Privacy Policy

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Your privacy is important to us. This Privacy Policy describes the types of information Shareholder Capital collects from you when you visit this Site or otherwise interact with us online. This Privacy Policy also describes the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

 
Information Collected

In the course of its business, Shareholder Capital may collect personal data from public and non-public sources regarding clients, prospective clients, other business partners or employees (“Personal Information”). Such Personal Information may include:

• Information you provide to Shareholder Capital, including your name, contact information      (including mailing address, e-mail address and telephone numbers), financial information (including bank or brokerage account information and wire transfer instructions), information relating to sources of funds, government-issued identification numbers (including social security numbers, tax identification numbers and passport numbers) or citizenship status in connection with making an investment in a Fund or account managed      by Shareholder Capital, or otherwise in the course of doing business with Shareholder Capital.
• Information that is automatically collected by Shareholder Capital through this Site      (including “cookies), which can include date and time of access of the Site, the Internet Protocol address of the computer that you are using while accessing this Site, the domain and host from which you access the Internet, your browser software and operating system, and the specific activities in which you are engaged while visiting this website.
• Any other Personal Information that you may choose to share with Shareholder Capital      that either you or Shareholder Capital deems necessary or desirable to share.

How We Use Personal Information We Obtain

We may use Personal Information that we obtain about an individual for the following purposes, subject to applicable law or regulation (including when an individual’s consent is required by applicable law):

• In order to provide our products and services.
• In order to communicate with clients, prospective clients, or other business partners.
• To establish and maintain a potential business relationship between you and Shareholder      Capital
• In order to comply with regulatory requirements (including, potentially, disclosure of      Personal Information to a governmental or regulatory authority in order to comply with Anti-Money Laundering or other related regulations promulgated by a jurisdiction) or complying with a prime broker, custodian, administrator, broker-dealer, other investment counterparty or third-party service provider or business partner’s due diligence or “Know Your Customer” requirements.
• In connection with the expansion or growth of Shareholder Capital’s business, including      the creation and marketing of new funds or other investment products.
• In connection with an audit or examination by a third-party auditor or regulatory      authority, in connection with the prevention or investigation of potential fraud or other criminal activity or the mitigation of any liability or potential liability of Shareholder Capital, in connection with security initiatives or the maintenance of Shareholder Capital’s information technology systems or infrastructure, or to enforce any legal rights of      Shareholder Capital.
• In order to fulfill any other legal or regulatory obligations of Shareholder Capital      or any fund or account managed by Shareholder Capital.
• In following any industry best practices in connection with the use of information.
• To manage the website’s functionality (including the use of “Cookies”).

Information Sharing

Shareholder Capital may disclose the Personal Information we collect from you with the following categories of third parties and in the following ways:

• With our affiliated companies;
• With our third-party service providers that provide business, professional or technical support functions for us;
• As necessary if we believe that there has been a violation of our Terms of Use or of our      rights or the rights of any third party;
• To respond to judicial process or provide information to law enforcement or regulatory      agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and
• As otherwise described to you at the point of collection.

Contact Us About the Privacy Policy

If you have additional questions about this Privacy Policy or the practices described herein, you may contact us at info@shareholdercap.com