Privacy Policy

This Privacy Notice sets forth the policies of Alarad Capital LLC (together with its affiliates, “Alarad”) and the funds to which Alarad provides administrative or investment management services with respect to the collection, use, storage, sharing and disclosure (collectively, “processing”) of non-public and other sensitive personal information. These policies apply to individuals only and may be modified at any time. You should check this website periodically for updates.

Information We Collect

We may collect your personal information when conducting our business, including when you contact us, seek information from us, use our website or provide services to us. The types of personal information about you that we may process include your name, address and other contact details, photographs, social security or other tax identification number, nationality, place of birth, account information, assets, transaction and/or income information, materials necessary to verify personal information (e.g., copies of passports or utility bills), and other information (including potentially sensitive information) that may be derived from the information and documentation that we collect. This information is collected primarily (i) in subscription agreements and related documents and background checks to satisfy anti-money laundering and sanctions compliance obligations, (ii) in correspondence and conversations with us and our representatives, (iii) through transactions in a Alarad fund, (iv) through applications for employment and (v) in your everyday business dealings with us. We may also receive your personal information from third parties or other sources, such as third-party account administrators and publicly accessible sources (e.g., the internet or social media).

How We Use and Share Your Information

We may disclose your personal information to third parties, and we and such third parties may process your personal information only for the reasons listed below. The third parties to whom your personal information may be disclosed include, without limitation, auditors and accountants, attorneys, brokers and trading counterparties, back-up data storage providers, employees, consultants, temporary workers and third-party account administrators.

  • Legal and everyday business purpose: Your personal information may be processed for the purposes of administering the relationship between us (including communications and reporting), monitoring and analyzing our activities, and everyday business purposes. Your personal information may also be processed to comply with our policies and applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, compliance, or responding to subpoenas, court orders or other requests for information from regulatory, supervisory, law enforcement or judicial agencies).
  • For marketing purpose: Your personal information may be processed by Alarad to market products and services to you.
  • To manage your investments: Your personal information may be disclosed to or processed by certain service providers we have engaged to help us review requests for subscriptions or withdrawals from you and to manage your investments.
  • With your authorization or for other purposes permitted by law: Your personal information may be shared with or processed by certain persons with your consent, upon your instruction, or for any purposes permitted by applicable law.

Cookies and Tracking Technologies

This website may use “cookies,” which from time to time automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of this website. Cookies also help us diagnose problems with our server and analyze how visitors use our website.

You may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies. However, if you block or otherwise reject cookies or similar technologies, certain websites (including this website) may not function as expected. Without refusing cookies through your browser, you can also opt out of Google Analytics by installing a [Google Analytics Opt-out Browser Add-on] for each web browser you use.

How We Protect Your Information

We maintain physical, electronic and procedural safeguards to protect your personal information. The entities performing services for us are directed to protect your personal information and to only use such information in connection with the services we have contracted with them to perform. From time to time, we may review the purpose for which personal information has been collected and decide whether to retain or delete such information if we are permitted to do so under applicable law.

Notice Concerning Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. At this time, we do not recognize or respond to DNT signals. You can learn more about Do Not Track here. [https://allaboutdnt.com]

California Collection Notice

If you are a California resident, California law requires us to provide you with some additional information regarding how Alarad collects, uses, and shares your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). Please note the CCPA’s scope excludes personal information covered by certain financial services-specific privacy laws, including the Gramm-Leach-Bliley Act (GLBA) and California Financial Information Privacy Act (FIPA). Our separate Privacy Notice that is provided to investors applies to this excluded data and has been provided to our fund investors.

Depending on how you interact with our website and services, we may collect the following categories of information from you, in addition to the information we collect in connection with providing financial products and services:

  • Identifiers (such as your name and contact information, IP address, and mobile device identifiers);
    • We share identifiers with service providers, including Google Analytics.
    • Our business and commercial purposes for collecting and sharing this information are to operate our website, to communicate with you, and for legal and everyday business purposes.
  • Internet usage information (such as browsing history and use and interaction with our website).
    • We share internet usage information with service providers, including Google Analytics.
    • Our business and commercial purposes for collecting and sharing this information are to operate our website, to communicate with you, and for legal and everyday business purposes.

This information is used and disclosed for the various business purposes and to the categories of third parties described in the “How We Use and Share Information” section of the privacy notice, above.

Your California Privacy Rights

If you are a California resident, you may have certain rights.

California law may permit you to request that we:

  • Provide you with the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
  • Provide you with access to and/or a copy of certain personal information we hold about you.
  • Delete certain personal information we have about you.

You may have the right to receive information about the financial incentives that we offer to you for your personal information (if any). You also have the right not to be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we may need certain information to provide services to you or for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use some of our services.

Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

Additional Information for California Residents

Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties, and gives California residents the right to opt out of the “sale” of personal information. We do not engage in such activity and have not engaged in such activity in the past twelve months, nor do we have actual knowledge that we have engaged in such activity in connection with individuals under 16 years of age. We do share certain information and allow parties to collect certain information about your activity, for example through cookies. We explain our use of cookies and how you can control cookies in the How We Use and Share Your Information and the Cookies and Tracking Technologies sections. 

Additional Privacy Terms

If you do not wish us to share your non-public personal information for marketing purposes, or have any other questions or requests with regard to how we process your personal information, you may contact Alarad’s Chief Compliance Officer by calling 617-276-6024.  U.S. federal law gives you the right to limit only certain types of information sharing. U.S. state laws and individual companies may give you additional rights to limit information sharing. If you limit information sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account.

[**If you are an individual (including, for purposes of this section of the Privacy Notice only, an individual associated with an investor in a Alarad fund) and the fund in which you are invested is organized in the Cayman Islands (including any master fund in which you are indirectly invested), such fund and Alarad are considered to be data controllers in respect of any personal information we hold about you for the purposes of the Cayman Islands Data Protection Law 2017 (the “DPL”). This means that the fund and Alarad (alone or jointly, as applicable) determines the purposes and the means of the processing of your personal information.  We may share your personal information with the fund’s services providers 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 or our service providers outside the Cayman Islands will be carried out in accordance with the DPL.  You may have certain rights under 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 a Alarad fund organized in the Cayman Islands may be lodged with the Office of the Ombudsman in the Cayman Islands.**] Not required yet as you don’t have a Cayman fund.

If you are an individual (including, for purposes of this section of the Privacy Notice only, an individual associated with an investor) resident in the European Economic Area, your personal information will be processed as described herein by us and other parties in countries outside the EEA, including the United States, India and Bermuda, which may not offer the same level of protection of personal information as the EU General Data Protection Regulation 2016/679 (“GDPR”).  Please be advised that certain aspects of the GDPR may not be consistent with the laws and regulations applicable to us.

Close Bitnami banner
Bitnami