Vatic Investments, LLC (the “Trading Advisor”) is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by the Trading Advisor is controlled by the Trading Advisor and the Trading Advisor is the data controller of your personal information. Where your details are provided to the Trading Advisor as a consequence of your investment (or potential investment) in the private investment fund set forth on the cover page of this policy (the “Fund”), then the Trading Advisor, acting as a data controller, may itself (or through a third party such as NAV Fund Services (Cayman) Ltd. (the “Administrator”) acting in its capacity as the Fund’s administrator) process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (the foregoing collectively, “Your Personal Information”). When processing Your Personal Information, there may also be times when the Administrator will act as a data controller.
The Trading Advisor’s European Union representative is located in the United Kingdom at Katten Muchin Rosenman, Paternoster House, 65 St. Paul’s Churchyard, London EC4M 8AB and can be contacted at email@example.com.
The Trading Advisor collects Your Personal Information from the following sources, as applicable:
Your Personal Information may be processed by the Trading Advisor and/or the Administrator (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes, as applicable:
The Trading Advisor’s servers, which store and keep Your Personal Information, are located in the United States.
The Trading Advisor and the Administrator are able to legally collect and use Your Personal Information either because:
The Trading Advisor and the Administrator will retain Your Personal Information for the purposes described in (i), (ii), and (iii) in the immediately preceding paragraph as long as required for the purposes described above.
You have the right to:
To make any requests as listed above, please contact the Trading Advisor at firstname.lastname@example.org.
The Trading Advisor will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.
You can tell the Trading Advisor to stop collecting, using and retaining Your Personal Information at any time by emailing the Trading Advisor at email@example.com. You should note that notwithstanding your withdrawal of consent, the Trading Advisor may be legally required to retain some or all of Your Personal Information.
Where the Trading Advisor or the Administrator requires Your Personal Information to comply with AML or other legal requirements, failure to provide this information will mean that you will be unable to be accepted as an investor in the Fund and/or may be mandatorily redeemed from the Fund if you are already an Investor.
The Trading Advisor maintains appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards that comply with the GDPR to protect customer information, including:
The Trading Advisor restricts access to the personal and account information of Investors to those employees who need to know that information in the course of their job responsibilities. The Trading Advisor will destroy, erase or make unreadable data, computer files and documents containing Your Personal Information that is non-public prior to disposal.
If you would like to make a complaint about the way the Trading Advisor has collected, used or retained Your Personal Information, please contact us at firstname.lastname@example.org.
You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by the Trading Advisor or its service providers infringes the GDPR.