance and supports transparency in our dealings with investors and stakeholders.
Business Planning and Development: We use aggregated data to inform business decisions and develop new strategies, services, or products that align with market demands and investor needs. This may include exploring new AI/ML trading models, launching new funds, or expanding our presence in specific market sectors.

3.7. Sharing Information with Third Parties

We may use your information to collaborate with third-party service providers and partners who assist in delivering our services. We ensure that these third parties follow strict privacy standards and only process your data as necessary for the specific purpose outlined. Information is shared with third parties for the following purposes:

Service Providers: We may share information with third-party service providers who assist with account management, transaction processing, due diligence, compliance checks, and IT support. These service providers are contractually bound to protect your information and use it solely for the purpose of providing the services we have engaged them for.
Legal and Regulatory Authorities: As part of our regulatory obligations, we may share your information with government agencies, financial regulators, tax authorities, or law enforcement bodies, either voluntarily or in response to legal requests.
Business Partners: In certain cases, we may collaborate with business partners or affiliates who offer complementary services or products. If you engage with these partners, we may share relevant information necessary to facilitate the partnership and provide you with a seamless experience.

3.8. Other Uses with Consent

If we intend to use your information for purposes not covered by this Privacy Policy, we will seek your explicit consent before doing so. For example, if we want to use your data for a new marketing initiative, we will inform you of the details and provide you with the opportunity to opt in or out.

4. Sharing and Disclosure of Information

At the Fund, we are committed to safeguarding your privacy and ensuring that any personal information we collect is only shared in a manner consistent with applicable regulations and industry best practices. We may disclose your information only under specific circumstances and ensure that any third-party service providers adhere to strict confidentiality and security standards. Below is a detailed breakdown of how and when your information may be shared and disclosed.

4.1. Disclosure to Service Providers

In order to operate efficiently and deliver our services, we may share your personal and non-personal information with third-party service providers. These providers help us manage and maintain various operational and technical functions that are crucial to our business activities, including:

Administrative and Operational Support: We engage with service providers who help manage the day-to-day administrative functions of the Fund, such as account administration, fund accounting, and transaction processing. These providers may require access to your personal and financial information to perform these services, and they are contractually bound to use your data only for the purposes specified in our agreements with them.
Technology and IT Services: We work with technology partners who provide IT infrastructure, data storage, website hosting, cybersecurity, and technical support services. These providers may have access to information such as your IP address, device information, and website usage data in order to maintain the security and functionality of our systems.
Data Analytics and Marketing Services: We may engage with third-party analytics providers who help us analyze aggregate data related to our Fund’s performance, website traffic, and investor engagement. These service providers may use cookies, web beacons, or similar technologies to collect non-personal data that helps us enhance our services and customize our communications. Additionally, marketing service providers may assist us in delivering tailored advertisements or email campaigns, subject to your consent and preferences.
Legal, Compliance, and Auditing Services: We work with legal advisors, auditors, and compliance consultants to ensure that our operations meet regulatory standards. These providers may require access to certain personal and financial information as part of their auditing, legal, or regulatory review processes. Any information shared is handled under strict confidentiality agreements.

4.2. Disclosure to Regulatory Authorities

As a regulated financial institution, we are required to share certain personal and financial information with regulatory and governmental authorities. This is done in compliance with applicable laws, regulations, and industry standards. Specific circumstances under which we may disclose your information to regulators include:

Regulatory Reporting: We may be required to submit reports to regulatory agencies, such as the U.S. Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), or state-level authorities. These reports may contain investor-related information as part of our obligation to comply with financial industry regulations.
Know Your Customer (KYC) and Anti-Money Laundering (AML) Compliance: In compliance with KYC and AML regulations, we may be required to disclose certain identification and transaction-related information to government authorities, law enforcement agencies, or designated financial intelligence units. This helps prevent financial crimes such as money laundering, terrorist financing, and tax evasion.
Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS): We may disclose tax-related information, such as your name, address, account details, and investment income, to tax authorities to comply with FATCA and CRS obligations. This reporting helps ensure compliance with international tax transparency regulations.
Court Orders and Legal Proceedings: If required by law or in response to a valid legal request, such as a subpoena, court order, or search warrant, we may disclose your personal information to law enforcement agencies, courts, or other governmental bodies. This disclosure will only occur if we have a legal obligation to do so, and we will take reasonable steps to inform you when such disclosure is made unless prohibited by law.

4.3. Disclosure to Business Partners and Affiliates

In certain cases, we may share information with business partners and affiliates with whom we collaborate to offer complementary services or joint products. Any sharing of information in these instances is done with strict adherence to confidentiality agreements and is limited to the following scenarios:

Joint Offerings: We may collaborate with affiliated companies or business partners to offer additional financial services or products that complement our AI/ML systematic macro trading strategies. For example, if we partner with a firm offering advanced trading tools or new investment vehicles, we may share your contact information and investment preferences to introduce you to these opportunities. In such cases, you will be given the option to opt out of receiving information related to these joint offerings.
Affiliated Companies: If the Fund operates within a broader group of companies, we may share certain information with other affiliated entities for operational purposes, regulatory compliance, or to streamline services. This may include shared back-office functions, legal compliance, or investor support services. However, all affiliated companies will be required to protect your information in accordance with this Privacy Policy and applicable law.
Business Transactions: In the event of a merger, acquisition, or sale of the Fund or its assets, we may disclose personal information to the prospective buyer, investor, or successor entity. Any such transaction will be conducted in a manner that protects the confidentiality of your information, and we will provide you with notice of any changes in ownership or use of your personal information resulting from the transaction.

4.4. Disclosure for Fraud Prevention and Risk Management

We take the security of your personal and financial information seriously and may disclose such information to protect against fraud, security threats, and unauthorized access:

Fraud Detection and Prevention: We may share personal information with third-party fraud detection and prevention services, as well as with financial institutions or payment processors, in order to detect, prevent, or mitigate fraudulent activity. For example, if suspicious activity is detected in your account, we may share relevant information with fraud prevention services to verify your identity or freeze your account.
Risk Management and Compliance: In order to manage and mitigate risk, we may disclose information to third-party risk management service providers or auditors who help assess and monitor potential risks to the Fund. This may include the use of specialized data analytics services to ensure that the Fund’s strategies comply with regulatory risk tolerance thresholds and investor risk profiles.
Insurance and Legal Defenses: We may share personal information with our insurance providers or legal advisors in the event of litigation, claims, or disputes involving the Fund. This is necessary to protect our legal rights, defend against potential liabilities, and ensure that any claims are properly managed.

4.5. Disclosure to Investors and Advisors

As part of normal business operations, we may disclose non-personal and aggregated information to investors, advisors, or partners in the context of managing and reporting on the Fund’s performance:

Performance Reporting: We may share aggregated data related to the Fund’s performance, trading strategies, and market activities with existing or prospective investors. This may include general information about the composition of the portfolio, asset allocations, or the returns generated by the Fund. However, such reporting will not disclose personal information that can identify any individual investor.
Advisors and Consultants: We may disclose information to financial advisors, investment consultants, or legal professionals who are advising the Fund on its operations or strategy. Such disclosures are made on a need-to-know basis and are subject to confidentiality agreements designed to protect the privacy of your personal information.
Annual and Quarterly Reports: We may publish annual and quarterly reports that disclose certain information about the Fund’s activities, performance, and investment strategies. These reports are typically shared with investors and may include information such as aggregated financial performance data, market commentary, or the results of our AI/ML trading models.

4.6. Disclosure Based on Your Consent

In certain cases, we may disclose your information with your explicit consent:

Third-Party Services: If you choose to engage with third-party services, platforms, or tools through our website or investor portal, we may share relevant information with those third parties based on your consent. For example, if you sign up for a third-party research tool, we may provide your contact details or account information as needed to facilitate your use of the service.
Investor Referrals: If you refer other investors to the Fund or participate in referral programs, we may disclose your information for the purpose of verifying referrals or tracking program participation. These disclosures will only occur if you have consented to participate in the program.

4.7. International Data Transfers

If you are located outside of the United States, please note that the Fund may transfer, process, and store your personal information in the United States or other jurisdictions. As part of these international data transfers, we ensure that your personal information is protected in accordance with applicable data protection laws and regulatory frameworks. In cases where we transfer personal information to countries outside of your jurisdiction, we implement appropriate safeguards, such as data processing agreements, to protect your privacy and rights.

4.8. Data Retention and Deletion

We retain personal information for as long as it is necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Once your information is no longer needed for these purposes, we take steps to securely delete or anonymize the data in accordance with applicable data retention policies and legal requirements.

5. Data Retention

At the Fund, we are committed to retaining personal information only for as long as it is necessary to fulfill the purposes for which it was collected, meet regulatory and legal obligations, and protect the Fund’s legitimate business interests. This section outlines our policies regarding the retention, storage, and eventual deletion of personal and non-personal information. We adhere to strict data retention protocols to ensure the security and privacy of your information throughout its lifecycle.

5.1. Purpose-Based Retention

We may retain personal and non-personal data based on the specific purposes for which it was collected, as outlined in this Privacy Policy. This ensures that we only store your information for the period necessary to achieve the following objectives:

Account Management and Customer Support: We retain personal information related to your account, including contact details, investment data, and transaction history, as long as your account remains active. This information is essential for managing your account, providing customer support, and responding to any inquiries or issues you may have.
Regulatory and Legal Compliance: As a financial institution, we are subject to various regulatory requirements, including securities laws, anti-money laundering (AML) regulations, Know Your Customer (KYC) obligations, and tax reporting. We are required to retain certain personal and financial information to comply with these regulations, even after your account has been closed or your relationship with the Fund has ended.
Audit and Litigation Support: We may retain data for the purposes of responding to legal claims, regulatory investigations, or audits. In these instances, personal information may be preserved beyond the ordinary retention period to assist in legal defense or compliance with court orders, subpoenas, or investigations.
Fraud Prevention and Risk Management: In order to protect the integrity of our systems and prevent fraud, we may retain personal information related to suspicious transactions, account activity, or security incidents. This information helps us to investigate and mitigate risks associated with fraudulent activity, identity theft, or unauthorized access.

5.2. Retention Periods for Specific Categories of Data

Different types of data are subject to varying retention periods based on legal, regulatory, and operational requirements. Below is an overview of the retention periods for specific categories of data:

Personal Identification Data: Information such as your name, contact details, and identification documents (e.g., passport or driver's license) is retained for the duration of your relationship with the Fund and for a minimum period of five to seven years following the closure of your account, in compliance with KYC and AML regulations. This retention period may be extended if required by applicable law.
Transaction and Investment Data: Records related to your transactions, investments, trade history, and performance are retained for at least seven years following the date of the transaction or the closure of your account, as required by U.S. securities regulations, the Internal Revenue Service (IRS), and other governing bodies.
Communications Data: Email correspondence, recorded phone calls, and any other communications with our customer support or advisory teams are typically retained for up to seven years. This information may be used for compliance monitoring, customer support, and dispute resolution purposes. Recorded calls may also be retained in accordance with applicable laws and regulations for monitoring trading and advisory services.
Tax-Related Information: Tax documentation, including W-9/W-8 forms, investment income reports, and tax withholding data, is retained for seven years following the end of the tax year to which it pertains. This allows us to meet tax reporting and compliance obligations both in the U.S. and internationally (e.g., FATCA and CRS requirements).
Website Usage Data: Non-personal information collected through cookies, web beacons, or analytics tools for website usage, performance tracking, and optimization is retained for a shorter period, typically ranging from 30 days to 24 months, depending on the nature of the data and its purpose. For example, session cookies are deleted when you close your browser, while persistent cookies may remain on your device for a set period or until manually deleted by you.

5.3. Retention for Legal and Regulatory Requirements

Due to the nature of financial services and the regulatory framework under which we operate, we are required to retain certain categories of information for extended periods to meet our obligations. The key legal and regulatory frameworks influencing our data retention policies include:

Anti-Money Laundering (AML) and Know Your Customer (KYC) Regulations: Financial institutions are required to maintain records related to customer identification and transactions for a minimum period of five to seven years following the end of the customer relationship, or longer if required by law enforcement or regulators. This ensures that records are available for audit, regulatory review, and investigation of any suspicious activities.
Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) Regulations: As part of our obligations under U.S. financial regulations, we are required to maintain detailed records of investor transactions, communications, and portfolio holdings. These records must be kept for at least five years and, in some cases, up to seven years, depending on the nature of the documentation and the activities it covers.
Tax Reporting and Compliance: Tax-related documents, including investment income reports and tax withholding forms, are subject to IRS regulations and must be retained for seven years from the date of filing. These records are essential for both the Fund’s tax reporting obligations and investor compliance with domestic and international tax laws.
Litigation and Dispute Resolution: In the event of litigation, claims, or disputes involving the Fund, personal and financial information may be retained for the duration of the legal process, including any appeals or regulatory reviews. This ensures that necessary documentation is available to support the Fund’s defense, enforce legal rights, or comply with court rulings.

5.4. Data Minimization and Secure Deletion

Once your personal data is no longer necessary for the purposes outlined in this Privacy Policy, we will take steps to securely delete or anonymize the information in compliance with applicable laws and regulations. Our approach to data minimization and secure deletion includes the following procedures:

Secure Deletion: We utilize industry-standard data destruction techniques to ensure that all personal information is securely deleted from our systems. This includes the use of software tools that permanently erase digital files, making them unrecoverable. For physical records, we employ shredding and secure disposal methods to prevent unauthorized access.
Anonymization: In cases where personal information is no longer required in its original form but may still be useful for statistical or research purposes, we may anonymize the data. Anonymization ensures that any personally identifiable information is removed, and the data cannot be linked back to any individual. Anonymized data is then used for internal analysis, improving our AI/ML trading strategies, or enhancing the user experience on our platform.
Retention of Aggregated and Non-Personal Data: We may retain aggregated or de-identified data for longer periods for research, analysis, or business purposes, as this information does not contain any personal identifiers and poses no risk to your privacy. For example, we may use anonymized performance metrics to evaluate the effectiveness of our systematic macro trading models.

5.5. Investor Rights Related to Data Retention

As part of our commitment to data protection and privacy, we recognize that investors have certain rights with respect to the retention of their personal information:

Right to Access: You have the right to request access to the personal information we hold about you, including details about how long your information will be retained and the purposes for which it is being used. We will provide you with a copy of this information in a clear and accessible format.
Right to Request Deletion: If you believe that we no longer need your personal information for the purposes specified in this Privacy Policy, or if you withdraw your consent (where applicable), you have the right to request the deletion of your data. Please note that certain information may need to be retained to meet regulatory obligations, legal claims, or compliance with financial laws.
Right to Object: You may object to the retention of your personal data if you believe it is being held or used beyond its necessary purpose. In such cases, we will review your request and, where appropriate, limit or stop the processing and retention of your data, provided it does not conflict with legal or regulatory requirements.

5.6. Regular Review of Retention Policies

We periodically review our data retention policies and practices to ensure that we comply with evolving legal standards, industry best practices, and regulatory requirements. Any changes to our data retention schedules, as well as updates to this Privacy Policy, will be communicated to you in a timely manner through our website or other relevant communication channels.

6. Data Security

At the Fund, the security of your personal and financial information is of paramount importance. We are committed to implementing and maintaining robust security measures to protect the integrity, confidentiality, and availability of the data we collect, store, and process. This section outlines the comprehensive security practices and protocols we have in place to safeguard your information against unauthorized access, disclosure, alteration, or destruction, in compliance with applicable laws and industry standards.

6.1. Multi-Layered Security Approach

We employ a multi-layered approach to data security, combining advanced technical safeguards, physical security controls, and administrative procedures. This layered defense ensures that your information is protected from various types of threats, including cyberattacks, data breaches, and unauthorized internal access. The key components of our security infrastructure include:

Encryption: All sensitive personal and financial data, including account information, transactional data, and communication logs, are encrypted both in transit and at rest. We utilize industry-standard encryption protocols, such as SSL/TLS for data transmission and AES-256 for data storage, to ensure that your information is protected from interception or unauthorized access during its transfer and storage.
Access Controls: We implement strict access controls to ensure that only authorized personnel within the Fund have access to your personal information. Access is granted based on the principle of least privilege (PoLP), meaning that employees, contractors, or service providers are only given the minimum access necessary to perform their duties. Access to sensitive data is further restricted based on job roles, with additional authentication and approval requirements for high-level data access.
Two-Factor Authentication (2FA): We require two-factor authentication for all internal systems that handle sensitive data, as well as for investor accounts and client portals. This adds an extra layer of security by requiring users to verify their identity using a second factor, such as a one-time password (OTP) or biometric authentication, in addition to their standard login credentials.
Network Security: Our internal network is protected by state-of-the-art firewalls, intrusion detection and prevention systems (IDPS), and security information and event management (SIEM) tools. These systems monitor and filter network traffic, detect suspicious activity, and respond to potential threats in real time. We also employ endpoint protection and anti-virus solutions across all devices used within the organization to prevent malware and unauthorized access.
Data Segmentation and Isolation: We employ data segmentation practices to ensure that sensitive investor data is stored separately from other data types and isolated within secure environments. This minimizes the risk of unauthorized access or data exposure in the event of a security breach. Additionally, sensitive information such as account details and trade records are kept in encrypted, compartmentalized databases with restricted access controls.
Regular Penetration Testing and Vulnerability Assessments: We conduct regular penetration testing and vulnerability assessments to identify and address potential security weaknesses in our systems. These tests are performed by third-party security experts who simulate real-world attack scenarios to ensure that our defenses are resilient and capable of withstanding sophisticated cyber threats. We also continuously monitor for vulnerabilities and apply security patches and updates as they become available.

6.2. Security of Third-Party Service Providers

As part of our business operations, we may engage third-party service providers for services such as cloud storage, payment processing, and data analytics. We carefully vet these providers to ensure that they adhere to the highest security standards and comply with applicable data protection laws. Our agreements with third-party vendors require them to implement strong security measures and maintain the confidentiality of your information.

Vendor Security Audits: We regularly audit our third-party service providers to verify that their security practices align with our own. This includes reviewing their security certifications (e.g., SOC 2, ISO 27001), monitoring compliance with data protection regulations, and conducting independent assessments of their security controls.
Data Transfer Agreements: When transferring data to third-party providers, we utilize secure transmission methods and encryption protocols to ensure that your information remains protected. Data sharing with third parties is strictly limited to the purposes outlined in our Privacy Policy, and we implement contractual safeguards, such as Data Protection Addendums (DPAs), to ensure that your information is handled in compliance with applicable laws and regulations.

6.3. Physical Security

We employ rigorous physical security measures to protect the data centers and offices where your information is stored. These measures prevent unauthorized physical access and ensure that sensitive data remains secure from both internal and external threats.

Secure Data Centers: Our data centers are housed in facilities that are equipped with 24/7 surveillance, access controls, or biometric authentication systems. Physical access to these data centers is restricted to a limited number of authorized personnel, and all activity is logged and monitored in real time.
Office Security: In our office environments, we implement secure access controls, such as keycard or biometric entry systems, to prevent unauthorized individuals from accessing areas where sensitive data is handled. Employee workstations are equipped with automatic locking mechanisms, and security awareness training is provided to all staff to ensure they follow best practices when handling personal information.
Backup and Disaster Recovery: We maintain secure, redundant backups of all critical data in geographically dispersed locations to ensure business continuity in the event of a disaster or system failure. Our backup systems are regularly tested, and we have a robust disaster recovery plan in place to minimize downtime and data loss.

6.4. Monitoring and Incident Response

We continuously monitor our systems and networks for signs of unauthorized access, suspicious activity, or potential data breaches. Our security operations center is staffed with trained professionals who are responsible for detecting and responding to incidents in real time.

Real-Time Monitoring: Our Security Information and Event Management tools collect and analyze logs from all critical systems to identify unusual patterns of behavior, unauthorized access attempts, or potential security incidents. Alerts are generated in real time, allowing us to take immediate action in the event of a security breach or threat.
Incident Response Plan: We have a detailed incident response plan in place that outlines the steps we will take in the event of a security breach, data loss, or other cybersecurity incident. This plan includes the identification of affected systems, containment of the threat, mitigation of damage, and communication with stakeholders, including affected individuals and regulators. Our response team is trained to act swiftly and decisively to minimize the impact of any security incidents.
Data Breach Notifications: In the unlikely event of a data breach that results in the unauthorized access, disclosure, or loss of your personal information, we will notify you in accordance with applicable laws and regulatory requirements. We will also take steps to mitigate any harm and provide guidance on how to protect your information.

6.5. Employee Training and Awareness

Our employees play a critical role in maintaining the security of your personal data. We provide regular training and awareness programs to ensure that all staff members understand their responsibilities and follow best practices for data protection.

Security Awareness Training: All employees undergo comprehensive security awareness training as part of their onboarding process and receive ongoing refresher courses throughout their employment. This training covers topics such as phishing prevention, secure password practices, safe handling of sensitive data, and how to recognize potential security threats.
Confidentiality Agreements: All employees, contractors, and vendors who have access to personal information are required to sign confidentiality agreements as part of their employment or service contracts. These agreements prohibit the unauthorized disclosure or use of personal data and outline the consequences of any violations.

6.6. Data Security Rights of Individuals

We are committed to ensuring that your personal information is protected, and we offer a range of data security rights to give you greater control over your information:

Right to Be Informed: You have the right to know what data we collect, how it is used, and what measures we take to secure it. Our Privacy Policy provides detailed information on our data security practices and your rights as an investor.
Right to Rectification: If you believe that your personal information is inaccurate or incomplete, you have the right to request that we update or correct the information. We will take prompt action to make the necessary updates.
Right to Erasure: In certain circumstances, you may have the right to request that your personal data be deleted from our systems. We will evaluate your request in accordance with applicable data protection laws and take appropriate action to securely erase your information, provided it does not conflict with our legal or regulatory obligations.

6.7. Compliance with Global Data Security Standards

Our data security practices are aligned with global standards and best practices in cybersecurity and data protection. We comply with relevant data protection regulations, including:

General Data Protection Regulation (GDPR): For our European investors, we comply with the stringent data security requirements set forth by the GDPR, ensuring that personal data is protected in accordance with EU regulations. This includes the implementation of strong security controls, encryption, and data minimization practices.
California Consumer Privacy Act (CCPA): For our U.S. investors, we adhere to the data security requirements under the CCPA, providing the necessary protections to ensure the confidentiality and integrity of your information.
Financial Industry Regulations: As a hedge fund operating in the financial services industry, we comply with all relevant security standards mandated by regulatory authorities such as the SEC, CFTC, and FINRA. These standards include requirements for data encryption, access controls, and breach reporting.

6.8. Continuous Improvement

We are committed to continuously improving our data security measures to stay ahead of emerging threats and evolving regulatory requirements. Our security team regularly reviews and updates our security protocols to ensure that we maintain the highest level of protection for your personal information.

Security Audits: We conduct regular internal and external audits of our security practices to identify areas for improvement and ensure compliance with industry standards.
Adoption of New Technologies: As part of our commitment to innovation, we actively evaluate and adopt new security technologies, such as AI-driven threat detection systems, to enhance our ability to detect and respond to cyber threats.

7. Your Rights

As an investor, client, or visitor of the Fund, you have certain rights regarding the personal information we collect, process, and store. These rights are designed to give you more control over your personal data and ensure that your information is treated transparently and fairly. This section outlines your key data protection rights, the processes for exercising them, and how we ensure compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) for EU residents and the California Consumer Privacy Act (CCPA) for U.S. residents.

7.1. Right to Access

You have the right to request access to the personal information that we hold about you. This includes the right to:

Obtain a copy of your personal data: You may request a copy of the personal information we have collected and stored about you. This information will be provided to you in a clear, structured, and commonly used format, enabling you to review how your data is being processed and for what purposes.
Understand how your data is used: You can request detailed information about the specific types of personal data we hold, how it is collected, for what purposes it is processed, and the legal basis for that processing. Additionally, we will inform you about the categories of third parties to whom your data may be disclosed and whether your personal data has been transferred internationally.
Request confirmation of processing: You may request confirmation that your personal information is being processed by us and that we are adhering to the relevant legal and regulatory data protection obligations.

7.2. Right to Rectification

If you believe that any personal data we hold about you is inaccurate, incomplete, or outdated, you have the right to request that we correct or update that information. This includes the right to:

Update your personal details: You may request changes to incorrect or outdated information, such as contact details, financial information, or identification numbers, ensuring that we maintain accurate records for future communications and transactions.
Provide supplemental information: If the data we hold is incomplete, you have the right to provide additional information to ensure that your records reflect a full and accurate account of your relationship with the Fund.

We will act on your request to rectify personal data without undue delay and inform you when the correction has been made.

7.3. Right to Erasure (Right to be Forgotten)

In certain circumstances, you may have the right to request the deletion of your personal data from our systems. This right to erasure, also known as the “right to be forgotten,” allows you to:

Request deletion of your data: You can ask us to delete your personal data where it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent to data processing. This right also applies if you believe your data has been unlawfully processed or if you wish to exercise your right to object to the processing of your data.
Conditions of erasure: We will review your request in light of any legal or regulatory obligations that may require us to retain certain information for compliance, auditing, or reporting purposes. Where applicable, we may refuse the request if the data is necessary for establishing, exercising, or defending legal claims or for compliance with legal obligations.
Notification of third parties: If your data has been shared with third parties and you request erasure, we will take reasonable steps to notify those third parties of your request, subject to technical and legal feasibility.

7.4. Right to Restrict Processing

You have the right to request the restriction of processing of your personal data in specific circumstances. This means that, while we continue to store your personal data, we will temporarily cease processing it, except for certain essential activities. You may exercise this right if:

You contest the accuracy of your data: If you believe that the personal data we hold about you is inaccurate, you may request that we restrict its processing while we verify its accuracy.
You object to the processing: If you have raised an objection to our use of your personal data (see Section 7.7), you may request a restriction of processing while we evaluate your objection.
Processing is unlawful: If you believe that the processing of your personal data is unlawful but do not wish to request erasure, you may request that we restrict the processing of your data instead.
Data is no longer needed: If we no longer need your personal data for the purposes for which it was collected, but you require it to establish, exercise, or defend legal claims, you may request that we retain your data but cease further processing.

7.5. Right to Data Portability

You have the right to request that we provide your personal data in a structured, commonly used, and machine-readable format, allowing you to transfer your data to another data controller or service provider. This right to data portability applies when:

Processing is based on consent or contract: You have provided us with your data under a contract or based on your consent, and the processing is carried out by automated means.
Direct transfer to another party: You may request that we transmit your personal data directly to another organization, where technically feasible. We will make every effort to facilitate this transfer while ensuring that your data remains secure and intact.

This right ensures that you can easily move, copy, or transfer your personal data between different services or platforms without hindrance.

7.6. Right to Withdraw Consent

Where the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time. This includes:

Withdraw at any time: You can withdraw your consent to any data processing activities that rely on it, including marketing communications, data analytics, or the processing of sensitive information.
Impact of withdrawal: Please note that withdrawing your consent does not affect the lawfulness of any data processing that took place before the withdrawal. Once you withdraw your consent, we will cease the associated processing activities, but we may still process your data if there are other legal grounds for doing so (e.g., compliance with legal or regulatory requirements).

7.7. Right to Object to Processing

You have the right to object to the processing of your personal data in certain circumstances, particularly where we process your data based on legitimate interests or for direct marketing purposes. This includes:

Objection to legitimate interest processing: If you believe that our processing of your personal data based on our legitimate interests is unwarranted, you may object to that processing. We will evaluate your objection and, unless we have compelling legitimate grounds to continue processing your data, we will cease the processing in question.
Objection to direct marketing: You have the absolute right to object to the processing of your personal data for direct marketing purposes. Upon receiving your objection, we will stop using your data for these purposes without delay.

7.8. Rights Concerning Automated Decision-Making and Profiling

In certain circumstances, you may have the right to not be subject to automated decision-making, including profiling, where such decisions have a significant legal or similar impact on you. This right applies where:

Decisions are based solely on automated processes: If a decision about you is made solely using automated means (i.e., without human intervention), you may have the right to request that a human reviews the decision, or that you provide additional input before the decision is finalized.
Exemptions: Please note that automated decision-making may still occur in specific cases where it is necessary for entering into or performing a contract, is authorized by law, or is based on your explicit consent.

7.9. Right to Complain to a Supervisory Authority

If you believe that our processing of your personal data violates data protection laws, you have the right to lodge a complaint with a supervisory authority. Depending on your location, you can submit a complaint to:

Data protection authorities in the EU: For residents of the European Union, complaints can be filed with the relevant Data Protection Authority (DPA) in your member state, particularly where the alleged infringement occurred.
Supervisory authorities in other regions: In other jurisdictions, such as the U.S. or the U.K., you may submit complaints to the appropriate data privacy and protection authorities, such as the Federal Trade Commission (FTC) or the Information Commissioner's Office (ICO).

7.10. How to Exercise Your Rights

To exercise any of your rights under this section, you may contact us by using the contact details provided in this Privacy Policy. We will respond to your request without undue delay and within the timeframes required by applicable data protection laws. We may require you to provide verification of your identity before processing your request, particularly when dealing with sensitive or high-risk personal data.

8. Cookies and Tracking Technologies

At the Fund, we use may cookies and other tracking technologies to enhance the user experience on our website, analyze site traffic, and better understand how visitors engage with our content and services. These technologies also help us to personalize the content and advertisements you see and ensure that our communications are relevant to your interests. This section provides detailed information about the types of cookies and tracking technologies we use, how we use them, and how you can manage or disable them.

8.1. What are Cookies?

Cookies are small text files that are placed on your device (such as a computer, tablet, or smartphone) by a website. Cookies allow the website to remember your preferences, recognize you upon future visits, and help the website to perform various functions efficiently. Cookies can be either session cookies (which are deleted when you close your browser) or persistent cookies (which remain on your device for a specified period or until you delete them).

There are different types of cookies used for various purposes, including:

Essential Cookies: These cookies are necessary for the proper functioning of our website. They enable you to navigate the site, access secure areas, and use essential features, such as login credentials and account management. Without these cookies, some services you request cannot be provided.
Performance and Analytics Cookies: These cookies collect anonymous information about how visitors use our website. We use these cookies to understand which pages are the most popular, how visitors navigate the site, and whether any errors occur. This data helps us improve the performance of our site and enhance user experience. Analytics tools such as Google Analytics or similar platforms may be used in conjunction with these cookies.
Functional Cookies: These cookies allow our website to remember your preferences, such as language, region, or settings, to provide you with a more personalized experience. For example, functional cookies may be used to remember your login information or the contents of your shopping cart during online transactions.
Targeting or Advertising Cookies: These cookies track your browsing habits and are used to deliver advertisements that are relevant to your interests. They may be set by third-party advertisers or ad networks with our permission. These cookies also help us measure the effectiveness of our advertising campaigns and limit the number of times you see a specific ad. They do not store directly identifiable personal information, but they work by uniquely identifying your browser and device.

8.2. What are Tracking Technologies?

In addition to cookies, we may use a variety of other tracking technologies to collect information about your interaction with our website and services. These technologies include:

Web Beacons (Pixel Tags): Web beacons, also known as pixel tags or clear GIFs, are tiny graphics embedded in web pages or emails that track whether you have interacted with specific content (e.g., clicked a link, opened an email). Web beacons help us monitor the effectiveness of our email campaigns and website analytics.
JavaScript: JavaScript is a programming language embedded in our web pages that allows us to interact with your device in real-time. It helps us monitor your behavior on our site, such as clicks, mouse movements, and page navigation, enhancing the user experience and providing dynamic content.
Local Storage and Session Storage: These are HTML5-based technologies that store data locally on your browser. Local storage enables us to retain information (e.g., preferences or settings) across sessions, while session storage is used to remember information only for the duration of your browsing session.
IP Address Tracking: We collect your Internet Protocol (IP) address when you visit our site to better understand your location, device type, and browsing behavior. This helps us detect potential fraud, maintain site security, and optimize your user experience.

8.3. How We Use Cookies and Tracking Technologies

We may use cookies and tracking technologies for several purposes, including:

Improving Site Performance: We use cookies to monitor the performance and reliability of our website. This includes measuring website load times, analyzing errors, and optimizing page layout to ensure that our content is easily accessible and responsive to users’ needs.
Personalizing Your Experience: Cookies help us tailor your experience on our website by remembering your preferences, login information, and browsing history. This ensures that you have a consistent and relevant experience across multiple sessions.
Analyzing Website Traffic: We use performance and analytics cookies to gather aggregated, anonymous data on how visitors interact with our website. This helps us identify trends, improve site content, and develop new features that enhance user engagement.
Supporting Advertising Efforts: Targeting cookies are used to deliver personalized advertisements both on our website and across other platforms. These cookies ensure that you see ads relevant to your interests and help us track the performance of our advertising campaigns.
Facilitating Security and Fraud Prevention: Cookies and tracking technologies are used to maintain the security of our site by detecting malicious activity, unauthorized access, or fraudulent behavior. They also assist in ensuring that only legitimate users can access restricted areas of the site.

8.4. Managing and Disabling Cookies

You have the right to manage or disable cookies and tracking technologies through your browser settings or by using third-party tools. However, please note that disabling certain cookies may affect your ability to use certain features of our website or result in a less personalized browsing experience.

Browser Settings

Most web browsers allow you to manage cookie preferences. You can choose to block or delete cookies, and you may also set your browser to notify you when cookies are being placed on your device. Instructions for managing cookies vary by browser, but common steps include:

Google Chrome: Go to "Settings" > "Privacy and security" > "Cookies and other site data."
Mozilla Firefox: Go to "Options" > "Privacy & Security" > "Cookies and Site Data."
Microsoft Edge: Go to "Settings" > "Cookies and site permissions."
Safari: Go to "Preferences" > "Privacy" > "Cookies and website data."

You can also find detailed instructions for managing cookies in the help section of your browser or by visiting websites such as AllAboutCookies.org.

Third-Party Tools

There are also third-party tools and browser extensions that allow you to manage and block cookies from specific advertisers or websites. Popular tools include:

Please note that managing or disabling cookies may impact your user experience and prevent you from accessing certain features or functionalities of our website.

8.5. Third-Party Cookies and Tracking

Some cookies and tracking technologies used on our website are placed by third-party service providers, such as analytics platforms, advertisers, and social media networks. These third parties may collect information about your browsing habits, device type, and engagement with content to provide targeted advertisements or analyze site traffic.

Examples of third-party cookies we may use include:

Google Analytics: We use Google Analytics to collect information about how visitors use our site. Google Analytics uses cookies to track and report website traffic and user behavior. The data collected is used for analytics purposes only and does not personally identify you.
LinkedIn Insights Tag: We use LinkedIn’s tracking pixel to collect data on website visitors who have LinkedIn accounts. This data helps us target relevant content and advertising to LinkedIn users who visit our site.
Facebook Pixel: The Facebook pixel allows us to track user activity on our website and measure the effectiveness of our advertising campaigns. It enables us to target Facebook ads to users who have previously visited our site.

You can review the privacy policies of these third-party service providers for more information on their use of cookies and how to manage or disable them.

8.6. Consent to Use of Cookies and Tracking Technologies

By continuing to use our website, you consent to the use of cookies and tracking technologies as described in this Privacy Policy. You can manage or withdraw your consent at any time by adjusting your browser settings or using third-party tools to block cookies. However, please be aware that disabling cookies may affect the functionality and usability of our website.

9. International Transfers

At the Fund, we are committed to protecting your personal data regardless of where it is processed or stored. Due to the global nature of our operations and the digital services we provide, your personal data may be transferred to, stored in, or processed in jurisdictions outside your home country. This section provides detailed information about how we manage international transfers of personal data, the protections we implement, and your rights regarding such transfers.

9.1. Why We Transfer Data Internationally

We may transfer your personal data internationally for several reasons, including:

Global Operations: As a hedge fund with global operations and investments across different markets, we may need to process and analyze data in various locations to provide our services, manage client relationships, and execute investment strategies.
Third-Party Service Providers: We work with third-party service providers, partners, and vendors located in different countries to help us operate our business. These providers may assist with data storage, IT infrastructure, analytics, payment processing, and marketing services. In some cases, these third parties are located in jurisdictions outside the United States or your country of residence.
Cloud-Based Solutions: Many of our data storage and processing systems are cloud-based, meaning that your personal data may be stored on servers located in various regions, including outside of your home country. Cloud service providers are selected based on their robust security practices and compliance with data protection laws.
Legal and Regulatory Requirements: In certain circumstances, we may need to transfer personal data to fulfill legal or regulatory obligations in foreign jurisdictions, for example, to respond to law enforcement requests, regulatory audits, or litigation processes.

9.2. Countries We May Transfer Data To

Your personal data may be transferred to countries that may not have the same level of data protection as your home country. Some of the common regions where we may transfer your personal data include:

United States: As our hedge fund is based in Florida, personal data may be transferred to the United States for processing, storage, and compliance with U.S. regulations.
European Union/European Economic Area (EU/EEA): If you are based in the EU/EEA, your data may be transferred to countries outside the EU/EEA, such as the United States or other jurisdictions, which may not offer the same level of protection as within the EU.
Asia-Pacific (APAC): Depending on the nature of our business activities and partnerships, personal data may be transferred to countries in the APAC region, including Singapore, Hong Kong, or Australia.

9.3. Legal Basis for International Transfers

When transferring personal data internationally, we take appropriate steps to ensure that your data is protected in line with applicable data protection laws, including but not limited to:

Adequacy Decisions: In some cases, we may transfer personal data to countries that have been deemed by relevant regulatory authorities (e.g., the European Commission) to have an adequate level of data protection. This means that these countries’ data protection laws are comparable to those in your home jurisdiction.
Standard Contractual Clauses (SCCs): For transfers to countries without an adequacy decision, we implement legally binding agreements that include Standard Contractual Clauses (SCCs). These are model clauses approved by the European Commission or other relevant authorities that ensure a consistent level of data protection and security during international transfers.
Binding Corporate Rules (BCRs): In certain circumstances, we may rely on Binding Corporate Rules, which are internal policies used by multinational companies to ensure that personal data is protected when transferred internationally within the group.
Explicit Consent: Where required by law, we may seek your explicit consent before transferring your personal data to jurisdictions with lower levels of protection. This consent will be obtained transparently and with clear explanations of the associated risks.
Legal or Contractual Obligations: In some cases, we may be legally obligated to transfer personal data to foreign jurisdictions to comply with regulatory requests, tax requirements, or legal processes. These transfers will be conducted in compliance with applicable laws and safeguards.

9.4. Data Protection Measures

To safeguard your personal data during international transfers, we implement several measures, including:

Encryption: We use encryption technologies to protect your personal data while it is in transit and at rest, ensuring that unauthorized parties cannot access or tamper with the data.
Access Controls: Access to your personal data is restricted to authorized personnel who require the information for legitimate business purposes. These individuals are bound by confidentiality obligations and data protection policies.
Third-Party Due Diligence: Before engaging third-party service providers located outside of your home jurisdiction, we conduct rigorous due diligence to ensure that they have appropriate data protection policies, security measures, and compliance with applicable laws.
Contractual Safeguards: Where necessary, we implement contractual safeguards with third-party service providers to ensure that they comply with international data protection standards, even when operating in countries with lower levels of legal protection.

9.5. Your Rights Regarding International Transfers

Depending on your location and applicable data protection laws, you may have the following rights concerning the international transfer of your personal data:

Right to be Informed: You have the right to be informed about how and where your personal data is transferred, the reasons for such transfers, and the protections in place.
Right to Object: In certain circumstances, you may have the right to object to the international transfer of your personal data, particularly if the transfer is not necessary for the performance of a contract or required by law.
Right to Access: You have the right to request access to the personal data we hold about you, including information about where your data is stored and processed internationally.
Right to Rectification: If any of the personal data transferred internationally is inaccurate or incomplete, you have the right to request its correction or completion.
Right to Erasure: In some situations, you have the right to request the deletion of your personal data, particularly if the transfer is not compliant with applicable laws or is no longer necessary for business purposes.
Right to Data Portability: You may request that your personal data be transferred to another organization or jurisdiction, subject to applicable laws and technical feasibility.

9.6. Managing International Data Transfers

If you have any concerns or questions regarding the international transfer of your personal data, please contact us. We will make reasonable efforts to address your concerns and provide additional information about the safeguards we use to protect your data.

10. Changes to This Privacy Policy

At the Fund, we understand that transparency and accountability are vital in maintaining your trust. As part of our commitment to protecting your personal data and complying with applicable data protection laws, we may update this Privacy Policy from time to time. This section outlines how we will communicate any changes, the importance of reviewing the policy regularly, and your rights in relation to these changes.

10.1. Right to Modify

We may modify this Privacy Policy for several reasons, including:

Legal and Regulatory Requirements: Changes in laws, regulations, or guidance from data protection authorities may necessitate updates to our Privacy Policy to ensure compliance with applicable laws in the jurisdictions in which we operate.
Business Practices: As our business evolves, we may introduce new services, modify existing processes, or enhance our technology. These changes may require adjustments to how we collect, use, and protect your personal data.
Feedback and Best Practices: We value feedback from our clients, partners, and stakeholders. We may make changes to our Privacy Policy in response to suggestions or as best practices in data protection evolve within our industry.
Operational Enhancements: In efforts to improve our operations and enhance user experience, we may revise our data handling practices, which could require updates to this policy.

10.2. Communication of Changes

To ensure that you are aware of any changes to this Privacy Policy, we will communicate updates through the following means:

Website Notification: We will publish the updated Privacy Policy on our website. The revised policy will be effective immediately upon posting, and we will indicate the date of the last revision at the top of the document.
Email Notification: If we make significant changes that materially affect your rights or how we process your personal data, we may notify you directly via email or other communication channels. This may include details about the nature of the changes, their impact, and any necessary actions you may need to take.
In-App Notices: For users who access our services through a mobile application or client portal, we may provide in-app notifications or alerts to inform you of important changes to our Privacy Policy.
User Agreements: In cases where our Privacy Policy is integrated into a user agreement or service contract, we will notify you of any changes as stipulated in those agreements.

10.3. Your Responsibility to Review

It is essential for you to review our Privacy Policy regularly to stay informed about our practices regarding your personal data. We recommend that you check our website periodically to ensure you are aware of any updates. Your continued use of our services following the posting of changes constitutes your acceptance of those changes.

10.4. Your Rights in Relation to Changes

In the event of significant changes that materially affect the way we process your personal data, you may have certain rights, including:

Opt-Out Options: If you disagree with any substantial changes to our Privacy Policy, you may have the right to opt out of specific data processing activities, withdraw consent where applicable, or terminate your relationship with us.
Request Clarifications: If you have questions about any changes made to the Privacy Policy or how they may affect your personal data, you are encouraged to reach out to us directly. We will strive to provide clarifications and address any concerns you may have.
Access to Updated Policy: You can always access the latest version of our Privacy Policy on our website. If you wish to receive a copy of the current policy or previous versions, please contact us.

10.5. Archive of Previous Versions

For your reference, we maintain an archive of previous versions of our Privacy Policy. If you would like to review earlier versions or understand how our practices have evolved over time, please contact us, and we will be happy to provide that information.

10.6. Final Considerations

By using our website or services, you acknowledge that you have read and understood this Privacy Policy, including any modifications that may occur. We appreciate your trust and are committed to safeguarding your personal data in accordance with this Privacy Policy.

Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your personal information, please contact us at info@goldentree.one.