Privacy Policy

ARGAND PARTNERS, LP

 

Effective Date: September 28, 2020

Table of Contents:

  1. Introduction
  2. Scope
  3. Information We Collect
  4. How We Collect Information
  5. How/Why We Use Information We Collect
  6. How/Why/With Whom We Share the Information We Collect
  7. Transfers of Personal Information from the EEA or the Cayman Islands to the U.S. and/or Other Countries
  8. Children’s Personal Information
  9. Your Rights
  10. Security and Protection of Personal Information
  11. Website Usage
  12. Exercising your Rights
  13. Changes
  14. Contact Us

 

  1. Introduction

Argand Partners, LP and its affiliates (“Argand”, “we,” “our,” or “us”) are committed to protecting the privacy and security of our clients, employees, and visitors to our website.  This Privacy Policy (this “Policy”) helps you understand whether and how Argand collects information about you when you visit the website controlled by Argand that links to this Policy (our “Website”).  Please read this Policy to understand what we do and understand your rights.

  1. Scope

This Policy does not apply to information collected from you offline or to third-party websites to which our Website may link.  This Policy does not apply to the offline information practices of Argand, nor does it apply to personal information we may collect from you as an investor (an “Investor”) in any fund or account that we sponsor or manage (collectively, the “Fund”). We address these practices in separate notices to clients or investors as required by law.  In the event that we offer special programs, events or activities with unique or additional terms, privacy notices or consent forms, please review such additional terms.

For your convenience and information, our Website may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Argand, we are not responsible for these third parties’ information practices.

  1. Information We Collect

Argand does not collect any personally identifiable information from visitors to our Website. Argand also does not track other information such as your Internet Protocol (IP) address, the websites you visit immediately before and after you visit our Website, the length of time spent on our Website or the pages accessed while visiting our Website. The only information that Argand collects from Website visitors is that which is voluntarily submitted by users, for example via email. By voluntarily submitting information to Argand via our Website, you agree that Argand may use and retain it for business purposes, such as for the performance of any contract between you and us and/or to allow us to comply with our legal or regulatory obligations, without restriction or compensation to you.

We may make inferences drawn from any such information to create a profile reflecting your preferences and characteristics.

Argand does not offer financial incentives for the use of personal information.

  1. How We Collect Information

Argand collects personal information that you voluntarily provide to us through your interaction with our Website, such as by using the contact information provided on our Website to give us your contact or other personal information.

  1. How/Why We Use Information We Collect

Argand will use the personal information you provide through our Website to respond to your questions, to correspond with you regarding our business, and/or to provide you with services.  We may also use your information to:

  • Improve our services and develop new offerings.
  • Send you information regarding our products or services.
  • Invite you to participate in surveys or programs regarding our products or services.
  • Furnish and maintain our website.
  • Protect Argand and our users.

Argand may also use or disclose personal information for our business purposes, such as to:

  • Secure our online services including our network and our Website.
  • Conduct audits related to our current interactions with you.
  • Debug the site and service to identify and repair errors that impair existing intended functionality.
  • Perform services, including providing customer service, processing or fulfilling transactions, processing payments, providing financial analysis or similar services on behalf of Argand.

For Investors, Argand may also collect, store and use personal information to provide you with the requested services and for lawful purposes, including where this information is necessary for us to:

  • Perform our responsibilities under the Fund documents (such as processing a new subscription agreement or additional investment); and
  • Comply with our legal or regulatory obligations (such as compliance with anti-money laundering procedures or tax reporting).

Argand does not sell personal information of consumers to third parties in exchange for monetary or other valuable consideration. 

  1. How/Why/With Whom We Share the Information We Collect

Financial companies need to share customer personal information to run their everyday business.  Below are some of the reasons we may share personal information and to whom:

  • For our everyday business purposes (such as to process your transactions, maintain your account(s), respond to requests by government agencies or legal or other properly authorized investigations, establish, exercise or defend our legal rights, or prevent physical or other harm or financial loss).
  • For our marketing purposes for us to offer our products and services to you.
  • With our affiliates about your transactions and experiences for their everyday business purposes.
  • To non-affiliates, because we hire service providers such as auditors, fund administrators, legal and tax advisors, and information technology consultants, software companies, website hosting, operating systems and platforms, data analytics providers, placement agents to market the Fund to prospective investors, and other third-party service providers. Service providers typically execute a written agreement that prohibits them from disclosing or using the information other than to carry out the purposes for which we disclosed the information to them.  Even with a service provider agreeing to abide by the restrictions on disclosure, we cannot control how third parties process your personal information.
  • To comply with legal or regulatory requirements.
  • To a buyer in the event we sell all or part of our business or assets.
  • For other purposes after we have provided you notice and received your consent to share personal information for that purpose.

We do not otherwise disclose personal information to non-affiliates except in accordance with applicable law.  Any consent you give to allow us to share information may be withdrawn at any time (to the extent set forth below). If you withdraw consent, that will not impact your personal data that was processed prior to withdrawal of the consent.

  1. Transfers of Personal Information from the EEA or the Cayman Islands to the U.S. and/or Other Countries

We may transfer your personal information within Argand and/or to third parties, such as our third-party service providers. Your personal information may be transferred, processed and/or stored in a country other than the one in which your personal information is collected. To the extent that you reside in the European Union, or EU or Cayman Islands data privacy legislation applies to you or the Fund in which you invest, and we transfer your personal information to the U.S. or other countries located outside of the European Economic Area (“EEA”) or the Cayman Islands, we have implemented procedures to ensure that appropriate safeguards are in place to protect the personal information regardless of where it is being transferred.

  1. Children’s Personal Information

Our Website is intended for a general audience and is not directed to children. Argand does not knowingly collect or use any information from children (we define “children” as minors younger than 13).  We do not knowingly allow children to order our products, communicate with us, or use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.  Argand does not sell the personal information of minors under 16 years old and would not without affirmative authorization.

  1. Your Rights

You may exercise the applicable rights described in this section, including submitting a verifiable request, by following the instructions listed in the “Exercising your Rights” section of this Policy.

Please note that certain personal information collected and processed by Argand will be out of scope for certain individual rights as it falls under exemptions for information collected under the federal Gramm-Leach-Bliley Act (“GLBA”).  Under the GLBA, non-public personal information that is collected from an individual who obtains from us financial products or services to be used primarily for personal, family, or household purposes is covered by the GLBA and therefore not subject to aspects of various jurisdictional privacy laws.  Nonetheless, depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right to:

  • Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared.
  • Access a copy of the personal information we retain about you upon a verifiable request.
  • Request deletion of your personal information.
  • Opt-out of the sale of your personal information.
  • Not be discriminated against for exercising your privacy rights.

SEC privacy regulations

Under SEC regulations, you have the right to limit only: (1) sharing of personal information about your creditworthiness with our affiliates; (2) affiliates from using your information to market to you; and (3) sharing for non-affiliates to market to you.  In some instances, we may be required to allow you to opt-out of sharing information with anyone else, affiliate or non-affiliate. However, we do not engage in any of those activities and only share information in accordance with the exemptions contained in the SEC privacy regulations.

Other Jurisdictions

Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right to:

  • Manage your information.
  • Rectify inaccurate or incomplete information.
  • Data access and portability.
  • Data retention and erasure.
  • Withdraw consent and restrict processing.
  • Object to processing.
  • Request a copy of any agreement under which personal information is transferred outside of the European Economic Area.
  • Be informed of and be able to object to decisions affecting your investment in the Fund that are based solely on automated processing, including profiling (ADM).
  1. Security and Protection of Personal Information

We have put in place reasonable and appropriate technical and information safety safeguards designed to protect against unauthorized or unlawful processing of personal information, and against accidental loss or destruction of, or damage to such information.  This includes measures such as computer safeguards and secured files and buildings.

While we would intend to take reasonable steps to secure any webpage that collects information, the confidentiality of information transmitted over the Internet cannot be guaranteed.  We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your financial information.

  1. Website Usage

When you access our Website, your personal information may be, but is not currently, collected by cookies and other similar technologies.  Additionally, when you use our Website, some browsers have Do Not Track (“DNT”) features that allow you to tell a website not to track you.  Argand does not honor the AdChoice DNT signals.  Please be aware that limiting the ability of website technologies may limit your experience and in some cases the sites may not work.

  1. Exercising your Rights

Please direct all requests to exercise your applicable rights under this Policy to dataprivacy@argandequity.com or call us at (212) 588-6470.

Requests to Know (Access Requests)

Argand may deny requests for disclosure of the categories of personal information if the request is not verifiable.  We cannot provide specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable security risk to the personal information, the consumer’s account, or our systems or networks.

  1. Changes

We reserve the right to amend this Policy at any time.  When we do revise this Policy, we will update the “Effective Date” at the top of this page so that you can tell if it has changed since your last visit.  Please note: the Effective Date is also the date in which this Policy was last updated.  Your continued use of our Services constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us from the Effective Date.

  1. Contact Us

If you have any questions, concerns or complaints regarding the information in this Policy and/or our privacy practices, please email us at dataprivacy@argandequity.com or call us at (212) 588-6470.