We at HedgServ Holding L.P. and its affiliates HedgeServ Corporation, HedgeServ Limited, and HedgeServ Cayman Limited (collectively "HedgeServ", "we" or "us") respect your right to the protection and privacy of your Personal Data.
HedgeServ recognises its responsibility for protecting and ensuring the privacy and confidentiality of the information it obtains, retains, uses and discloses in the course of its business and operations.
The purpose of this Privacy Statement (the "Statement") is to outline how we will use or deal with your Personal Data for the purposes of enabling you to use this investor portal application (the "Portal").
Nothing in this Statement is to be construed as suggesting HedgeServ acts as a data controller (as defined in the applicable data protection law ("Data Protection Law"), including, without limitation, the Cayman Islands Data Protection Law, 2017 (as amended and/or supplemented from time to time)) with respect to the Personal Data provided to us through this Portal. HedgeServ acts as a data processor (as defined in the Data Protection Law) at all times for and on behalf of the relevant investment fund in connection with all Personal Data collected, stored or otherwise processed by HedgeServ through your use of the Portal and the issue of this privacy notice has not impact on that. In processing the Personal Data, unless otherwise required by applicable law, HedgeServ shall comply with the instructions of the relevant investment funds who act as data controllers with respect to the Personal Data. Such investment fund(s) are responsible for determining the purposes, means and the legal basis for the processing of your Personal Data at all times.
If the intended use by HedgeServ of your Personal Data through this Portal is not acceptable then you should not use this Portal.
HedgeServ is not responsible for the content or privacy practices of any websites other than websites beginning with the URL [https://hiportal.hedgeserv.com/portal]. Any external links to other websites are clearly identifiable as such. This Statement does not cover other websites including the HedgeServ.com website which is subject to a separate privacy statement.
HedgeServ fully respects your right to privacy. Subject to section 3.2 below, Personal Data is not collected by HedgeServ via this Portal, unless you choose to provide such information to us, but some of the Personal Data provided to us as a provider of services to investment funds will be displayed on this Portal.
In addition, like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our Portal.
3.1 "Personal Data"
Personal Data, is information from which a living individual can be identified, either directly or through the use of the information in conjunction with other information that is in, or is likely to come into, the possession of the party processing that information.
Information of this nature is also referred to as Personally Identifiable Information or "PII" and for the purpose of this Statement, all such data or information will be referred to as "Personal Data".
3.2 Cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
This Portal does not use cookies, apart from temporary "session" cookies which enable a visitor's web browser to remember which pages on this Portal that have already been visited. Technical details in connection with visits to this Portal are logged by our internet service provider for our statistical purposes. No information is collected that could be used by us to identify Portal visitors. The technical details logged are confined to the following items:
(a) the IP address of the visitor's web server;
(b) the top-level domain name used (for example .ie, .com, .org, .net, .co.uk);
(c) the previous website address from which the visitor reached us, including any search terms used; and
(d) clickstream data which shows the traffic of visitors around this Site (for example pages accessed and documents downloaded) and the type of web browser used by the website visitor.
4.1 Personal Data
Other than the collection of "cookies" and IP addresses as described at section 3.2 above, we do not collect Personal Data about visitors to this Portal, unless you choose to provide such information to us.
The Personal Data that may be collected by us for the purpose of providing services to investment funds and which may be displayed on this Portal or transmitted within the HedgeServ group includes:
(a) Individual's names,
(b) Contact details including home and work address and professional and personal email addresses,
(c) Any other information including your opinions or other Personal Data provided by you electronically (including by sending us an email).
Please remember that it remains your responsibility to ensure that any information including Personal Data that you send to us, including the content of emails, is within the bounds of the law. Unsolicited material of a criminal nature will be reported to the relevant authorities and blocked.
Personal Data will be used by us for the purposes of this Portal to:
(a) Identify the name of an investor in an investment fund;
(b) Provide information in relation to an investor's holdings in an investment fund;
(c) Provide access to copies of documents containing information to users of this Portal;
(d) Process your request or respond to a communication from. By contacting us in this manner, you consent to the collection and use of your Personal Data for purposes of responding to your request;
(e) Prevent the misuse of this Portal and maintain records of the communications issued through it;
(f) Comply with our legal and regulatory obligations and any requests from law enforcement authorities.
4.2 Non-Personal / Technical Data:
We use non-personal / technical data gathered from visitors to our Portal in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise our Portal.
4.3 Intra-Group Transfer
In order to ensure that any requests or communications issued to us by you are appropriately responded to and dealt with, any Personal Data you provide to us through this Portal or email to us may be shared across the HedgeServ group of entities, some of which are located in countries and territories which may not have the same standards of Privacy or Data Protection as those that are in place where you live. By sending your Personal Data to us you recognise this and consent to this transfer.
HedgeServ will make no attempt to identify individual visitors, or to associate the non-personal / technical details collected with any individual.
It is the policy of HedgeServ never to disclose such technical information in respect of individual Portal visitors to any third party (apart from our internet service provider, which records such data on our behalf and which is bound by confidentiality provisions in this regard), unless obliged to disclose such information by a rule of law.
This Portal is hosted on secure servers by our Internet Service Provider. The nature of the Internet is such that we cannot guarantee or warrant the security of any information accessed via the Internet. No data transmission or access over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect Personal Data.
You may inform us of any changes to the Personal Data about you displayed via this Portal and such requests for updates or changes to your Personal Data, including deletion thereof, will be processed in accordance with the respective legal obligations of the relevant HedgeServ entities. To request your Personal Data to be updated, amended or removed please contact us at hsportalsupport@hedgeserv.com.
For security and Data Protection purposes you will be required to provide evidence to us to verify that you are who you say you are.
Any changes to this Statement will be posted on this Portal.