Paloma Partners, a prominent investment management firm, prioritizes the privacy of its investors. This comprehensive guide delves into Paloma Partners’ privacy notice, outlining their policies for collecting, using, and safeguarding personal data. Understanding these practices is crucial for current, prospective, and former investors in Paloma Funds.
Data Collection and Usage by Paloma Partners
Paloma Partners collects various types of personal data for account registration, management, regulatory compliance, and service optimization. This includes:
- Identity and Contact Information: Name, address, contact details, nationality, passport number, tax ID, date and place of birth, photo ID, and government-issued identification documents.
- Financial Information: Bank account details, account balances, transaction information, asset details, net worth, credit history, and source of funds.
- Demographic Information: Age and location.
- Website Usage Data: Browser type, operating system, IP address, domain name, click activity, referring website, and date/time stamp. This data is collected through web logs and first-party cookies.
Alt text: An image showcasing the modern and spacious office of Paloma Partners in Greenwich, Connecticut.
How Paloma Partners Gathers Personal Data
Paloma Partners collects personal data through various channels:
- Directly from Investors: Information provided during the subscription process.
- Transaction Records: Data obtained from transactions between Paloma Partners and investors.
- Electronic Communications: Information exchanged through emails and other electronic platforms.
- Third-Party Sources: Data received from affiliates, administrators, publicly accessible databases, tax authorities, government agencies, credit agencies, and fraud prevention agencies.
Sharing of Personal Data by Paloma Partners
Paloma Partners adheres to strict data sharing practices in compliance with data protection laws. Data sharing occurs in the following instances:
- Everyday Business Operations: Processing transactions, maintaining accounts, responding to legal investigations, and reporting to credit bureaus.
- Marketing Purposes: Offering products and services (investors can sometimes limit this sharing).
- Affiliate Sharing: Sharing information about transactions and experiences with affiliates for business purposes (investors cannot limit this sharing).
- Affiliate Marketing: Sharing data with affiliates for direct marketing purposes (investors have the right to limit this sharing).
- Legal Requirements: Disclosing information in response to subpoenas, court orders, regulatory requests, or legal processes.
- Service Providers: Sharing data with service providers such as administrators, prime brokers, website providers, custodians, auditors, and legal advisors to facilitate fund operations.
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Data Security and Retention at Paloma Partners
Paloma Partners employs robust security measures to protect personal data, including computer safeguards and secured facilities. Data is retained only for as long as necessary for the intended purpose, generally ten years after an investment redemption or fund liquidation.
International Data Transfers
Due to the global nature of Paloma Partners’ operations, personal data may be transferred to countries with varying data protection laws. Paloma Partners ensures compliance with applicable regulations, including through Standard Contractual Clauses for transfers outside the EEA, Switzerland, or the Cayman Islands.
Investor Rights and Choices
Paloma Partners respects investor rights regarding their personal data. Depending on jurisdiction, investors may have the right to:
- Access their personal data.
- Request changes or corrections to their data.
- Request deletion of their data.
- Object to or restrict certain data processing activities.
- Revoke consent for data processing.
- File complaints with relevant authorities.
Contacting Paloma Partners Regarding Privacy
Investors with questions or concerns about Paloma Partners’ privacy practices can contact Investor Relations at +1(203) 861-3236, [email protected], or by mail at Two American Lane, Greenwich, Connecticut 06836-2571, USA. For inquiries related to specific service providers, investors can contact them directly using information provided in the fund’s memorandum. This notice is effective as of March 2024. California residents have additional rights outlined in a separate section of the full privacy notice.
