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.
PRIVACY NOTICE supplement FOR CALIFORNIA RESIDENTS
Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:
- name, date of birth and birth place;
- contact details and professional address (including physical address, email address and telephone number);
- account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly);
- information regarding your use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history);
- risk tolerance, transaction history, investment experience and investment activity;
- information regarding investors’ status under various laws and regulations, including social security number, tax status, income and assets;
- accounts and transactions with other institutions;
- information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses;
- information regarding citizenship and location of residence;
- source of funds used to make the investment in the applicable fund(s); and
- anti-money laundering, identification (including passport and drivers’ license) and verification documentation.
Purposes for Collecting Personal Information: We may collect or share the personal information we collect about you for one or more of the following business or commercial purposes:
- performing services to you, including but not limited to:
- the administrative processes (and related communication) in preparing for the admission of investors to the fund(s);
- ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund;
- the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
- ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
- keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
- auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
- detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and
- complying with U.S., state, local and non-U.S. laws, rules and regulations.
We do not sell any of the personal information we collect about you to third parties.
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting such personal information;
- Categories of third parties with whom we share the personal information;
- The specific pieces of personal information we have collected about you; and
- Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, please submit a request using any of the methods set forth below.
- Call us at the following number: (646) 494-0202.
- Submit a request online using the following online form: https://www.inherentgroup.com/contact/.
- Email us at: info [at sign] inherentgroup.com.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline.
© 2018-2020 Inherent Group, LP. All rights reserved.