Eagle Trading Systems Inc. (the “Investment Manager”) and the private investment vehicles that were managed by the Investment Manager in the past and may be managed by the Investment Manager in the future (each, a “Fund,” and together with each Fund’s master fund, and the Investment Manager, the “Joint Data Controllers”) are committed to protecting your privacy and maintaining the confidentiality and security of your personal information that is provided in connection with your investment (or potential investment) in the Fund. Where your details are provided to either or any of the Joint Data Controllers as a consequence of your investment (or potential investment) in the Fund, then the Joint Data Controllers, may themselves (or through a third party data processor such as SS&C Technologies, Inc. that served as administrator to the private investment vehicles managed by the Investment Manager in the past (the “Administrator”) acting in its capacity as the Fund’s administrator) process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (as distinguished from the entity itself) (the foregoing collectively, “Your Personal Information”). When processing Your Personal Information, the Administrator will only act as a data processor on the instructions of the Joint Data Controllers.
The Joint Data Controllers’ European Union representative is located in United Kingdom at Paternoster House, 65 St. Paul’s Churchyard, London EC4M 8AB and can be contacted at [email protected].
This policy (the “EU Privacy Policy”) explains the manner in which the Joint Data Controllers collect, utilize and maintain nonpublic personal information about investors and potential investors (“Investors”) based in the European Union (“EU”) or the European Economic Area (“EEA”), as required under the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This EU Privacy Policy applies to your investment or potential investment in the Fund and also applies to former Investors in the EU and the EEA.
The Joint Data Controllers collect Your Personal Information from the following sources, as applicable:
1. Subscription documents and other information provided by the Investor in writing, in person, by telephone, electronically or by any other means (this information includes (i) name, address, income, financial and investment qualifications, and tax-related information, birth date, nationality, passport or other identification number, and employment information);
2. Transactions within the Fund, including account balances, investments, redemptions and management fees and performance allocations; and
3. Other interactions with the Joint Data Controllers (for example, discussions with our staff).
Your Personal Information may be processed by the Joint Data Controllers and/or the Administrator (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes, as applicable:
1. to facilitate your investment in the Fund and the management and administration of your investment in the Fund on an ongoing basis (the “Services”) which are necessary to fulfill all contractual and regulatory obligations related to your investment in the Fund, including without limitation the acceptance and processing of subscription documents and redemption and transfer requests;
2. in order to carry out anti-money laundering checks and related actions that the Joint Data Controllers and/or Administrator consider appropriate or necessary to fulfill any of their legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with the Joint Data Controllers’ and the Administrator’s anti-money laundering policies and procedures;
3. to comply with their legal obligations and, in particular, to report tax-related information to tax authorities;
4. to disclose information to other third parties such as service providers of the Joint Data Controllers and/or Administrator (including, for example, attorneys, accountants, auditors, or other professionals), regulatory authorities and technology providers in order to comply with any legal obligation imposed on the Joint Data Controllers and/or Administrator or in order to pursue the legitimate interests of the Joint Data Controllers and/or Administrator;
5. to monitor and record electronic communications and if applicable, calls, for any of the purposes specified herein; and/or
6. to otherwise pursue the legitimate interests of the Joint Data Controllers and/or Administrator relating to your investment or your potential investment in the Fund, and/or where the processing of Your Personal Information would be in the public interest.
The Joint Data Controllers’ servers, which store and keep Your Personal Information, are located in the United States and elsewhere.
The Joint Data Controllers also have service providers whose personnel will have access to Your Personal Information and that are located in jurisdictions outside the United States. Transfers to these service providers are necessary for the performance of the contract between the Fund and the Investor. These jurisdictions either (i) afford an adequate level of protection for Your Personal Information (as declared by the European Commission) or, (ii) if they do not, then the Fund has entered into agreements with these service providers (which has been acknowledged by the Investment Manager) incorporating clauses that are the same or substantially similar to the standard contractual clauses, as well as other relevant provisions contained in the GDPR, and impose obligations no less onerous than those contained in this EU Privacy Policy.
The Joint Data Controllers and the Administrator are able to legally collect and use Your Personal Information either because:
1. you have consented to their doing so;
2. it is necessary for the performance of a contract to which the Investor is a party or in order to take steps at the request of the Investor prior to entering into a contract or to otherwise perform the Services;
3. collecting and using Your Personal Information is necessary for the Joint Data Controllers and/or the Administrator to fulfill their legitimate business interests, which may include to investigate, defend against, or prosecute any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum, or otherwise protect their legal rights; and/or
4. it is necessary to comply with any applicable regulatory, judicial or other legal obligations applicable to the Joint Data Controllers and the Administrator.
The Joint Data Controllers and the Administrator will retain Your Personal Information for the purposes described in 1, 2, and 3 in the immediately preceding paragraph for as long as required for the purposes described above.
In particular, and without limitation to the foregoing, the Joint Data Controllers and the Administrator have legal obligations imposed on them under applicable legal systems that require them to retain Your Personal Information for certain minimum time periods.
You have the right to:
1. be informed about Your Personal Information that the Joint Data Controllers and/or the Administrator collects from you, uses, and retains, which this EU Privacy Policy seeks to do;
2. obtain confirmation from the Joint Data Controllers that Your Personal Information is being collected, used, and retained as described above and to access Your Personal Information held by the Joint Data Controllers and/or the Administrator;
3. have Your Personal Information corrected if it is inaccurate or incomplete at any time;
4. erasure, or the right to be forgotten, which means you can request deletion or removal of any of Your Personal Information the Joint Data Controllers and/or the Administrator hold about you at any time, subject to the Joint Data Controllers’ or the Administrator’s rights to retain Your Personal Information as provided for under the GDPR;
5. block or suppress the Joint Data Controllers and/or the Administrator collecting and using Your Personal Information, which means the Joint Data Controllers and the Administrator can continue to store Your Personal Information but cannot further collect or use it in any way;
6. obtain and reuse any of Your Personal Information that the Joint Data Controllers and/or the Administrator hold about you for your own purposes across different services, which allows you to move, copy or transfer Your Personal Information easily from the Joint Data Controllers and/or the Administrator to another place identified by you to the Joint Data Controllers in a safe and secure way without hindrance to the usability of Your Personal Information;
7. object to the Joint Data Controllers and/or the Administrator collecting, using or retaining Your Personal Information where this is based on:
a. your legitimate interest or the performance of a task in the public interest; or
b. direct marketing even if otherwise legally permitted; and
8. withdraw your consent to the use of Your Personal Information at any time, as described below.
To make any requests as listed above, please contact the Investment Manager (acting for the Joint Data Controllers) at [email protected].
The Investment Manager (acting for the Joint Data Controllers) will respond to requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.
You can tell the Joint Data Controllers to stop collecting, using and retaining Your Personal Information at any time by emailing the Investment Manager (acting for the Joint Data Controllers) at [email protected]. You should note that notwithstanding your withdrawal of consent, the Joint Data Controllers and the Administrator may be legally required to retain some or all of Your Personal Information.
Where the Joint Data Controllers or the Administrator require Your Personal Information to comply with AML or other legal requirements, failure to provide this information will mean that you will be unable to be accepted as an investor in the Fund and/or may be mandatorily redeemed from the Fund if you are already an Investor.
The Joint Data Controllers maintains appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards that comply with the GDPR to protect customer information, including:
1. the pseudonymization and encryption of Your Personal Information where appropriate;
2. ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
3. ensuring the Joint Data Controllers can restore access to Your Personal Information in a timely manner if a physical or technical incident occurs; and
4. regular testing, assessment and evaluation of the effectiveness of its technical and organizational measures to attempt to ensure Your Personal Information is secure.
The Joint Data Controllers restrict access to the personal and account information of Investors to those employees who need to know that information in the course of their job responsibilities. The Joint Data Controllers will destroy, erase or make unreadable data, computer files and documents containing Your Personal Information that is non-public prior to disposal.
If you would like to make a complaint about the way the Joint Data Controllers have collected, used or retained Your Personal Information, please contact us at [email protected].
You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by the Joint Data Controllers or their service providers infringes the GDPR.
As noted above, this EU Privacy Policy also applies to former Investors in the EU and the EEA.
This EU Privacy Policy is in addition to the Investment Manager’s existing Privacy Policy adopted under US law, a copy of which is available from the Investment Manager or at https://www.eaglets.com. The Investment Manager reserves the right to change this EU Privacy Policy at any time and without prior notification. The examples contained within this EU Privacy Policy are illustrations and are not intended to be exclusive. This EU Privacy Policy complies with the GDPR regarding privacy. You may have additional rights under other foreign or domestic privacy laws in addition to those that are described above. If you have any questions about this EU Privacy Policy, please call +1-609-688-2060 or email us at [email protected]. Other than as described above, no further action is required on your part.
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