Inherent Group, LP (“Inherent“) is committed to protecting and respecting your privacy. This privacy statement sets out the basis on which we will process any personal information that we may collect about you as a visitor to our website or through contact with one of our employees or business partners.
The information published on our website is provided as a convenience to visitors and is for informational purposes only. It is not a solicitation or offer to sell investment advisory services or any security. No service, security or other product is or will be offered or sold in any jurisdiction in which such offer or sale would be unlawful under the securities laws, or other laws, of the jurisdiction. Past performance may not be indicative of future results.
We may collect and process the following information about you:
- Information that you give us: This is information about you that you give to us by filling in forms on our website (or other forms that we ask you to complete), giving us a business card or other contact information, or corresponding with us by telephone, post, email or otherwise. It may include, for example, your name, address, email address and telephone number; financial status (assets and income); investment objectives; prior investment experience with different types of investment vehicles; and information about your professional role, background and interests.
- Information that our website and other systems collect about you: When you visit our website it may automatically collect some information about you and your visit, including the internet protocol (IP) address used to connect your device to the internet and some other information such as your browser type and version and the pages on our site that you visit. If you exchange emails or have telephone conversations or other electronic communications with our employees and other staff members, our information technology systems may record details of those communications, sometimes including their content.
- Other information: We may also collect some information from other sources. For example:
- If we have a business relationship with the organization that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship.
- We sometimes collect information from third party data providers or publicly available sources for anti-money-laundering, due diligence and similar purposes, and to protect our business and comply with our legal and regulatory obligations.
We may use your information for the following purposes:
- to operate, administer and improve our website and other aspects of the way in which we conduct our operations;
- to comply with our legal and regulatory obligations and bring and defend legal claims;
- to operate, manage, develop and promote our business and, in particular, our relationship with you or the organization you represent (if any) and related transactions – including for marketing purposes; and
- to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes.
We may from time to time review information about you held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or governmental investigations. To the extent permitted by applicable law these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management.
When we collect personal data from you, we will tell you if:
- provision of the requested information is necessary for compliance with a legal obligation; or
- it is purely voluntary and there will be no implications if you decline to provide us with it.
Unless otherwise indicated, you should assume that we require the information for business and/or compliance purposes and then only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes. To the extent that we do rely on consent to process your personal data, we will contact you to obtain this consent. You have the right to withdraw this consent at any time.
If you are uncertain as to Inherent’s need for information that we request from you, please contact us (see below), with your query.
We may disclose personal data about you where we have obtained your consent or where it is reasonably necessary for the various purposes set out above:
- to your colleagues within the organization that you represent;
- to service providers who host our website or other information technology systems or otherwise hold or process your information on our behalf, under appropriate conditions of confidentiality and security;
- to a person who takes over our business and assets, or relevant parts of them; or
- in exceptional circumstances:
- to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
- where we are required by law to disclose.
Your emails and other communications may also occasionally be accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left Inherent).
We keep your personal data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or as is required by law or regulatory obligations which apply to us. We will delete the information that we hold about you when we no longer need it. We will generally retain your data for no longer than six years after our most recent communication with you, after which it will be deleted or anonymized.
Note that we may retain some limited information about you even when we know that you have left the organization that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organization.
Please contact us for more information or if you have questions.
You may have certain rights under data protection law, including:
- the right to direct us not to disclose nonpublic personal information to a nonaffiliated third party;
- the right to access your personal data;
- the right to restrict the use of your personal data;
- the right to have incomplete or inaccurate data corrected;
- the right to ask us to stop processing your personal data;
- the right to request for us to “port” your personal data in a portable, re-usable format to other organizations, where applicable and possible; and
- the right to require us to delete your personal data in some limited circumstances.
If you would like to exercise any of these rights, you must provide a written statement exercising that right. Please contact us as set out below.
VII. Contact us
If you have any questions or concerns regarding the processing of personal data, please contact Michael Ellis (Chief Compliance Officer) at the following address: 510 LaGuardia Place, 5th Floor, New York, NY 10012, United States or by sending an email to michael [at sign] inherentgroup.com.
© 2018 Inherent Group, LP. All rights reserved.