The Guardian
Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Serengeti Asset Management LP (the “Manager”) as manager of certain pooled investment vehicles (the “Funds” and each, a “Fund”, and together with the Manager, “we” or “us”), and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to current, prospective and former investors in the Funds or counterparties, as applicable.
References to “you” or an “investor” in this Privacy Notice mean any investor or counterparty who is an individual, or any individual connected with an investor who is a legal person, as applicable.
This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”). The Funds and the Manager are considered to be data controllers in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that each of the Fund and the Manager (alone or jointly, as applicable) determines the purposes and the means of the processing of your personal information.
Please contact our Head of Investor Relations at info@serengeti-am.com, or +1 (212) 672-2250 or by writing to the following address, Serengeti Asset Management LP, 632 Broadway, 12th floor, New York, New York 10012, with any questions about this Privacy Notice or requests with regards to the personal data we hold.
Please note that the Administrator, the Sub-Administrator and the Prime Broker may also act as data controllers of your personal information in connection with the performance of their legal and contractual obligations for purposes of certain Data Protection Laws. For more specific information or requests in relation to the processing of personal data by the Administrator, the Sub-Administrator, the Prime Broker or any other service provider of the Funds, you may also contact the relevant service provider by visiting their websites. You can access the Administrator’s privacy notice at https://citco.com/footer/privacy-policy/.
The categories of personal data we may collect include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches.
We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; or (ii) information that we obtain in relation to any transactions between you and us.
We also may receive your personal information from third parties or other sources, such as our affiliates, the Administrator, the Sub-Administrator, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.
As applicable, depending on the purpose for which the information was obtained, we may process your personal data for the purposes of administering the relationship between you and us (including subscription acceptance, contract execution, funding, communications and reporting), marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance), or responding to requests for information from supervisory authorities, or law enforcement agencies.
We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal information. Such grounds include, for example, circumstances where:
Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in your subscription in the applicable Fund or your potential transaction being rejected, compulsorily redeemed, or withdrawn, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.
As applicable, depending on the purpose for which the information was obtained, we may disclose information about you to our affiliates, service providers (including the Administrator, the Sub-Administrator of the Funds), or other third parties to process our transactions with you, accept your subscription, administer and maintain your account(s), or otherwise perform our contractual obligations. We may also need to share your personal information with regulatory, tax or law enforcement authorities comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. We will also release information about you if you direct us to do so.
It may also be necessary, under anti-money laundering and similar laws, to disclose information about you to facilitate the establishment of trading relationships for the Funds with prime brokers, executing brokers or other trading counterparties.
We may also disclose information about you, or your transactions and experiences with us, to our affiliates or service providers for our everyday business purposes, such as administration of our business, record-keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, and compliance with applicable legal and regulatory requirements.
We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to the applicable Data Protection Laws. Personal data will be retained for the duration of your transaction or investment in the applicable Fund and for a minimum of five years after the termination of your transaction or a redemption, or withdrawal, as applicable, of your investment, or liquidation of the applicable Fund. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.
To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with applicable Data Protection Laws. These measures include computer safeguards and secured files and buildings.
We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws.
For purposes of U.S. federal law, this Privacy Notice applies to current and former investors who are individuals or Individual Retirement Accounts. We are providing this additional information under U.S. federal law.
We may disclose information about our counterparties, investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary or appropriate, under anti-money laundering and similar laws, to disclose information about the Fund’s investors in order to accept subscriptions from them or about counterparties in order to process transactions. We will also release information about you if you direct us to do so.
We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at (212) 672-2220. If you are a new investor or counterparty, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our investor or counterparty, we may continue to share your information with our affiliates for such purposes.
You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.
We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by the Funds.
The applicable Fund may share your personal information with its services providers, including the Investment Manager, the Administrator, the Sub-Administrator, the Prime Broker or others who are located outside the Cayman Islands. It may also be necessary to share your information with the Cayman Islands Monetary Authority or the Tax Information Authority, which may, in turn, exchange this information with foreign tax authorities, regulatory or law enforcement agencies. Any transfer of your personal data by us, our affiliates or service providers outside the Cayman Islands will be carried out in accordance with the DPL.
You have certain rights under the DPL, including: (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to stop or restrict processing; (v) the right to stop direct marketing; (vi) rights in relation to automated decision making; (vii) the right to seek compensation; and (viii) the right to complain to the supervisory authority. A complaint in respect of the Offshore Fund may be lodged with the Office of the Ombudsman in the Cayman Islands. Please use the contact details under Who to Contact About This Privacy Notice if you wish to exercise these rights.
You may have certain rights under EU General Data Protection Regulation (“GDPR”) in relation to our processing of your personal data and any processing carried out on your behalf. These rights include: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of your personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities); (vi) where relevant, the right to request the portability of the data; (vii) if your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. Please note that the right to be forgotten that applies in certain circumstances under GDPR is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above.
Due to the international nature of our business, your personal data will be processed in the United States, or other jurisdictions that do not offer equivalent protection to personal data as under the GDPR.
Last updated: March 8, 2021
This notice contains disclosures required by the California Consumer Privacy Act (“CCPA”), is only relevant to residents of California, and applies only to the collection or other use of “personal information” that is subject to the CCPA. Consumers with disabilities may access this notice by requesting a PDF version of this policy readable by accessibility software.
Information We Collect. In the past 12 months, we have collected the following categories of personal information about California consumers:
| Category | Examples |
|---|---|
| Identifiers | A real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers. |
| Other personal information categories, as listed in the California Customer Records statute | A signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. |
| Protected classification characteristics under California or federal law | Age (40 years or older), race, citizenship, marital status, sex, veteran or military status. |
| Commercial information | Account activity, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
| Professional or employment-related information | Current or past job history or performance evaluations. |
| Non-public education information | Education records directly related to a student maintained by an educational institution or party acting on its behalf. |
| Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
We do not knowingly collect, solicit, or sell personal information from anyone under the age of 16.
We collect personal information from the following categories of sources:
Use of Personal Information. We may use the personal information we collect for one or more of the following purposes:
Sharing Personal Information. We may disclose personal information in one or more of the categories identified above to:
In the past 12 months, we have not sold any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.
Rights of California Consumers. The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:
You may submit requests relating to your exercise of rights under the CCPA to us:
via phone 212-672-2250.
or
email info@serengeti-am.com
We may need to request additional information from you to verify your identity or understand the scope of your request. In verifying requests, we will require you to provide, at a minimum a telephone number and mailing address. If we are unable to verify your identity, we will need to deny your request.
You may designate an authorized agent to make a CCPA request on your behalf by mailing two forms of identification showing your first name, last name, and current address, and a signed authorization allowing an agent to request information on your behalf.
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