Your privacy is very important to us. This notice (“Privacy Notice”) is provided by Caius Capital LLP,
Caius Capital Services Limited and Caius Capital Limited (“we” or “us”) and sets out our policies
with respect to the collection, sharing and use of personal information.
We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store
information on your computer. Such text files and images are used for technical convenience to store
information on your computer. For instance, we may use a session cookie to store form information
that you have entered so that you do not have to enter such information again. We may use information
stored in such text files and images to customise your experience on this website and to monitor use
of this website. You may set your browser to notify you when you receive a cookie. Many web browsers
also allow you to block cookies. If you block cookies you may not be able to access certain parts of
this website. You can disable cookies from your computer system by following the instructions on your
browser or at www.allaboutcookies.org.
Who to Contact About This Privacy Notice
This Privacy Notice is being provided in accordance with the applicable requirements under the
privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the
“Data Protection Laws”). We are considered to be data controllers in respect of any personal
information we hold about you for the purposes of certain Data Protection Laws. This means that
we determine the purposes and the means of the processing of your personal information.
Please contact our Compliance Officer on +44 2071907940, firstname.lastname@example.org or by
writing to the following address 135-137 New Bond Street, London W1S 2TQ, United Kingdom with any
questions about this Privacy Notice or requests with regards to the personal data we hold.
The Types of Personal Data We May Hold
The categories of personal data we may collect include names, residential or business addresses,
or other contact details, signature, nationality, tax identification or passport number,
date of birth, place of birth, photographs, copies of identification documents, bank account details,
information about assets or net worth, credit history, information on investment activities, or other
personal information, such as certain special categories of personal data (including, where relevant,
information on political affiliations, ethnic origin, or criminal convictions), as specified under the
applicable Data Protection Laws, that may be contained in the relevant materials, documents, or
obtained through background searches.
How We Collect Personal Data
We may collect personal data about you through: (i) information provided directly to us by you, or
another person on your behalf; (ii) information that we obtain in relation to any transactions between
you and us; and (iii) recording and monitoring of telephone conversations with you.
We also may receive your personal information from third parties or other sources, such as our
affiliates, Fund Administrator, Fund Sub-Administrator, publicly accessible databases or registers,
tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention
and detection agencies, or other publicly accessible sources, such as the Internet.
How We May Use Personal Information
We may process your personal data for the purposes of administering the relationship between you and
us (including subscription acceptance, communications and reporting), marketing of our products and
services, monitoring and analysing our activities, and complying with applicable legal or regulatory
requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance,
or responding to requests for information from supervisory authorities, or law enforcement agencies).
We will use one of the permitted grounds under the applicable Data Protection Laws to process your
personal information. Such grounds include, for example, circumstances where:
- processing is necessary to perform our obligations under the relevant Fund Documents;
- we are required to comply with a legal or regulatory obligation applicable to us; or
- we, or a third party on our behalf, have determined that it is necessary for our legitimate
interests to collect and use your personal information, such as if we believe that you have a
reasonable expectation for us or a third party to collect or use your personal information for such purpose.
What Are The Consequences Of Failing To Provide Personal Information
Where personal data is required to satisfy a statutory obligation (including compliance with applicable
anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such
information may result in us being unable to provide a service to you.
Where there is suspicion of unlawful activity, failure to provide personal data may result in the
submission of a report to the relevant law enforcement agency or supervisory authority.
How We May Share Personal Data
We may disclose information about you to our affiliates, service providers or other third parties
to accept your subscription, administer and maintain your account(s), or otherwise perform our
contractual obligations. We may also need to share your personal information with regulatory,
tax or law enforcement authorities comply with applicable legal or regulatory requirements,
respond to court orders, or in the context of regulatory requests for information, administrative
proceedings, or investigations. We will also release information about you if you direct us to do so.
We may also disclose information about you, or your transactions and experiences with us, to our
affiliates or service providers for our everyday business purposes, such as administration of our
business, record-keeping, maintaining security of our information technology systems, reporting
and monitoring of our activities, investor relations activities, and compliance with applicable
legal and regulatory requirements.
Retention Periods and Security Measures
We will not retain personal data for longer than is necessary in relation to the purpose for which
it is collected, subject to the applicable Data Protection Laws. Personal data will be retained
for the duration of your investment in the applicable Fund and for a minimum of five years after
a redemption or withdrawal, as applicable, of your investment, or liquidation of the applicable Fund.
We may retain personal data for a longer period for the purpose of marketing our products and
services or compliance with applicable law. From time to time, we will review the purpose for
which personal data has been collected and decide whether to retain it or to delete if it no longer
serves any purpose to us.
To protect your personal information from unauthorised access and use, we apply organisational and
technical security measures in accordance with applicable Data Protection Laws. These measures
include computer safeguards and secured files and buildings.
We will notify you of any material personal data breaches affecting you in accordance with the
requirements of applicable Data Protection Laws.
Monitoring of Communications
We may record and monitor telephone conversations and electronic communications with you for
the purposes of: (i) ascertaining the details of instructions given, the terms on which any
transaction was executed or any other relevant circumstances; (ii) ensuring compliance with
our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.
Additional Information under the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)
For purposes of U.S. federal law, this Privacy Notice applies to current and former investors who
are individuals or Individual Retirement Accounts. We are providing this additional information
under U.S. federal law.
We may disclose information about our investors, prospective investors or former investors to
affiliates (i.e., financial and non-financial companies related by common ownership or control)
or non-affiliates (i.e., financial or non-financial companies not related by common ownership
or control) for our everyday business purposes, such as to process your transactions, maintain
your account(s) or respond to court orders and legal investigations. Thus, it may be necessary
or appropriate, under anti-money laundering and similar laws, to disclose information about the
Fund’s investors in order to accept subscriptions from them. We will also release information
about you if you direct us to do so.
We may share your information with our affiliates for direct marketing purposes, such as offers
of products and services to you by us or our affiliates. You may prevent this type of sharing
by contacting us at +44 2071907940. If you are a new investor, we can begin sharing your
information with our affiliates for direct marketing purposes 30 days from the date you receive
our Privacy Notice. When you are no longer our investor, we may continue to share your
information with our affiliates for such purposes.
You may contact us at any time to limit our sharing of your personal information. If you limit
sharing for an account you hold jointly with someone else, your choices will apply to everyone
on your account. U.S. state laws may give you additional rights to limit sharing.
We may disclose information you provide to us to companies that perform marketing services on
our behalf, such as any placement agent retained by the Funds.
Additional Information under the Cayman Islands Data Protection Law 2017 (“DPL”)
If you are an investor in a Fund that we manage. The applicable Fund may share your personal
information with its services providers, including the Investment Manager, the Administrator,
the Sub-Administrator, the Prime Brokers, or others who are located outside the Cayman Islands.
It may also be necessary to share your information with the Cayman Islands Monetary Authority
or the Tax Information Authority, which may, in turn, exchange this information with foreign
tax authorities, regulatory or law enforcement agencies. Any transfer of your personal data by
us, our affiliates or service providers outside the Cayman Islands will be carried out in
accordance with the DPL.
You have certain rights under the DPL, including: (i) the right to be informed; (ii) the right
of access; (iii) the right to rectification; (iv) the right to stop or restrict processing;
(v) the right to stop direct marketing; (vi) rights in relation to automated decision making;
(vii) the right to seek compensation; and (viii) the right to complain to the supervisory
authority. A complaint in respect of the Offshore Fund or the Master Fund may be lodged with
the Office of the Ombudsman in the Cayman Islands. Please use the contact details under Who to
Contact About This Privacy Notice if you wish to exercise these rights.
Additional Information under the EU General Data Protection Regulation
You may have certain rights under EU General Data Protection Regulation (“GDPR”) in relation
to our processing of your personal data and any processing carried out on your behalf. These rights
include: (i) the right to request access to your personal data; (ii) the right to request
rectification of your personal data; (iii) the right to request erasure of your personal data (the
“right to be forgotten”); (iv) the right to restrict our processing or use of your personal data;
(v) the right to object to our processing or use where we have considered this to be necessary for
our legitimate interests (such as in the case of our marketing activities); (vi) where relevant,
the right to request the portability of the data; (vii) if your consent to processing has been
obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint
with a supervisory authority. Please note that the right to be forgotten that applies in certain
circumstances under GDPR is not likely to be available in respect of the personal data we hold,
given the purpose for which we collect such data, as described above.
A complaint in respect of the Investment Manager may be made to the Information Commissioner’s
Office in the United Kingdom.
Due to the international nature of our business, your personal data may be transferred to
jurisdictions that do not offer equivalent protection to personal data as under the GDPR
(“Third Countries”). In such cases, we will process personal data (or procure that it be
processed) in the Third Countries in accordance with the requirements of GDPR, which may
include having appropriate contractual undertakings in legal agreements with service providers
who process personal data on our behalf in such Third Countries. We may also be required
to transfer your personal information to our regulators or government agencies in Third
Countries in cases where such transfers are necessary in the context of administrative
proceedings, such as requests for information, examinations or investigations, or to other
relevant parties in Third Countries where it is necessary for the purposes of establishing,
bringing, or defending legal claims, or for another legitimate business purpose, such as
compliance with our legal or regulatory obligations under foreign law.