AGR Partners LLC considers your privacy our utmost concern. As a Registered Investment Adviser, we are required to provide you with certain information regarding our policy on nonpublic personal information. We collect certain nonpublic personal information about you from information you provide on applications or other forms, and information about your account transactions with us. We may also collect such information through your inquiries by mail, email or telephone.
We do not disclose any nonpublic personal information about you to anyone, except as permitted by law. So that we may service and effect transactions in your account, we may disclose the information we collect, as described above, to companies that perform administrative services on our behalf, such as internal shared services personnel, lawyers, external expert advisers and accountants that assist us in the service of your account. These companies will use this information only for the services for which we hired them, and are not permitted to use or share this information for any other purpose.
If you decide at some point to close your account(s), we will continue to adhere to the privacy policies and practices described in this notice.
We restrict access to your personal and account information to those who need to know that information to service your account. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.
AGR, its subsidiaries, including its affiliated investment advisers and funds (together, the “Company”, “us” or “we”), consider your privacy our utmost concern. This privacy notice (the “Notice”) contains information about how the Company collects, uses, and shares Personal Information, as defined by the California Consumer Privacy Act (“CCPA”).
1. Purpose and content
1.1 This Notice applies to all websites operated by us, as indicated on the relevant website (“Sites”). This Notice is for California residents only pursuant to the CCPA.
1.2 The CCPA defines Personal Information broadly to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
1.3 Please note that much of the Personal Information we collect about California residents is not covered by this Notice. The CCPA includes certain exemptions that may apply to our use or collection of your Personal Information and it is possible that not all Personal Information that we collect from you or about you is covered by the CCPA or this CCPA Privacy Notice. For example:
2. Categories of Personal Information that we may collect, use, and share
2.1 We may collect, use, or share Personal Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or a member of your household. The categories of Personal Information we may collect, use, or share include, but are not limited to:
3. Sources from which we may collect your Personal Information
3.1 We may obtain your Personal Information:
4. How we use your Personal Information
4.1 We use your Personal Information for our business and commercial purposes, including:
5. How we share your Personal Information
5.1 We do not currently sell your Personal Information. The CCPA defines the term “sale” very broadly. In the past twelve months, we have disclosed the following categories of Personal Information to third parties that provide services to us, such as website advertising and analytics services. Such disclosures may be considered a sale for purposes of the CCPA:
5.2 We share your Personal Information for business purposes and in the last twelve months we have shared the categories of Personal Information listed in Section 2 for a business purpose. For example, we share Personal Information with our affiliates, with entities that provide marketing services to us, and with our business partners, service providers and vendors. We may share your Personal Information with third parties and endeavor to ensure that they use it only for those services requested and keep it confidential.
5.3 We may share any of the Personal Information described in this CCPA Notice with third parties as part of or in connection with a sale, merger, consolidation, change of control, transfer of assets or reorganization of all or part of our business.
5.4 We may additionally share Personal Information in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving the Company or the clients of the Company, or as otherwise required by law.
6. Your rights under the CCPA
6.1 As a California resident, you have the right to know how we have collected, used, and shared your Personal Information in the last twelve months. Specifically, you have the right to request to know:
6.2 In addition, you have the right to request that we delete your Personal Information.
6.3 You have a right to not be discriminated against for exercising these rights.
7. Requests to know or delete your Personal Information
7.1 You have the right to request that we disclose to you the categories and/or specific pieces of Personal Information that we have collected about you. When you make a request, we will first take steps to verify your identity. Once we have verified your identity, we will provide information from our records for the preceding twelve months. Please note, we may decline your request if we are unable to verify your identity.
7.2 You have the right to request that we delete your Personal Information. When you make a request, we will first take steps to verify your identity. Once we have verified your identity, we will delete your Personal Information from our records unless an exception to your deletion request applies or we are unable to verify your identity. We may deny your request to delete Personal Information in whole or in part if retaining the information is necessary for us or our service providers to:
7.3 To submit a request to know or a request to delete as described above, please call 866-887-1975 or send an email to firstname.lastname@example.org.
7.4 You can block cookies by activating the setting on your browser that allows you to refuse all, or some, cookies. If you block all cookies you may find that parts of our Sites do not work properly, or you may not be able to access our Sites at all.
8. Verifying and responding to your requests
8.1 We only respond to requests that you make which are “verifiable.” To verify your requests, we may require authentication of you or the authorized agent acting on your behalf that is reasonable in light of the nature of the personal information requested. We may need additional information from you to verify your request.
8.2 In order to verify your request, we may need to obtain additional information about you to match the information we already have about you. If you provide us with new personal information that we did not already have about you, we will use it solely for the purposes of verifying your request. We will let you know if we need more information from you to verify your request. Please reply to our requests promptly.
8.3 If we cannot verify your request, we will let you know.
9. Changes to this notice
We will occasionally update this Notice to reflect new legislation or industry practice and Company changes. We encourage you to review this Notice periodically to be informed of how we collect, use and share your Personal Information.
This AGR Privacy Notice is for applicants for AGR positions (“applicant”), residing in California, and is made available pursuant to the California Consumer Privacy Act (CCPA) (the “AGR California Applicant Privacy Notice” or “this Notice”).
If you are applying for a job with AGR and you reside in California, please review this this Notice carefully, as it applies to the personal information we collect about you solely in your capacity as an applicant. We encourage you to read this Notice to have a full description of our online and offline data practices.
If you receive an employment offer for AGR, you may receive additional requests for information, including a background check, subject to additional disclosures.
Under the CCPA, personal information includes information that identifies and describes who you are; as well as information that relates to, is capable of being associated with, or could reasonably be linked to you, one of your devices and/or a member of your household. In this Notice, we refer to the information subject to the CCPA as “Applicant Personal Information.”
Your rights under the CCPA
As a California resident, you have the right to receive this information on AGR’s privacy practices, including why we collect Applicant Personal Information about you, from whom it is collected and for what purpose.
Categories of Applicant Personal Information that AGR may collect or generate
AGR may collect or generate Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or a member of your household. The categories of information we may collect or use about you are:
We may obtain Applicant Personal Information –
We do not hire minors under sixteen years of age and therefore do not collect Personal Information from them.
Use of your Personal Information
We only use such Applicant Personal Information for AGR’s business purposes. AGR may share it with vendors who have agreed to use it only to render contracted services to AGR and keep it confidential. AGR does not sell your Candidate Personal Information to third parties.
AGR will notify you of an intended change in our use of your Personal Information and obtain your prior consent before implementing it.
If you have any questions or comments about this Notice, please do not hesitate to contact us by email at: email@example.com.
Changes to this Notice
AGR reserves the right to amend this Notice in its discretion and at any time.
AGR Partners LLC (the “Company”, “us” or “we”) consider your privacy our utmost concern.
This privacy notice (the “Notice”) outlines the information we may collect about you and describes the basis on which we process your Personal Information, as defined by the European Union’s (“EU”) General Data Protection Regulation (“GDPR”) and other United Kingdom (“UK”) and European data privacy laws (the “Privacy Laws”). This Notice also gives information regarding the basis on which we process your Personal Information and your privacy rights under applicable Privacy Laws.
This Notice applies to all websites operated by us, as indicated on the relevant website (“Sites”). This Notice is addressed to any natural person who is resident in the European Union and/or the UK who is any of the following: an investor or prospective investor in any fund or account managed or advised by the Company (a “Company Fund”), a member, distributor, sales representative, business affiliate, or other representative of any client or prospective client of the Company, a website user, a business contact working with service providers and vendors, or an individual on a Company mailing list (“you”) whose Personal Information the Company collects, controls and processes in the conduct of its business.
1. Collection of Personal Information
Our primary goal in collecting Personal Information from you is to effectively conduct business with our business partners and when applicable provide services and features to our clients, investors and potential clients and investors. You may make a data request by emailing firstname.lastname@example.org.
2. Types of Personal Information held and its use
2.1 Customer services and administration
The Company may, in the conduct of our business, obtain Personal Information about you that may include, subject to the type of business or service relationship we have with you, without limitation:
In the course of our business, we may collect Personal Information about you from sources including, but not limited to:
We process your Personal Information to fulfill our contractual obligations, our statutory obligations and/or the legitimate interests of the Company and for other purposes for which the Company has a lawful basis under the Privacy Laws, including:
We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Personal Information should be kept may also be governed by specific business-sector requirements and agreed practices. Personal Information may be held in addition to these periods depending on individual business needs.
2.2 Monitoring use of our Sites
The Company collects certain information that you provide to us when subscribing to a Company mailing list, which may include your name, email address and other contact details. Some of your Personal Information collected, in accordance with this Notice, may be used by us and third party service providers to contact you by email, fax, telephone and/or post for sending information or promotional material on our products and/or services and/or those of the Company.
In addition, we may process your Personal Information in order to communicate with you for marketing purposes. In this event, we may provide additional information that we believe may be of interest, including about services, news updates, research or market commentary, conferences, or events offered by or in conjunction with the Company.
We give you the opportunity to opt-out of receiving marketing communications and may in certain circumstances need to obtain your consent before sending such communications to you. Further detail can be found in each marketing communication sent by us.
Email Tracking: So that we can better understand our users’ needs, we track responses to our emails – for example, to see which links are the most popular in newsletters, and to log and follow up responses to our marketing messages. To do this, we use small image files that are placed within the body of our email messages. They enable us to tell if a message has been opened and to track click-throughs on links within the message.
A cookie is a small text file that we store on the browser or the hard drive of your desktop, tablet or smartphone when you first visit our Sites. The cookie will help our Sites, or another website, recognize your desktop, tablet or smartphone the next time you visit. A cookie can contain Personal Information.
Cookies may be required to operate our Sites, allow us to recognize and count the number of visitors and to see how visitors move around our Sites, which may help us improve the design of our Sites. Cookies may also recognize you when you return to our Sites, enabling us to personalize our content and remember your preferences, and may be used to record your visit to our Sites, the pages you visited and the links you followed. We may use this information to provide you with targeted advertising and content we think you will be interested in. In some cases, we may use information from third party cookies to help us with market research or improving the design of our Sites (for example, where traffic to our Sites comes from).
You can block cookies by activating the setting on your browser that allows you to refuse all, or some, cookies. If you block all cookies you may find that parts of our Sites do not work properly, or you may not be able to access our Sites at all.
4. Third Parties
We may pass your Personal Information on to third-party service providers contracted to us in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service that they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with our procedures.
We may share your Personal Information with the Company entities including with the Company Funds for any of the purposes set forth above. In any such business purposes set out above, the Company may share your Personal Information with third parties, including:
We may transfer, sell or assign any of the information described in this policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganization of our business.
6. Transfers outside the UK / European Economic Area (EEA)
Where your Personal Information is processed by third parties outside the UK / EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law.
Services on the Internet are accessible globally, so collection and transmission of Personal Information is not always limited to one country. We may transfer your Personal Information, for the purposes listed above, to the Company, service providers or other third parties which may be located in countries outside the EEA, whose laws may not give the level of protection to Personal Information as within the EEA. This may include transfers to Companies in the US (who may collect some data directly from you, in relation to the sites which it operates) and to third parties who provide us with email and marketing services. Where we conduct any transfers, we will endeavor to take steps reasonably necessary to ensure that your data is treated securely.
Confidentiality and security of your Personal Information
We are committed to keeping the data you provide us secure and will take reasonable precautions to protect your Personal Information from loss, misuse or alteration. Once we have received your information, we will use procedures and security features to try to prevent unauthorized access.
We have implemented information security policies, rules and technical measures to protect the Personal Information that we have under our control from:
8. How to access, update and erase your Personal Information
At your request, we can confirm what information we hold about you and how it is processed. If we do hold Personal Information about you, you can request the following information:
Upon request, we will provide you with a readable copy of the Personal Information which we keep about you. We may require proof of your identity.
We will allow you to challenge the data that we hold about you and, where appropriate in accordance with applicable laws and policies, you may request to have your Personal Information:
If you would like to make a data request, please contact email@example.com.
Changes to this Notice
We will occasionally update this Notice to reflect new legislation or industry practice, Company changes and customer feedback. We encourage you to review this Notice periodically to be informed of how we are protecting your Personal Information.
The purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Law, 2017 of the Cayman Islands (the “DPL“).
In this document, “we”, “us” and “our” refers to AGR Partners LLC and its affiliated investment advisers, a fund or account managed or advised by them (together, “AGR Partners” or
AGR”) and its or their affiliates and/or delegates.
By virtue of making an investment with AGR Partners and your associated interactions with us (including any subscription (whether past, present of future), including the recording of electronic communications or phone calls where applicable) or by virtue of you otherwise providing us with personal information on individuals connected with you as an investor (for example directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents), you will provide us with certain personal information which constitutes personal data within the meaning of the DPL (“Investor Data“). We may also obtain Investor Data from other public sources. Investor Data may include, without limitation, the following information relating to you and/or any individuals connected with you as an investor:
In our use of Investor Data, AGR Partners (e.g., the respective fund) will be characterized as a “data controller” for the purposes of the DPL. AGR Partners’ affiliates and delegates may act as “data processors” for the purposes of the DPL.
Who this Affects
If you are a natural person, this will affect you directly. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with Investor Data on individuals connected to you for any reason in relation to your investment with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.
How We May Use Your Personal Data
AGR Partners (e.g., the respective fund), as the data controller, may collect, store and use Investor Data for lawful purposes, including, in particular:
Additionally, an AGR Partners affiliate or a respective fund’s administrator (the “Administrator“), may use Investor Data, for example to provide its services to the fund or to discharge the legal or regulatory requirements that apply directly to it or in respect of which the fund relies upon the Administrator, but such use of Investor Data by the Administrator will always be compatible with at least one of the aforementioned purposes for which we process Investor Data.
Why We May Transfer Your Personal Data
In certain circumstances we and/or our authorized affiliates or delegates may be legally obliged to share Investor Data and other information in possession of AGR Partners with the relevant regulatory authorities such as the Cayman Islands Monetary Authority or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities.
We may share Investor Data with the following parties (which may be amended from time to time) who provide services to a respective fund and their respective affiliates (which may include certain entities located outside the Cayman Islands or the European Economic Area), who will process your personal data on our behalf:
The Data Protection Measures We Take
Any transfer of Investor Data by us or our duly authorized affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL.
We and our duly authorized affiliates and/or delegates shall apply appropriate technical and organizational information security measures designed to protect against unauthorized or unlawful processing of Investor Data, and against accidental loss or destruction of, or damage to, Investor Data.
Getting In Touch
Should you have any queries or wish to discuss your data protection rights with us, please contact firstname.lastname@example.org.
Changes to this Notice
We will occasionally update this notice to reflect new legislation or industry practice, company changes and customer feedback. We encourage you to review this notice periodically to be informed of how we are protecting Investor Data.