Aksia LLC and its affiliates and funds (together, “Aksia,” “we,” “us,” or “our”) have created this privacy policy (the “Privacy Policy”) to describe our approach to the collection, processing, storage, and use of information that we collect from you. This privacy policy covers the collection and use of information by Aksia and its affiliates, as well as the collection and use of information by any funds, including any Cayman Islands Exempted Limited Partnerships, for which it serves as investment manager.
Application
This Privacy Policy applies to information we collect through:
- our websites (the “Websites”) and their associated services;
- any documents you deliver to us;
- our discussions with you, including via email or other electronic messages; and
- third-party public and non-public sources.
Websites
We provide visitors and registered users with access to the Websites as described below.
Visitors: Visitors are individuals who do not create a login and can only access publicly-available features and functionalities of the Websites.
Registered Users: Registered users are individuals who are able to access public as well as password-protected areas of the Websites.
For more information about each of our Websites, please refer to the applicable terms of use.
Information We Collect
Aksia collects information from visitors and registered users of its Websites; employees of its clients, prospective clients, vendors, service providers, and managers on which it may perform due diligence, in addition to other parties in the financial services industry; as well as from its current, former, and prospective employees, and from employees of its professional advisors, including, but not limited to, its attorneys and auditors.
If you are a visitor to the Websites, we may collect information that identifies your computer automatically through the use of cookies, pursuant to our Cookies Policy.
If you are a registered user of any of the Websites, we may collect information about you including personal identifiers and professional information, such as your name, company name, professional title, email address, business address, telephone number, IP address, and geolocation, as well as analytic information relating to your activity on the Websites, such as device information and login activity. Additionally, we may collect information that identifies your computer automatically through the use of cookies, pursuant to our Cookies Policy.
If you are applying for a position with Aksia, we may collect information relevant to your candidacy, including your contact information, resume, test scores, reference and background check information, and other information you may submit as part of the application and assessment process. Except to the extent necessary to provide accommodations requested during the hiring process, please do not provide Aksia with sensitive data as defined by your country’s relevant data protection laws, which may include information relating to sexual orientation, race, religion, age, health or disability status.
If you are an employee of a company on which we are conducting due diligence, we may collect information about you and your current position, as well as your employment history. For a certain subset of such employees, we may also run a background check as part of our standard operational due diligence process. If you are the subject of such a background check, we may collect your court records, educational records, full employment history, disciplinary records, military service, corporate records, news reports, regulatory records, licensing records, civil and criminal litigation and bankruptcy records, and other relevant publicly available records in accordance with your consent.
Use of Your Information
Aksia uses, processes and stores your information in connection with our provision of specialist research and portfolio advisory services. We may collect information about you directly from you, from your current or former employer or one of your colleagues, or from third party public and non-public sources.
We may process your information because we have a contractual obligation to do so. In addition, our processing of your information serves a legitimate business interest, as, depending on your relationship with Aksia, it enables you to receive, contribute to, learn about, or provide services related to our research and advisory services, and Aksia’s internal use of your information allows us to provide such services and otherwise administer our business. We may also use your contact information to communicate with you regarding Aksia or our relationship with you, or to send you periodic updates and other communications related to Aksia’s business and/or the private fund industry. Finally, Aksia may process your information in order to comply with legal and regulatory requirements.
If you are a candidate for employment with Aksia, we will process your information solely for recruiting and employment purposes, or in order to comply with legal and regulatory requirements. Only those Aksia employees who have a need to know your information in order to facilitate the hiring process will have access to your information. We may store your information for reference or use during future candidate searches.
When you provide your information to Aksia, or, in the event that you provide the information of another individual to Aksia, you represent and warrant that you have the ability to transfer such information and have obtained any required consents to do so, and you explicitly consent to the processing of any such information in accordance with this Privacy Policy.
Data Transfer and Storage
Aksia will transfer your information to our global offices, including our New York headquarters, which may be located in jurisdictions that have not adopted data protection regulations similar to those in the EU.
Aksia will store and process your data for varying lengths of time, depending on our relationship with you, our internal business needs, our legal and regulatory obligations, and our automated archiving procedures.
Sharing of Your Information
Aksia may share your information with our affiliates and subsidiaries. Aksia may also share your information with our clients and prospective clients, and/or with the managers on which we perform due diligence, as applicable and subject to any confidentiality agreements we may have with you. We may also share your information with third-party vendors and service providers that assist us in providing research and advisory services, including technology and cloud service providers, background check providers (only with your consent), and companies that provide administrative, legal, compliance and other professional services. Finally, we may disclose information about you if required by law, rule, or regulation, including to our advisors, accountants, attorneys, auditors, regulators, law enforcement or other government entities, or if necessary, to prevent harm, fraud or financial loss.
Security Measures and Your Rights
Aksia has put in place contractual, technological and procedural safeguards designed to protect your information, such as our internal Privacy Policy and our internal Program for Protecting Client Information. In addition, depending on the jurisdiction in which you are based, global data protection laws may afford you certain rights with respect to your data. These rights may include:
- The right to request access to your information;
- The right to update or amend your information;
- The right to object to certain uses of your information;
- The right to request deletion or restrict the processing of your information; and
- The right to log a complaint with the relevant supervisory authority related to our use or processing of your information.
Please contact us at compliance@aksia.com for further information, to opt out of communications from Aksia, or if you have any questions about this policy. Please note that we may need you to provide further information in order to assist us in complying with your request. In addition, we may be restricted in our ability to respond to your request due to our legitimate business interests in maintaining the information in question, to our contractual, legal and regulatory obligations, and to our automated archiving procedures.