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 for which it serves as investment manager.
If you are a natural person, this Privacy Policy relates to you directly. If you are a corporate investor (including, for these purposes, a legal arrangement such as a limited partnership or trust) that provides personal data on natural persons connected to you for any reason in relation to your investment with us, this will be relevant for those persons and you should transmit this Privacy Policy to them.
Application
This Privacy Policy applies to information we collect through:
- our websites (the “Websites”) and their associated services;
- any documents you deliver to us, including these subscription documents;
- any transactions among, you, us and/or any service providers that are necessary to carry on our everyday business;
- our discussions with you, including via email or other electronic messages; and
- third-party public and non-public sources, including consumer reporting agencies.
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.
Certain of the information we collect constitutes “personal data” under the Data Protection Act (as amended) of the Cayman Islands (the “DPA”). Under the DPA, the Partnership is a “data controller” and the Partnership’s affiliates and/or delegates may be “data processors” (or, in some circumstances, data controllers in their own right), in respect of your personal data. A reference in this Privacy Policy to your “information” or “data” includes a reference to your personal data.
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 process your information because we have a contractual obligation to do so. In addition, we may process your information where it is necessary for the purposes of our legitimate interests or those of any third party to whom the data is disclosed, including without limitation, for the purposes of enabling you to receive, contribute to, or learn about our research and advisory services, to allow us to provide such services and otherwise administer our business, and 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.
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 equivalent to those in the European Union or the Cayman Islands.
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.
We have entered into written agreements with the third parties that process your information on our behalf. These agreements require third parties to act only on our instructions and to implement appropriate technical and organizational measures against unauthorized or unlawful processing of your information and against accidental loss or destruction of, or damage to your information, consistent with the DPA.
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 or 212-710-5710 for further information 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.