Privacy Policy
Revised: April 2024
Introduction
MultiAlpha Portfolio Fund Ltd SAC (“MultiAlpha”, “Fund”, “us”, “we” or “our”) values the privacy and security of information about MultiAlpha's clients and potential investors. MultiAlpha may collect and retain certain information in order to provide a variety of financial products to our customers. In this privacy policy ("Policy"), we describe how MultiAlpha collects, uses, and discloses information collected by MultiAlpha on this website (the "Site").
As discussed below in the section titled Cross-border transfer of information, information that we collect may be transferred to and processed in the Bahamas, Switzerland or another jurisdiction outside your country of residence, which may have less stringent data protection laws than in your country of residence.
Information collection
MultiAlpha collects and processes both Personal Data and Other Data. For purposes of this Policy, "Personal Data" is any information that alone or together with other information in MultiAlpha's possession relates to an identified or identifiable natural person, such as name, phone number, email address, financial account information, and online identifiers and account information such as user name and password. "Other Data" is any additional information that is not Personal Data. In this section, we describe our information-collection practices, including the types of Personal and Other Data that we collect. In subsequent sections of this Policy, we describe how we use and disclose Personal and Other Data.
We may combine the Personal and Other Data we collect directly from you with information collected from or about you in other contexts, such as on the Site. This may include information collected online, such as through our email exchanges with you; from publicly available sources, such as your company website if you are a financial adviser; from the registrar for our exchange-traded funds so that we can provide information about products or services that may be of benefit; or from offline sources, such as information that we collect when you establish your account with us or call customer service. We will treat such combined information in accordance with this Policy. If you do not wish to provide information to MultiAlpha, we may be unable to provide certain products or services to you.
What Personal Data do we collect?
MultiAlpha may collect the following Personal Data from or about you:
Personal Data we collect directly from you, such as when you request information from us, invest with us, or register to use the Site: MultiAlpha collects and maintains Personal Data about you, and about any person or entity on whose behalf you are acting, that you provide to us, such as when you obtain a product or service from MultiAlpha, request information or materials from us, register to use the Site, or otherwise interact with us or our Site. The types of Personal Data we collect vary based on your particular interaction with us, but could include:
Your name, company name, and primary role or title;
Postal mailing address;
Telephone and fax numbers;
Email address;
Account number and other account information;
Username, password, and other security credentials; and
Other information you provide to us directly, such as information collected for identification or authentication purposes.
Personal Data for your account: Depending on the type of investment in the Fund, and to the extent permitted by law, we may collect the following Personal Data from you when you invest in shares of the Fund, establish a business relationship with MultiAlpha on behalf of yourself or another individual or entity:
Full name, date of birth, gender, and contact details, including mailing address, email address, and telephone and fax numbers;
Tax identification number/national insurance number, and bank account and payment method details, if such information is needed for the purpose of administering your accounts;
Employment details, which may include annual salary;
Contribution amounts and investment choices;
Details about authorised signatories, agents, or representatives;
Copies of any relevant legal documents;
Details of services you are interested in and about your investment needs;
Information about employees, agents, or other representatives of a client or prospective client, if such information is needed to open or maintain an account; and
Other information that you provide to us in connection with your account.
We also may collect Personal Data for your account from third parties authorised to disclose your Personal Data, such as from companies that provide identification verification services.
Information about third parties: We may collect information from you regarding other individuals related to your account. Where you disclose information about authorised signatories, dependents, relatives, potential beneficiaries, employees, agents, or other representatives as outlined above, you warrant that you will only do so in accordance with applicable data protection laws; that you will ensure that before doing so, the individuals in question are provided with a copy of this Policy and made aware of the fact that MultiAlpha will hold information relating to them and may use it for any of the purposes set out in this Policy; and where necessary that you will obtain the other individuals’ consent to MultiAlpha’s collection, use, and disclosure of their information as described in this Policy. MultiAlpha may, where required under applicable law, notify those individuals that they have been provided with their Personal Data and provide a copy of this Policy to them.
Information from telephone, email, online chat, or text message communications with MultiAlpha: If you communicate with MultiAlpha by telephone, email, online chat, or text message, MultiAlpha may keep a record of that communication. In accordance with applicable law, MultiAlpha also may (after according prior announcement and, if required, your consent each via phone) record and monitor telephone calls for training, quality assurance, security, and customer service purposes.
Information contained in surveys: MultiAlpha may ask you to complete surveys for research and client satisfaction assessment or similar client service-related purposes. You are not required to respond to those surveys, and any information collected by MultiAlpha or on MultiAlpha's behalf that you provide in response to those surveys is at your discretion.
What Other Data do we collect automatically?
Where you have consented, we may collect data about you on our Site and through emails that we send to you, including whether you click on links in our emails. We use a variety of technologies, such as cookies, web beacons, and similar mechanisms, as described further in our cookie policy.
We may combine Other Data with additional information that we have collected about you, including, where applicable, your name and other Personal Data. When we combine Other Data with Personal Data, we treat all of the combined information as Personal Data. If you have registered for secure access on our Site, we are able to combine the information we collect about your usage of our Site during a secure (logged-on) session with other information we know about you, such as any searches you conduct or information you request during your web session. We can also identify your computer or device on each visit to our Site, even if you do not log on, and determine whether you came to our Site by clicking on an email link. This enables us to link information about your Site visits, as well as about MultiAlpha ads that you may have viewed on other websites, to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our Site and the effectiveness of our email communications and online advertising, as well as to identify MultiAlpha products and services that may be of interest to you. For more information about how we and our service providers use information for analytics and advertising purposes, please see the section below titled please see the section in our cookie policy titled: What cookies do we use and why?
Use, legal basis, and disclosure
How do we use Personal and Other Data?
We use the Personal and Other Data that we collect for the purposes described in this Policy, for the purposes for which it was provided to us, as required by law, and for our business purposes, including:
To establish and administer accounts and your relationship with us, to fulfil the terms of any agreement you have with us, and to otherwise provide MultiAlpha's products and services to you;
To communicate with you, notify you about important updates or changes to MultiAlpha's products and services, and address relevant inquiries or complaints;
To comply with our legal obligations and protect our legal rights, including, without limitation, to comply with record-keeping, reporting, and tax obligations under applicable law (such as corporations, tax, managed investments or securities, and anti-money laundering laws);
For marketing and promotional purposes, in accordance with applicable law. For example, as permitted by applicable law, we will use your Personal Data, such as your email address, to send you news and newsletters, or to otherwise contact you about MultiAlpha products or information we think may be of interest to you. Although we hope you will find our promotional communications of interest, you may opt out of receiving them by following the "unsubscribe" instructions at the bottom of each communication;
To create new products and services or improve our existing products and services;
To tailor the content, information, and advertising that we may send or display to you, including as discussed in the section below titled Website analytics and Interest-Based Advertising, to offer location customisation and personalised help and instructions, and to otherwise personalise your experiences with MultiAlpha and while using the Site;
To count and recognise visitors to the Site and various Site features and better understand how users access and use our Site and MultiAlpha products and services;
To support Site performance, perform Site analytics, enhance Site navigation, and improve our web design and functionality; and
For other research and analytical purposes
Legal bases for using Personal Data
We will only collect, use, and share your Personal Data where we are satisfied that we have an appropriate legal basis to do this. This may be because:
Our processing of your Personal Data is necessary to perform a contract with you or take steps to enter into a contract with you, for example where we use your contact, demographic, and banking information required to establish and fund your account in the performance of our services;
Our processing of your Personal Data is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to undertake vetting to comply with anti-money laundering legislation or where we are required to disclose Personal Data to a court or tax authority);
You have provided your consent to a certain processing of your Personal Data, (for example in relation to our use of targeting cookies on the Site); and/or
Our processing of your Personal Data is covered by an overriding legitimate interest, (for example in order to make improvements to our products and services and to provide you with information you request); in these cases we will process your Personal Data at all times in a way that is proportionate and respects your privacy rights, and you have a right to object to this processing as explained in the section below titled “Your legal rights”.
If you would like to find out more about the legal bases on which we process Personal Data, please contact us using the details below.
To whom do we disclose Personal and Other Data?
We may disclose Personal and Other Data to third parties for the following purposes, as permitted by law. You have certain rights to object to the processing of your Personal Data as described below:
Affiliates: We disclose Personal and Other Data to MultiAlpha Affiliates for the purposes described in this Policy. MultiAlpha Affiliates may contact you by email, to make you aware of MultiAlpha's product and service offerings (each provided you consented to the reception of such emails or, if you did not object to such emails, you previously acquired products or services from us indicating your interest to receive them as well).
Service providers: We may disclose Personal and Other Data to our service providers, who use it to perform tasks on MultiAlpha's behalf. Among other things, these service providers help us provide MultiAlpha products and services, send disclosures and statements to you, administer your accounts, and manage and improve the Site. Our service providers may collect, process, and retain information about you, in accordance with the laws of your country, directly on behalf of MultiAlpha. MultiAlpha's service providers include:
Any organisation involved in providing, managing, or administering the Site, related systems, or other MultiAlpha services, such as fund administrators, directors, corporate officers, administrators, mail houses, email senders and providers, technology service providers, and third parties that provide analytics and advertising services as described in the section below titled “Website analytics and Interest-Based Advertising”; and
MultiAlpha's auditors, consultants, legal advisers, and other professional advisers.
Customer agents: Where covered by a legal basis for such processing, we may disclose Personal Data to your agents or representatives, including:
Your legal or other professional adviser(s);
Any administrator or trustee for a fund or trust to which your investment balance is to be transferred or rolled over;
Your legal representative or attorney; and
Other financial institutions that hold an account in your name or on which you are authorised to act, for example, where amounts have been transferred to or from that account.
Legal purposes: We may use and disclose your Personal Data as far as this is necessary to protect the rights and property of MultiAlpha and MultiAlpha Affiliates, including to establish legal claims or defences, to obtain legal advice, to defend our legal rights, to protect our rights or property and those of MultiAlpha Affiliates, to protect against fraud and abuse, to protect other users of our services and our Site, and to protect the life, body, or property of others (individuals or entities). We also may disclose information about you in order to comply with the law, judicial proceeding, court order, or other legal process, such as in response to a court order or subpoena. We may disclose information to authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to your account or any other account on which you are authorised to act.
Sale or other transfer of the company: We reserve the right to disclose information to facilitate the licensing, merger, sale, assignment, acquisition, financing, securitisation, insuring, bankruptcy, or other transfer of our technology or business, or a portion thereof, to third parties, in accordance with applicable law.
Market research: We provide information to market research companies or MultiAlpha Affiliates for the purpose of assessing information about our business or client base. We may provide our clients' or prospective clients' contact details to market research companies to undertake research on behalf of MultiAlpha, in accordance with applicable law. For example, we may run client satisfaction surveys or run focus groups on proposed products. Any Personal Data processed for market research is deleted as soon as it is no longer required, i.e. upon termination of the market research study/studies for which such data was collected or, if earlier, you objected to the processing of your Personal Data for such purpose.
Direct sharing through third-party websites and services: The Site in the future may enable you to share information directly with websites or online services operated by third parties. For example, the Site contains features that allow you to share articles or content through Facebook, Google Plus, Twitter, LinkedIn, and other services, and to view content through video players and other services (such as the YouTube video player). If you choose to use these features, you may disclose information to those websites or services and their users, and to the public more generally. These websites and services may also set and/or access a cookie on your device.
Competitions, contests, and promotions: MultiAlpha may use an agency to run competitions, contests, or promotions on the Site or elsewhere, and if you choose to participate, we or third parties may request your name, address, telephone number, email address, and other information where it is necessary to ensure your eligibility and to comply with lottery and gaming regulations. In compliance with the relevant regulations, it may also be necessary to publish details of the winners of competitions in appropriate news media.
Aggregated information: From time to time, MultiAlpha may share aggregated information about users of the Site or MultiAlpha's products and services, such as sharing reports on the usage of the Site or MultiAlpha's services for regulatory reporting or marketing purposes.
Cross-border data transfer
MultiAlpha generally maintains servers and systems in the Bahamas/Switzerland as well as in the United States. These servers and systems are managed by or on behalf of MultiAlpha. MultiAlpha also may subcontract the processing of your information to, or otherwise share your information with, other third parties in the United States or countries other than your country of residence, including to MultiAlpha Affiliates for the following purposes: staff administration; management of employment relationship; recruitment; management of commercial relationship with business partners and customers; advertising, marketing and public relations; accounts and records; research and compliance with financial regulations.
Such transfers occur only when we are satisfied that we have an appropriate legal basis to do so, meaning that our transfer and use of your Personal Data is necessary to perform a contract or take steps to enter into a contract with you; our transfer and use of your Personal Data is necessary to comply with a relevant legal or regulatory obligation that we have; you have provided your consent to our using the Personal Data; and/or our transfer and use of your Personal Data is in our legitimate interest as a commercial organisation MultiAlpha will only transfer personal information outside the Bahamas/Switzerland where it is necessary and proportionate to do so and in limited circumstances.
Where the Personal and Other Data that we collect is transferred to and processed in the United States or anywhere else outside the Bahamas/Switzerland for the purposes described above, we will take steps to ensure that the information receives the equivalent level of protection as if it remained within the Bahamas/Switzerland, including entering into data transfer agreements, using the approved Standard Contractual Clauses (controller to controller and controller to processor). You may have a right to details of the mechanisms under which your data may be transferred outside the Bahamas/Switzerland.
Personal Data quality
MultiAlpha relies on the accuracy of the information provided by its clients and others. We take reasonable efforts to ensure that Personal Data collected by us or on our behalf is accurate, up to date, and complete, in accordance with applicable law. If any information about you changes or you have any concerns regarding the accuracy of information about you held by MultiAlpha, you should contact us at the address provided in the Contact us section below.
Information security
We use commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Data from loss, misuse, and unauthorised access, disclosure, alteration, and destruction in accordance with applicable law. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time. If you have online account access, we recommend that you take steps to protect against unauthorised access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your username and password private.
The Site may contain links to sites operated by partner networks, advertisers, and other companies not affiliated with MultiAlpha. MultiAlpha does not sponsor or endorse the linked sites, or any products or services offered by them. If you follow a link to any of these sites, you’ll be subject to the site’s privacy policy, which you should read and understand before using the site or its products or services.
Retention
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers for legal and regulatory purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your Personal Data:
Right to access Personal Data
You have a right to request that we provide you with a copy of your Personal Data that we hold, and you have the right to be informed of:
the source of your Personal Data;
the purposes, legal basis, and methods of processing;
the data controller’s identity; and
the entities or categories of entities to whom your Personal Data may be transferred.
Right to rectify or erase Personal Data
You have a right to request that we rectify inaccurate Personal Data. We may seek to verify the accuracy of the Personal Data before rectifying it.
You can also request that we erase your Personal Data in limited circumstances where:
it is no longer needed for the purposes for which it was collected; or
you have withdrawn your consent (where the data processing was based on consent); or
following a successful right to object (see Right to object below); or
it has been processed unlawfully; or
to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase Personal Data if the processing of your
Personal Data is necessary:
for compliance with a legal obligation; or
for the establishment, exercise, or defence of legal claims.
Right to restrict the processing of your Personal Data
You can ask us to restrict your Personal Data, but only where:
its accuracy is contested, to allow us to verify its accuracy; or
the processing is unlawful, but you do not want it erased; or
it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend legal claims; or
you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your Personal Data following a request for restriction:
where we have your consent; or to establish, exercise, or defend legal claims; or
to protect the rights of another natural or legal person.
Right to transfer your Personal Data
You can ask us to provide your Personal Data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
the processing is based on your consent or on the performance of a contract with you; and
the processing is carried out by automated means.
Right to object to the processing of your Personal Data
You can object to any processing of your Personal Data which has our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your Personal Data for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your Personal Data to unaffiliated third parties for the purposes of direct marketing or any other purposes.
If you would like MultiAlpha to stop sending promotional communications to your email address, you may opt out of receiving them by following the "unsubscribe" instructions at the bottom of each communication.
You may opt out of the use of your information for website analytics and online interest-based advertising by following the respective steps detailed above in the section titled Website analytics and Interest-Based Advertising.
Right to obtain a copy of Personal Data safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Data is transferred outside of the Bahamas/Switzerland.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with the data protection authority
You also have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
If you would like to exercise any of the rights described above, please send us a request at the address or email provided in the investor documentation. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Children's privacy
The Site is not directed to children under the age of 18, and MultiAlpha does not collect information from anyone it knows is under the age of 18. We recommend that persons under 18 years of age ask their parents for permission before using the Site or sending any information about themselves to anyone over the Internet.
Contact us
If you have any questions relating to this Policy, or concerns about the way in which we have handled information about you, please do not hesitate to contact us.
If you raise concerns about how we have handled your Personal Data, we may request additional details from you regarding your concerns, and we may engage or consult with other parties in order to investigate and resolve your issue. We will keep records of your request and any resolution of your issue.
Changes to this Policy
We will post changes to this Policy on our Site along with the effective date of the changed policy. We recommend that you review this Policy periodically. If we make a material change to this Policy, you will be provided with appropriate notice.
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