Your privacy is very important to us.
Last Updated: March 10, 2022
Investor Privacy Notice – Federal Financial Privacy Law
Federal law gives consumers certain rights to know about the collection of nonpublic personal information by financial institutions and, in some cases, gives consumers the right to direct financial institutions not to share such information. In this context, a “consumer” is an individual who obtains, from a financial institution, financial products or services that are to be used primarily for personal, family, or household purposes. Please read this Investor Privacy Notice carefully to understand what we do.
This Investor Privacy Notice includes required disclosures under federal financial privacy law with respect to consumers, which for our business includes investors, prospective investors and former investors (referred to herein as “you” and “investors”) in our funds (the “Funds”). These policies apply to investors who are U.S. residents only. If we change our policies in this regard, we will update these disclosures.
Nonpublic Personal Information We Collect
The types of nonpublic personal information we collect and share depends upon how you interact with us and the investments or services you obtain or seek to obtain from us. The information we collect can include your address, social security number, assets and/or income information. We may collect such information from a variety of sources, including (i) from the Subscription Agreements and related documents, (ii from your correspondence and conversations with the Funds’ representatives and (iii) through transactions in the Funds.
Sharing of Nonpublic Personal Information
We make limited disclosures of investors’ nonpublic personal information:
- For our business purposes, such as to process your transactions, maintain your accounts, report to credit bureaus or make other legally-required disclosures, such as may be to fulfill requirements under anti-money laundering laws. We will also release information about you if you direct us to do so, if compelled to do so by law or in connection with any government or self-regulatory organization request or investigation.
- For our marketing purposes, including to companies that perform marketing services on our behalf, such as placement agents.
- To our affiliates, for their everyday business purposes. In particular, information may be shared with our funds for those who wish to invest in those funds.
An “affiliate” is defined as a company that is related by common ownership or control. The affiliates mentioned in this Investor Privacy Notice are Haidar Jupiter International Ltd. and Haidar Jupiter Fund LLC. We do not share nonpublic information with nonaffiliated third parties. We do not share personal information with affiliates to market to you.
Protection of Nonpublic Personal Information
We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information. Those safeguards include, without limitation, restricting access to nonpublic personal information about you to those employees and other persons who need to know the information to enable the Funds to provide services to you. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security. If you have any questions regarding this Investor Privacy Notice or how we collect, use or disclose your nonpublic personal information, please contact us at email@example.com for more information.
U.S. Privacy Notice
This U.S. Privacy Notice (the “U.S. Notice”) concerns the Personal Information we may collect when you visit our website (the “Site”) and when we obtain your Personal Information from third parties or other sources for marketing or other outreach purposes. It does not apply to the nonpublic personal information covered by our Investor Privacy Notice. We describe below our practices with respect to the collection, use, and sharing of such information. We also describe the rights California residents may have with respect to Personal Information we collect.
By accessing the Site and using our services, you agree to our collection and use of Personal Information as described herein.
For purposes of this U.S. Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.
Personal Information We Collect and Have Collected in the Past 12 Months – Sources and Categories
In the 12 months preceding the date of this Policy, we may have collected your Personal Information when you visited our Site or when you submitted our online Contact form. We also collected Personal Information from third parties for marketing purposes. We will continue to collect Personal Information from the same sources.
- Personal identifiers: Name, email address, mailing address, IP address or other unique identifier.
- Commercial information: Including investment information and other account information
- Internet or other electronic activity information: Device and browser type, your browsing and search history on our Site, and information regarding your interaction with our Site and our advertisements.
Purposes for Collection of Personal Information
We use the Personal Information to provide you with news and other information about the Company, for marketing purposes, and to monitor or improve our Site; for internal business analysis; to prevent fraud, activities that violate our Terms of Service or that are illegal; and to protect our rights and the rights and safety of our users or others.
Disclosure of Personal Information For Business Purposes in the Past 12 Months
The following chart describes the categories of Personal Information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Policy:
|Categories of Consumers’ Personal Information||Categories of Third Parties With Which We Shared Personal Information for a Business Purpose|
|Personal identifiers: Name, address, email address, IP address or other unique identifier, and other similar information.||Service providers, including those that provide customer relationship management (CRM) or fund administrator services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; market our company or Funds.|
|Commercial information: Including investment information and other account information||Service providers, including those that provide customer relationship management (CRM) or fund administrator services;|
|Internet or other electronic network activity information: Device and browser type, browsing and search history on our Site, and information regarding interaction with our Site and our advertisements.||Service providers that provide data security services and cloud-based data storage; host our Site and assist with other IT-related functions; provide website hosting, webcast and teleconference services; market our company or Funds; and provide analytics information.|
Additional Information About How We May Share Personal Information
We may also share your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your Personal Information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may transfer your Personal Information to a third party in the event of an actual or contemplated sale, merger, reorganization of our entity or other restructuring.
We do not sell your Personal Information.
Cookies and Other Tracking Technologies
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
Personal Information of Minors
Our products and services are not directed to minors under the age of 13.
Third Party Websites
Our Site contains social media buttons and may contain links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on the social media platforms with buttons on our Site or any third-party websites. The privacy policies of those platforms and websites govern how they collect, use and otherwise process your Personal Information.
How We Keep Your Personal Information Secure
We implement and maintain reasonable security measures appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Personal Information. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.
California Privacy Rights
If you are a California resident, you may have separate rights regarding your Personal Information, in accordance with California law.
California Consumer Privacy Act
The California Consumer Privacy Act (CCPA) gives California residents rights described below with respect to their Personal Information.
Your Right To Request Disclosure of Information We Collect and Share About You
We are committed to ensuring that you know what Personal Information we collect. To that end, you can ask us for any or all of following types of information regarding the Personal Information we have collected about you in the 12 months prior to our receipt of your request:
- Specific pieces of Personal Information we have collected about you;
- Categories of Personal Information we have collected about you;
- Categories of sources from which such Personal Information was collected;
- Categories of Personal Information that the business sold or disclosed for a business purpose about the consumer;
- Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling your Personal Information.
Your Right To Request Deletion of Personal Information We Have Collected About You
Upon your request, we will delete the Personal Information we have collected about you, except for situations where the CCPA authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us. We will act on your deletion request within the timeframes set forth below.
Exercising Your Rights and How We Will Respond
To exercise any of the rights above, or to ask a question, contact us at +1 212 752 4936, or email us at firstname.lastname@example.org.
For requests for access or deletion, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Our Commitment to Non-Discrimination
If you exercise any of the rights explained in this Policy, we will continue to treat you fairly and will not penalize you in any regard.
Verification of Identity – Access or Deletion Requests
We will ask you for identifying information and attempt to match it to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial.
You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State.
If you would like to designate an agent to act on your behalf, and the agent submits requests to access, know or delete your Personal Information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
Requests for Household Information
There may be some types of Personal Information that can be associated with a household (a group of people living together in a single dwelling). Requests for access or deletion of household Personal Information must be made by each member of the household. To the extent we collect household information and requests are made pertaining specifically to such information, before responding to a request, we will verify the identity of each member of the household using the verification criteria explained above and will also verify that each household member is currently a member of the household.
California Do Not Track
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, our Site do not respond to browsers’ do not track signals.
Changes to This Policy
We will review and update this Policy periodically. We will notify you of material changes to it by posting on our Site notification that the Policy has been updated and by updating the date of the Policy.
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at email@example.com.
If there are any questions regarding this Policy or to request a copy of this Policy in another format you may contact us at:
One Blue Hill Plaza,
Floor 16, Suite 2L153
Pearl River, NY 10965
+1 212 752 4936