WHAT DOES GTIS PARTNERS LP DO WITH YOUR PERSONAL INFORMATION

Financial companies choose how they share your personal information, which may include personally identifiable information (“Personal Data”) and non-personally identifiable information.  Federal law gives consumers the right to limit some but not all sharing.  Federal law also requires us to tell you how we collect, share, and protect your Personal Data. 

For individuals in the EU, the EU General Data Protection Regulation (the “GDPR”) governs the way we, as a “data controller” and Third Parties we hire collect, use, share and retain - in one word “process” - your Personal Data.

Please read this Notice carefully to understand what we do.

The types of Personal Data we collect and share depend on the product or service you have with us.  This information can include:

• name, email address, mailing address and other contact details,
• social security number, tax identification number and income,
• date of birth,
• information to verify your identity (e.g., driver’s license number, passport),
• wire transfer instructions and investment experience,
• account balances and assets, and
• authorized representatives or beneficial owner of an investor.

For the avoidance of doubt, in the case of institutional investors, Personal Data includes Personal Data of individuals linked to such institution.

When you are no longer our customer, we continue to share your information as described in this Notice, subject to our record retention policies and applicable law.

We also collect information about your use of our website when you enter and browse the website through the use of “cookies,” web server logs and other electronic tools.  This information may include, without limitation, the number and frequency of visits to the website, the websites accessed before and after you visit the website, the Internet browsers used by you and your IP addresses.

All financial companies need to process and share investors’ Personal Data to run their everyday business.  In the section below, we list the reasons financial companies can process and share their investors’ Personal Data; the reasons we may share your Personal Data, and with whom; and whether you can limit this sharing.

This Privacy Notice applies to Personal Data that is collected on our website, through our marketing efforts, or from information provided by you, as set out further below.    

For business purposes, such as to:

• process your transactions,
• manage your investments and maintain your account(s),
• verify your information,
• respond to your inquiries,
• comply with federal securities laws,
• comply with laws applicable to investment advisers,
• perform accounting, legal or tax audits,
• identify and prevent fraud and other unlawful activity,
• develop new products and services,
• perform data analyses,
• undertake a corporate business transaction (e.g., financing, merger, joint venture, sale of assets, bankruptcy),
• respond to governmental inquiries or examinations, court orders and legal investigations,  
• report to credit bureaus, or
• undertake any activity with your consent.

Yes, with Affiliates, Non-Affiliates and Third Parties

Yes, if required by the law applicable to you, on grounds relating to your particular situation and to the extent that processing and sharing are based on legitimate interests (see below)

For marketing purposes-
to offer our products and services to you

Yes, with our Affiliates

Yes, if required by the law applicable to you

For Joint Marketing with other financial companies

Yes, with another investment adviser for purposes of marketing one or more of our funds on a joint basis

Yes, if required by the law applicable to you

US State laws and individual companies may give you additional rights to limit sharing.

Different legal bases relied upon for processing

We rely on various legal bases for processing your information, including:

1) To perform our contract with you, i.e.:

• process your transactions,
• manage your investments and maintain your account(s),
• verify your information,
• respond to your inquiries.

2) To comply with a legal obligation we are subject to, i.e.:

• comply with federal securities laws,
• comply with laws applicable to investment advisers.

3) For legitimate Interests, i.e.

• performing accounting, legal or tax audits,
• identifying and preventing fraud and other unlawful activity,
• developing, and direct marketing of, new products and services,
• performing data analyses,
• undertaking a corporate business transaction (e.g., financing, merger, joint venture, sale of assets, bankruptcy),
• responding to governmental inquiries or examinations, court orders and legal investigations,  
• reporting to credit bureaus.

4) Consent - you have given your consent to process your Personal Data (if we are relying on this legal basis we will make this clear to you at the time we ask for your consent).

If you have any questions, concerns or objections as to how your Personal Data is processed, please contact GTIS Partners LP’s Chief Compliance Officer (“CCO”):

Name: Amy Boyle

Email: Compliance@gtispartners.com

Telephone: (212) 220-5200

Who is providing this Notice?

GTIS Partners LP

787 Seventh Ave, 50^th Floor

New York, NY 10019

How does GTIS Partners LP protect my Personal Data?

To protect your Personal Data from unauthorized access and use, we use security measures that comply with federal laws and, if applicable, laws of foreign jurisdictions (including the GDPR).  These measures include electronic safeguards and secured files and buildings.  We limit employee access to customer information to those who have a business reason to know such information and are committed, by contract or statutory obligation, to confidentiality.  We educate our employees about the importance of confidentiality and investor privacy. 

How does GTIS Partners LP collect my Personal Data?

We collect your Personal Data, for example, when you:

• use our website,
• communicate with us or our representatives,
• complete subscription documents and investor questionnaires,
• provide account information, or
• give us your contact information or make a wire transfer.

What are my rights under the GDPR?

Under the GDPR, you have a number of rights with respect to your Personal Data, including:

• the right to obtain from us confirmation as to whether or not your Personal Data are being processed and, where this the case, obtain a copy of the Personal Data undergoing processing;
• the right to request that we correct or supplement without undue delay your Personal Data;
• the right to request us to delete without undue delay your Personal Data if no longer necessary or you have withdrawn consent, objected to processing or your Personal Data have been unlawfully collected;
• the right to restrict the processing of Personal Data where you contest its accuracy, or the lawfulness of its processing, or where we no longer need it.
• the right to object to the processing of your Personal Data, on grounds relating to your particular situation, when processing is based on legitimate interests, as well as direct marketing;
• the right to be informed about the existence of automated decision making, including profiling, and its significance and envisaged consequences on you;
• the right to portability, limited to the Personal Data that you provided on the basis of consent or for the performance of the contract of which you are party and only to the extent that the processing is carried out by automated means. A request for data portability may be rejected, or a fee may be charged, when the request is manifestly unfounded or excessive. A reasonable fee may also be charged based on administrative costs.
• The right to lodge a complaint with the data protection authority in your jurisdiction if you believe that we have breached GDPR requirements.

In addition, if you have provided consent to process your Personal Data, you have the right to withdraw consent at any time by contacting GTIS Partners LP’s CCO (see “Contact Information” above). 

How do I exercise such rights?

You can contact GTIS Partners LP’s CCO (see “Contact Information” above).

What other information do you share?

We may share anonymous or non-personally identifiable information with Third Parties for any purpose in accordance with this Notice.

How long will you store my Personal Data?

We will store Personal Data received from you in accordance with our records retention policy, which generally means that we will keep such information for two years after the termination of the relevant agreement or last contact or for longer, if necessary for the compliance with a legal obligation.    

Will you transfer my Personal Data outside of the EU?

We may transfer information about you to our Affiliates or service providers outside of the EU in the course of operating our business and to comply with our legal or contractual requirements.  We have safeguards in place so that any transfer of data outside of the EU is subject to an adequate level of data protection as mandated by the GDPR. You may request a copy of such safeguards by contacting us.

Affiliates

Companies related by common ownership or control.  They can be financial and nonfinancial companies.

Non-Affiliates

Companies not related by common ownership or control.  They can be financial and nonfinancial companies.

• Non-Affiliates we share with can include custodians, fund administrators, investments advisers, brokers, dealers, counterparties, auditors and legal advisors

Joint Marketing

A formal agreement between non-affiliated financial companies that together market financial products to you.

GTIS Partners LP may jointly market one or more of its funds with another registered investment adviser.

Third Parties

Third party service providers we may use to collect, process, and store your Personal Data at our request. These include: 

• attorneys, auditors, accountants,
• custodians, third party administrators, transfer agents,
• cloud providers, IT and other information security personnel.

Process

Any operation performed on Personal Data, such as collecting, recording, organizing, storing, adapting, altering, retrieving, consulting, using, disclosing, disseminating, making available, destroying or deleting such Personal Data.