Precision Capital Advisors, LLC Advisory Affiliates and Related Persons Privacy Notice
Commitment to Investor1 Privacy
Precision Capital Advisors, LLC and its advisory affiliates and related persons (collectively the "Firm") is committed to handling information regarding its investors responsibly. New technologies have dramatically changed the way information of all kinds is gathered, used and stored, but the importance of preserving the security and confidentiality of investor information has remained a core value of the firm.
We recognize and respect the privacy expectations of each of our investors. We believe the confidentiality and protection of investor information is one of our fundamental responsibilities.
Collection and Disclosure of Investor Information
Investor information collected by or on behalf of the firm is obtained directly from the investor or the investor’s professional advisors and generally comes from the following sources:
Subscription agreements, investor questionnaires, investment advisory agreements, investment management agreements, account applications, other required forms and agreements, correspondence, written or telephone contacts with investors regarding their accounts; or
Third parties, such as credit reference agencies, publicly available and accessible directories and sources, bankruptcy registers, tax authorities, including those that are based outside the UK and the EEA if an investor is subject to tax in another jurisdiction, governmental and competent regulatory authorities to whom we have regulatory obligations and fraud prevention and detection agencies and organizations.
The information we collect may include a client’s name, address, social security or Employee Identification Number, assets, net worth, income, investments, beneficial interests, investment history and other personal financial data. In addition, we obtain information about clients interest in funds (such as capital account balances and percentage interests) from the funds themselves and their other service providers. Some laws require us to explain our lawful reason for processing your personal information. We process personal information about you on the basis that it is:
necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfil that contract (i.e. to provide you with services)
in our or a third parties’ legitimate interests: for example, the investigation of any complaints, claims, proceedings or disputes or to protect our business against fraud, breach of confidence, theft of proprietary materials, and other financial or business crimes;
where you give us your consent: we only ask for your consent in relation to specific uses of personal information where we need to and, if we need it, we will collect it separately and make it clear that we are asking for consent
for compliance with a legal obligation (e.g., to respond to a court order or a regulator)
We will use investor information in accordance with this privacy policy and for the following purposes:
to verify your identity for the purpose of preventing fraud or other financial crime, complying with statutory, regulatory and internal compliance requirements for on-boarding in relation to anti-money laundering requirements;
to contact you with information about other products and services which may be of interest, unless you have requested not to receive such information, and compiling market research and statistical analysis;
administering your investment through us pursuant to your agreement with the Firm;
managing your relationship with the Firm;
meeting the legal, taxation, regulatory, reporting and/or financial obligations in relation to the Firm in the United States or elsewhere; and
disclosing personal data to other functionaries of the Firm for the purpose of investor communications, accounting, legal, tax and regulatory filings, reporting and other administrative activities related to operating the Firm.
If you do not provide all of the information requested by or on behalf of the Firm, then the Firm may not be able to provide you with or access to all of their products and services (but without prejudice to any terms of your agreement with the Firm for products or services that may apply).
We may disclose investor information to affiliated and non-affiliated third parties including:
- governmental, regulatory, taxation authorities to comply with the Firm's legal, regulatory and statutory obligations;
- third party service providers or agents (including delegates, investment advisers, investment brokers, professional advisors and any third party which provides administration functions in relation to the Firm, including the administrator in any of its capacities) appointed by such persons to provide services and perform obligations on behalf of the Firm to you; and
- any other third party as authorised by you.
If you provide information (including personal information) about someone else, it is your responsibility to ensure that you have obtained appropriate authority to disclose that information to the Firm for the purposes as described in this privacy policy. In particular, you shall ensure the individual concerned is aware of the various matters detailed in this privacy policy, as those matters relate to that individual, including the identity of the Firm, how to contact the Firm, the purposes of collection of the information, the individual's right to obtain access to their personal information and the consequences if the information is not provided (such as the Firm's inability to perform its obligations under the agreement with you).
International Transfers of Investor Information
Your information may be stored and processed outside of your home country, including in countries that may not offer the same level of protection for your personal information as your home country. We have measures in place to ensure that when your personal information is transferred internationally, it is subject to appropriate safeguards in accordance with data protection laws. Often, these include contractual safeguards.
The areas in which these recipients are located will vary from time to time, but include the United States, Europe, and other countries where the Firm has a presence or uses contractors.
When we transfer personal information internationally, we put in place safeguards in accordance with applicable law (including the EU General Data Protection Regulation). If you would like to know more about our data transfer practices and obtain copies of any relevant safeguarding measures, please contact investor.relations@precisioncapital.com.
Security of Investor Information
We restrict access to non-public personal information about investors to those employees who need to know that information to provide products or services to that investor. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard an investor's non-public personal information.
When information about investors is disclosed to non-affiliated third parties, we require that the third party maintain the confidentiality of the information disclosed and limit the use of information by the third party solely to the purposes for which the information is disclosed or as otherwise required by law.
We adhere to the policies and practices described herein regardless of whether the investor is a current or former investor. The Firm may keep personal information provided it has an ongoing legitimate business need to do so (including without limitation to provide you with a service that you have requested or to comply with any applicable legal, tax or accounting requirements), does not retain personal data for longer than needed for such ongoing legitimate business needs and usually deletes personal information at the latest 5 years following the date upon which you cease to be an investor with the Firm. The Firm may also retain personal data for the purposes of responding to any questions or complaints, maintaining records according to rules that apply to you, or preventing fraud or other financial crime.
Your Rights
You may have rights under European and other laws to have access to your personal information and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.
We will honor your rights under applicable data protection laws. You have the following rights under European laws, and may have similar rights under the laws of other countries.
Right of subject access: The right to make a written request for details of your personal information and a copy of that personal information
Right to rectification: The right to have inaccurate information about you corrected or removed
Right to erasure (“right to be forgotten”): The right to have certain personal information about you erased
Right to restriction of processing: The right to request that your personal information is only used for restricted purposes
Right to object: The right to object to processing of your personal information in cases where our processing is necessary for our or a third party’s legitimate interests
Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format
Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent
These rights are not absolute and they do not always apply in all cases. In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.
You can request, at any time, that the personal data provided is not used to contact you about other products and services by sending an email to investor.relations@precisioncapital.com.
Contacting Us
If you have any questions, comments, complaints or suggestions in relation to data protection or this policy, or any other concerns about the way in which we process information about you, please contact us at investor.relations@precisioncapital.com.
Making a Complaint
If you are unhappy about the way in which the Firm collects or uses the personal information or the way in which a complaint has been handled, you have a right to complain to the data protection authority in the jurisdiction in which you are domiciled, or where the alleged infringement of the applicable data protection laws has taken place. For more information investors should contact their local data protection authority. If you would like assistance in identifying your local data protection authority please contact us at investor.relations@precisioncapital.com.
The policy we have outlined here is current as of the date hereof, but as circumstances or requirements change, we may need to amend this policy. We will notify our investors of any such amendment.
Cookies
We and our third-party providers set and use cookies and similar technologies to store and manage user preferences, deliver targeted advertising, enable content, and gather analytic and usage data, for example. The use of cookies and other tracking technologies is standard across websites and apps through which information is collected about your online activities across applications, websites, or other services. More information about how we use cookies and similar technologies and how you can control and manage them is below.
What is a Cookie?
A cookie is a small text file that is placed on a computer or other device and is used to identify the user or device and to collect information. Cookies are typically assigned to one of four categories, depending on their function and intended purpose: absolutely necessary cookies, performance cookies, functional cookies, and cookies for marketing purposes.
Types of Cookies and Why We Use Them
Absolutely Necessary Cookies: These cookies are essential to enable you to move around a website and use its features.
Performance Cookies: These cookies collect information about how you use our websites. Information collected includes, for example, the internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These cookies only collect information in an aggregated format. Performance cookies are used to improve the user-friendliness of a website and enhance your experience.
Functionality Cookies: These cookies allow the website to remember choices you make (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of web pages. They may also be used to provide Services you have asked for, such as watching a video or commenting on a blog. These cookies cannot track your browsing activity on other websites.
Targeting and Advertising Cookies: These cookies track browsing habits and are used to deliver targeted (interest-based) advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They remember that you have visited a website and this information is shared with other organizations, such as advertisers.
Managing Cookies
You can delete all cookies that are already on your computer and you can set most browsers so they don’t place them. If you do, you may have to manually adjust some preferences each time you visit the website, or app, and some services and features may not work. For more information about cookies, visit aboutcookies.org.uk
SMS Data Privacy Policy Effective Date: December 1, 2024
Precision Capital Advisors, LLC respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, and share information when you opt in to receive SMS messages from us.
Information We Collect
When you opt-in to receive SMS messages, we collect:
Your phone number
Consent to send SMS messages
The content of SMS messages sent and received
How We Use Your Information
We use the collected information strictly for communication purposes, specifically for:
Communication: Responding to inquiries or requests for information via SMS
Legal Compliance: Complying with applicable laws and regulations
Sharing Your Information
We will not share, sell, or disclose your information to third parties except:
Service Providers: We may share your information with trusted third-party service providers that assist us in operating our SMS services. These parties are required to maintain the confidentiality and security of your information.
Legal Requirements: We may disclose your information if required by law or in response to a legal request, such as a subpoena, court order, or government demand.
Your Rights
You can opt out of receiving SMS messages at any time by replying with “STOP” to any message we send you. This privacy policy will follow the requirements of TCPA for U.S. messaging.
Data Security
We take reasonable measures to protect your information from unauthorized access, disclosure, alteration, or destruction including compliance with CCPA standards.
We may update this Privacy Policy from time to time. Any changes will be effective when we post the revised policy on our investor portal. We encourage you to review this Privacy Policy periodically.
If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at: investor.relations@precisioncapital.com or 212-476-9300.