Privacy Policy
PRIVACY POLICY
CFI Partners, LLC (“Company”) is committed to protecting the privacy of users of this Data Room website www.cfipartners.fundportal.io (the “Website”). This Privacy Policy describes how Company gathers and uses information about visitors to our Website (“Visitors”). This Privacy Policy applies solely to the information that we collect through the Website. This Privacy Policy does not address personal information that you provide to us in other contexts (e.g., through a business relationship not handled through the Website). This Website is solely directed to, and intended for, Company’s business customers, and not for individuals. Acceptance of Privacy Policy By using the Website, you signify your acceptance of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Website. Your continued use of the Website following the posting of changes to these terms will mean that you accept those changes. How Do We Collect Your Personal Information?
Information You Provide. You may visit our Website without telling us anything about yourself. If you contact us and choose to provide personally identifiable information (“Personal Information”), such as your email address or mailing address when you submit a question or request through our “Contact” page, we will use that information and may share it with other companies and/or individuals (e.g., our partners, consultants, and service providers) for the purpose for which you submitted it to us.
Domain Information. From time to time, our Website may be configured to collect domain information. This data enables us to become more familiar with which users visit our site, how often they visit and what parts of the site they visit most often. Company uses this information to improve our Website. No personally identifiable information is gathered in this process. This information is collected automatically and requires no action on your part.
How Do We Use Your Personal Information? If you choose to provide us with Personal Information by completing a form on the Website or emailing us, we will use that Personal Information to (i) operate the Website, (ii) respond to your question or request, (iii) communicate with you about our products or services via email, (iv) send information to you, and (v) notify you of changes to this Privacy Policy. Do We Disclose Any Personal Information to Outside Parties? Unless you expressly give us permission in writing to do so, Company will not sell, rent, license, or trade your Personal Information other than as specified in this Privacy Policy. Disclosures to Third Parties Assisting In Our Operations. Company may share your Personal Information under confidentiality agreements with other companies that work with, or on behalf of, Company to provide products and services. These companies may use your Personal Information to assist Company in its operations. However, these companies do not have any independent right to share this information. Disclosures Under Special Circumstances. We may provide information about you to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law. In such circumstances, we will take appropriate measures to ensure that the requester understands the sensitive nature of the Personal Information that they may receive. Business Transfers. We may share your Personal Information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of Company’s business to such business entity. We will require any such successor business entity to honor the terms of this Privacy Policy. Automatically Collected Information and Anonymous Information Each time a Visitor comes to the Website, Company collects some information to improve the overall quality of the Visitor’s online experience. Aggregated Data. Company collects aggregate queries for internal reporting and also counts, tracks, and aggregates the Visitor’s activity into Company’s analysis of general traffic-flow at the Website. To these ends, Company may merge information about you into aggregated group data. In some cases, Company may remove personal identifiers from Personal Information and maintain it in aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information. Such anonymous, group data may be shared on an aggregated basis with Company’s affiliates, business partners, service providers and/or vendors; if it does so, Company will not disclose your individual identity.
Web Server Logs and IP Addresses. An Internet Protocol (“IP”) address is a number that automatically identifies the computer or device you have used to access the Internet. The IP address enables our server to send you the web pages that you want to visit, and it may disclose the server owned by your Internet Service Provider. Company may use IP addresses to conduct Website analyses and performance reviews and to administer the Website.
Cookies and Web Beacons. Periodically, some pages on this Website may use “cookies,” which are small files that the site places on your hard drive for identification purposes. These files are used for site registration and customization the next time you visit us. You should note that cookies cannot read data off of your hard drive. Your web browser may allow you to be notified when you are receiving a cookie, giving you the choice to accept it or not. You can also refuse all cookies by turning them off in your browser. By not accepting cookies, some pages may not fully function and you may not be able to access certain information on this Website. Information that we collect through cookies includes (i) the name and version of the operating system on the Visitor’s computer, (ii) the name and version of the Visitor’s browser, (iii) which page on the Site the Visitor is currently reading, as well as clicks and time spent on a particular page, (iv) if the Visitor was sent to the current page by some other page on the web, the universal resource locator (“URL”) of the referring web page, and (v) geolocation of the Visitor’s computer or device. Some of the Site’s web pages may use web beacons in conjunction with cookies to compile aggregate statistics about Site usage. A web beacon is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) that is commonly used to track the traffic patterns of users from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of the Website. Some web beacons may be unusable if you elect to reject their associated cookies.
Security
The security of your data is very important to Company. We have implemented appropriate security measures preventing your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. However, you should know that no website operator, including Company, can fully eliminate security risks associated with Personal Information. While Company has endeavored to create a secure and reliable website for users, the confidentiality of any communication or material transmitted to/from the Website or via e-mail cannot be guaranteed.
Children's Privacy Protection Under Age 13 Company understands the importance of protecting children's privacy in the interactive online world. The Website is not designed for, or intentionally targeted at, children under 13 years of age. It is not our policy to intentionally collect or maintain information about anyone under the age of 13. No one under the age of 13 should submit any Personal Information to Company or the Website. Under Age 18 Minors under 18 years of age may have the Personal Information that they have provide to Company through the Website deleted by sending an email to helpdesk@cfipartners.com requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems. Response to “Do Not Track” Signals Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, Company does not process or respond to “Do Not Track” signals. Updating Your Information
If you wish to stop receiving e-mails or other communications from us, or if you have submitted Personal Information through our Website and would like that information deleted from our records, please notify us at helpdesk@cfipartners.com.
Links to Third Party Websites
As a convenience to our Visitors, this Website may contain links to other sites that we believe may offer useful information. As stated in more detail in the Website Terms of Service, the terms of usage and other conditions of use posted on those sites, and not the policies and procedures we described here, apply to those sites. Your linking to any other websites is at your own risk, and you are responsible for learning about and complying with the terms of usage and other conditions posted on those websites.
Changes to this Privacy Policy
This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on the policy in the upper right corner of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any change to this Privacy Policy regarding use or disclosure of Personal Information, we will provide advance notice on the Website. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.
For Additional Information
If you have any questions about this Privacy Policy, the practices of this Website, or your dealings with this Website, please contact the Chief Compliance Officer, Joe Sommer: JSommmer@cfipartners.com.
DATA PROTECTION NOTICE
The purpose of this Data Protection Notice (the “Notice”) is to provide you with information on the use of your personal data in accordance with applicable federal and state data protection legislation in the United States, the Cayman Islands Data Protection Act (As Revised) and, in respect of EU data subjects, the EU General Data Protection Regulation (together, the "Data Protection Legislation"). Please read this Notice carefully to understand how we and persons engaged by us will use, store, share and otherwise process your personal data.
We do not disclose nonpublic personal data about our clients or former clients to third parties other than as described below.
In this document, "we", "us" and "our" refers to CFI Partners, LLC.
Personal data we collect. We collect personal data about you, and others connected with you, in connection with making an investment. You will provide us with certain personal data which may constitute personal data within the meaning of the Data Protection Legislation. This information includes information such as your:
• Name; • Address; • Tax Identification Number; • Assets; • Investment Experience; • Transaction History; • Income; and • Wire Transfer Instructions.
How we collect this information. We collect this information from you through various means. For example, when you give us your contact information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, tell us where to send money, or make a wire transfer. We also may collect your personal data from another person on your behalf, other public accessible directories and other sources, such as our affiliates or other non-affiliated companies.
Our affiliates are companies related to us by common ownership or control and can include both financial and nonfinancial companies. Non-affiliates are companies not related to us by common ownership or control and can include both financial and nonfinancial companies.
How we use this information. We may collect, store and use your personal data for lawful purposes including the following:
The processing is necessary for the performance of a contract, for example: • administering or managing the Fund; • processing your subscription and investment in the Fund, such as entering your information in the register of shareholders; • sending you statements relating to your investment; • providing advisory services to you; • opening an account for you; and • processing a transaction for your account.
In pursuance of our legitimate interests, or those of a third party to whom your personal data are disclosed, for example: • complying with a legal, tax, accounting or regulatory obligation to which we or the third party are subject; • assessing and processing requests you make; • managing our risk and operations; • complying with audit requirements; • ensuring internal compliance with our policies and procedures; and • marketing products and services to you.
The processing is necessary for compliance with applicable legal or regulatory obligations, for example: • undertaking investor due diligence including anti-money laundering and counter-terrorist financing checks, including verifying the identity and addresses of our investors (and, where applicable, their beneficial owners); • sanctions screening and complying with applicable sanctions and embargo legislation; • complying with requests from regulatory, governmental, tax and law enforcement authorities; and • responding to court orders and legal investigations.
We will only process your personal data in pursuance of our legitimate interests where we have considered that the processing is necessary and, on balance, our legitimate interests are not overridden by your legitimate interests, rights or freedoms.
Disclosure to others. We may provide your personal data to our affiliates and to firms that assist us in servicing your account and have a need for such information.
We will share your personal data with:
the fund administrator, and its respective affiliates for the purposes set out in this Notice, which include:
• managing our relationship with you;
• delivering the services you require;
• managing your investment;
• supporting and administering investment-related activities;
• complying with applicable investment laws and regulations;
• delivering and facilitating the services needed to support our business relationship with you; and
• supporting and administering investment-related activities,
tax authorities:
• to comply with applicable laws and regulations; and
• where required by tax authorities (who, in turn, may share your personal data with other tax authorities),
our lawyers, auditors and other professional advisors for purposes of: • providing you with investment-related services; and • seeking advice on, and complying with, legal and regulatory requirements or legal rights and obligations.
In exceptional circumstances, we will share your personal data with regulatory, prosecuting and other governmental agencies or departments, and parties to litigation (whether pending or threatened) in any country or territory, as and to the extent required by law.
We will not sell your personal data. However, we may disclose your personal data in connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of a business or operating unit as permitted by Data Protection Legislation.
How we protect your personal data. To protect your personal data from unauthorized access and use, we use security measures that comply with applicable data protection laws. These measures include computer safeguards and secured files and buildings.
Sending your personal data internationally. Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection of personal data as under the Data Protection Legislation. In such cases, we will process personal data or procure that it be processed in accordance with the requirements of the Data Protection Legislation, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf.
Retention and deletion of your personal data. We will keep your personal data for as long as it is required by us. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. We will generally retain your personal data throughout the lifecycle of the investment you are involved in. Some personal data will be retained after your relationship with us ends. We expect to delete your personal data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal data.
Automated decision-making. We will not make decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your personal data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the applicable requirements under the Data Protection Legislation.
Your rights. You have certain data protection rights, including the right to:
• be informed about the purposes for which your personal data are processed; • access your personal data; • stop direct marketing or sharing for cross-context behavioral advertising; • restrict the processing of your personal data; • have incomplete or inaccurate personal data corrected; • ask us to stop processing your personal data; • be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you); • complain to a data protection authority; and • require us to delete your personal data in some limited circumstances.
Who is providing this Notice. This Notice relates to the following entities:
• CFI Partners, LLC
Who to contact with questions. If you have any questions about this Notice or the personal data we hold about you, please contact Joe Sommer, Chief Compliance Officer, at jsommer@cfipartners.com.