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Privacy Notice

Rosemawr Management LLC – Privacy Notice

Last updated January 4, 2021

IntroductionYour privacy is very important to us. Rosemawr Management LLC (“Rosemawr Management”) recognizes the importance of protecting your privacy and is committed to protecting your personal data. This notice (this “Privacy Notice”) is provided by Rosemawr Management and each investment account or pooled investment vehicle advised or managed by Rosemawr Management (each a “Fund”, and together with Rosemawr Management “we” or “us”), and sets forth the policies of Rosemawr Management and the Funds for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data through the use of this website, or otherwise, including any data you may provide when you enter into a transaction with us. This Privacy Notice is being provided in accordance with the requirements of data privacy laws, including the EU General Data Protection Regulation 2016/679 (“GDPR”), the US Gramm-Leach-Bliley Act of 1999 as amended, the Cayman Data Protection Law 2017, or any other law relating to privacy or the processing of personal data and any statutory instrument, order, rule or regulation implemented thereunder, each as applicable to Rosemawr Management and the Funds (collectively, “Data Protection Law”) References to “you” or a “user” or an “investor” in this Privacy Notice mean any user who is an individual and who is a legal person (each such individual, a “data subject”), as applicable.

California residents should also review our California Privacy Notice.

The types of personal data we may collect and useThe categories of personal data we may collect on this website include names, residential addresses, phone numbers, email addresses, or other contact details. Rosemawr Management may also collect from users - signatures, nationality, tax identification number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds details or other sensitive information, such as certain special categories of data contained in the relevant materials or documents.

How we collect personal dataWe may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us; and (iii) recording and monitoring of telephone conversations and electronic communications with you as described below.

We also may receive your personal information from third parties or other sources, such as our affiliates, our administrator, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

Using your personal data: the legal basis and purposesWe may process your personal data for the purposes of administering the relationship between you and us (including communications and reporting), direct marketing of our products and services, monitoring and analyzing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities, or law enforcement agencies, with competent jurisdiction over our business). Your personal data will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so.

Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How we may share your personal dataWe may disclose information about you to our affiliates or third parties, for our everyday business purposes, such as to facilitate transactions, maintain your account(s) or respond to court orders and legal investigations. We will also release information about you if you direct us to do so.

We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at (212) 286-9474. If you are a new user, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our user, we may continue to share your information with our affiliates for such purposes. We may also disclose information about your experiences with us to our affiliates for their everyday business purposes. We do not share your information with non-affiliates for them to market their own services to you.

Monitoring of communicationsWe may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.

Retention periods and security measuresWe will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Law. Personal data will be retained for the duration of your investment in a Fund and for a minimum period of five to seven years after a redemption or withdrawal, as applicable, of an investment from a Fund or liquidation of a Fund. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with Data Protection Law. These measures include computer safeguards and secured files and buildings. We will notify you of any material personal data breaches affecting you in accordance with the requirements of Data Protection Law.

International transfersBecause of the international nature of a fund management business, personal data may be transferred to countries outside the EEA (“Third Countries”), such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the Data Protection Law in the EEA. In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of the Data Protection Law, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries. We may also be required to transfer your personal information to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.

Your rights under Data Protection LawData subjects have certain rights under Data Protection Law in relation to our processing of their personal data and these may include: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of direct marketing activities); (vi) where relevant, the right to request the portability; (vii) where your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. You should note that your right to be forgotten that applies in certain circumstances under GDPR is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above.

You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. US state laws may give you additional rights to limit sharing.

CookiesCookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.

We may use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need.

This site uses Google Analytics cookies, a web analytics service provided by Google, which sets a cookie in order to understand how you use and interact with this website and to compile meaningful site traffic reports. More information on how Google Analytics uses cookies can be found at http://code.google.com/apis/analytics/docs/concepts/gaConceptsCookies.html

Third-party linksThis website may include links to other sites operated by third parties. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Who to contact about this Privacy Notice
Please contact Rosemawr Management by telephone at (212) 286-9474 or by email at info@rosemawr.com or by writing to 810 Seventh Avenue, 27th Floor, New York, NY 10019 for any questions about this Privacy Notice or requests with regards to the personal data we hold.

Privacy Notice For California ConsumersThis notice contains disclosures required by the California Consumer Privacy Act (“CCPA”), is only relevant to residents of California, and applies only to the collection or other use of “personal information” that is subject to the CCPA.

Information We Collect. In the past 12 months, we have collected the following categories of personal information about California consumers: A real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, or other similar personal identifiers, a signature, physical characteristics or description, telephone number, education, employment, employment history, bank account number, any other financial information, age, citizenship.

Use of Personal Information. We may use the personal information we collect for one or more of the following purposes:

• Providing you with information about our products and services;
• Providing performance and other updates;
• One or more of the following business purposes:
• Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
• Auditing related to our interactions with you (e.g., counting ad impressions to unique visitors, verifying positioning/quality of ad impressions, and auditing compliance, etc.);
• Legal compliance;
• Detecting and protecting against security incidents, fraud, and illegal activity;
• Internal operations;
• Activities to maintain and improve our services; and
• Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer.

Sharing Personal Information. We may disclose personal information in one or more of the categories identified above to:

• Service providers, including but not limited to: administrators, auditors, law firms, consultants;
• Affiliates;
• Business partners;
• Legal or government regulatory authorities as required by applicable law; and
• In connection with a potential business transfer.

In the past 12 months, we have not sold any personal information (including any information about minors under 16 years of age) we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

Rights of California Consumers. The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:

• The right to request (a) the categories and specific pieces of personal information we collect, use, disclose, and sell about you, (b) the categories of sources from which we collected your personal information, (c) our purposes for collecting or selling your personal information, (d) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we have shared personal information;
• For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties;
• The right to request that we delete the personal information we have collected from you or maintain about you;
• The right to opt out of our sale(s) (if any) of your personal information; and
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
• You may submit requests relating to your exercise of rights under the CCPA to us: via phone at (212) 286-9474; or via email to info@rosemawr.com .

We may need to request additional information from you to verify your identity or understand the scope of your request. In verifying requests, we will require you to provide, at a minimum your name and email address. If we are unable to verify your identity, we will need to deny your request.

You may designate an authorized agent to make a CCPA request on your behalf by mailing two forms of identification showing your first name, last name, and current address, and a signed authorization allowing an agent to request information on your behalf.