1.Many of the services offered by CRC require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described at paragraph 2.1 above, we will collect and process the following Personal Data about you:
2.Information that we may collect or generate about you. This includes (by way of non-exhaustive list):
1 ‘Christofferson Robb & Company’ refers to Christofferson, Robb & Company LLC and Christofferson, Robb & Company (UK) LLP, acting together or separately as the context requires.
General Data Protection Regulation
Christofferson Robb & Company (UK) LLP is a company registered in England and Wales with company number OC303662. Christofferson, Robb & Company, LLC is a company incorporated in the State of Delaware.
These companies are referred to below as ‘CRC.’
For the purposes of the General Data Protection Regulation (‘GDPR’), CRC will normally be the ‘controller’ of personal data that we have received. On occasion CRC may act in the capacity of a Data Processor where we have entered into a contract for the provision of Services.
Please read the following information carefully to understand CRC’s practices in relation to the treatment of your personal data.
CRC’s data privacy principles
– CRC to provide a service to you / the company you represent (hereinafter referred to as “you,” appropriate to the context);
– You / the company you represent to provide a service to CRC;
– CRC to keep you informed of its products and services; or
– CRC to comply with its legal and regulatory obligations.
Personal data collected by CRC
The type of personal data (e.g., name, contact details, address etc.) that we may collect will depend upon the relationship between CRC and you. The data so collected may be provided directly by you or, where appropriate, provided by third parties e.g., references, credit checks, etc.
As a client, a contact, a service provider or employee (or prospective employee) of CRC we will require some personal information to verify your identity and have the applicable relationship with you. Some of this information may be required to satisfy legal obligations (e.g., HMRC) whereas other information may be required in connection with the provision of services to you. The information collected will vary depending on the service CRC provides to you or you provide to CRC, but typically includes:
Firm storage of personal data
CRC has comprehensive policies and procedures in place to ensure your personal data is kept safe and secure, with these including:
Retention time for personal data
CRC will retain personal data for as long as is necessary for the purposes for which it was collected (or longer period if so required by law or legitimate interests) which will be at least for the period in which CRC has a business interest with you.
Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.
CRC’s categorisation of you
GDPR requires CRC to inform you of the legal basis on which we maintain your personal data. As a general rule the following is applicable:
Data subjects’ rights
You have certain rights that apply in respect of your personal data, depending on your relationship with CRC and CRC’s legal and regulatory obligations. These include the right to:
Notification of changes to this policy
CRC may, from time to time, review and update this policy. CRC will maintain the latest version of this policy on its website, and where the changes are deemed material, it will make you aware of these.
Contact details for questions
If you have questions, concerns or complaints about the practices contained within this document or how CRC has handled your data, please email the Data Protection Officer at firstname.lastname@example.org.
The California Consumer Privacy Act (“CCPA”) imposes certain obligations on Christofferson, Robb & Company LLC (the “Investment Manager”, “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used herein have the meaning ascribed to them in the CCPA. The Investment Manager is a “business.” “Personal information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California Resident or a household. It does not include deidentified information, aggregate consumer information or publicly available information, as those terms are defined in the CCPA.
Notice at Collection and Use of Personal Information
Information We Collect
Depending on how you interact with us, we may collect the following categories of personal information from or about you: (i) identifiers and similar information such as, name, address, date of birth, email address, social security number, driver’s license number, passport number, online identifiers or other similar identifiers; (ii) additional information subject to Cal. Civ. Code § 1798.80(e), including your, education, credit card number, state identification card number, signature, bank account or other financial information; (iii) characteristics of protected classifications under federal or certain state laws, including, gender, age, national origin, citizenship status, or marital status; (iv) commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth; (v) internet or other electronic network activity information, including interactions with our website or use of certain online tools; (vi) professional or employment-related information, including occupation, compensation, employer, and title; and (vii) inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds or products.
How We Use Collected Information
We may use your personal information for the following business or commercial purposes: (i) performing services on our behalf, including maintaining or servicing accounts, providing investor relations services, processing subscriptions, withdrawals, verifying information, processing payments or providing similar services; (ii) performing our contractual obligations to a California Resident as a subscriber to a fund, including processing initial subscriptions and providing updates on a fund’s performance, providing tax reporting and other operational matters; (iii) detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, anti-terrorist financing, and conflict checks; and (iv) enabling or effecting commercial transactions, including, using bank account details to remit funds and process distributions.
Our Collection, Use, Disclosure and Sharing of Personal Information
Information We Have Collected
In the preceding 12 months, and depending on how you interact with us, we may have collected the categories of personal information listed above in the “Information We Collect” section.
Sources of Personal Information
We may collect personal information about you directly from you and/or your intermediaries through sources such as: (i) account applications, subscription agreements, and other forms or related documentation; (ii) written, electronic, or verbal correspondence with us or our service providers; (iii) investor transactions; (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or (v) from information captured on applicable websites. In addition, we may collect personal information from different sources, such as: (i) our service providers; (ii) public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or (iii) from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.
Purposes for Collecting Personal Information
We may collect your personal information for the business or commercial purposes described above in the “How We Use Collected Information” section.
Disclosure and Sharing Personal Information with Third Parties
We do not sell your personal information. We do not knowingly sell the personal information of California residents under 16 years old. We may disclose personal information to third parties in circumstances where we believe in good faith that disclosure is required or permitted under law, to cooperate with regulators or law enforcement authorities, to protect our rights or property or upon reasonable request by the fund in which you have invested.
In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to third party entities who assist with fraud prevention, detection and mitigation, including credit agencies and to assist with anti-money laundering or anti-terrorism checks:
We also may share your personal information with our service providers such as our information technology and email providers, the Fund’s administrator, professional services organizations, and other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) request that we delete any personal information about you that we collected, subject to certain exceptions (“Request to Delete”); (iii) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting the personal information; (d) the categories of third parties to whom we disclosed personal information about you for a business purpose; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose; (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); and (v) not be discriminated against because you exercise any of your rights under the CCPA.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. Notwithstanding the foregoing, we reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or where another law or regulation is applicable.
How to Submit a Request under the CCPA
If your personal information is subject to the CCPA, you may submit a Request to Know, as described above, through the following toll-free telephone number 1 (800) 630-6408, or through our website at the following link: www.christoffersonrobb.com (see ‘Contact’ and click on email@example.com). You may submit a Requests to Delete through the following methods: via email to firstname.lastname@example.org or by mail to the General Counsel, Christofferson, Robb & Company, LLC, 720 Fifth Avenue, 13th Floor, New York, NY 10019.
We are required to provide certain information or to delete personal information only in response to verifiable requests made by a California resident or their legally authorized agent. When you submit a Request to Know or Request to Delete, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a Request to Know or a Request to Delete on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit written proof that they are authorized to act on your behalf, or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
We will deliver responses to verifiable consumer requests, free of charge, by mail or electronically, at your election. We will try to respond to your Request to Know or to Request to Delete within forty-five (45) days of receipt of the request. If we require more time, we will try to inform you of our need for an extension. Even with an extension, we will try to provide a response within ninety (90) days of initial receipt of the request.
Keep in mind that we are not required to provide information in response to Requests to Know more than twice in a 12-month period. Any response to a Request to Know will only cover the 12-month period preceding the verifiable request.
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