Effective: December 2021
This notice (the “Privacy Notice”) explains how PAAMCO Prisma, LLC and its group companies[1] (“PAAMCO Prisma”, “we”, “us”, “our”) collects, uses, shares, and otherwise processes your Personal Data in compliance with the General Data Protection Regulation (the “GDPR”). PAAMCO Prisma is a Data Controller with its main office at:
660 Newport Center Drive
Suite 930
Newport Beach, CA 92660
United States of America
This Privacy Notice also explains how investment funds or accounts managed or operated by PAAMCO Prisma that are organized in the Cayman Islands (each a “Cayman Islands Fund”) collect, use, share, and otherwise process Personal Data under the Cayman Islands Data Protection Law (as amended, the “Cayman DPL“). For the purposes of the Cayman DPL, the relevant Cayman Islands Fund is a Data Controller, and for the purposes of this Privacy Notice, the terms “we“, “us“, “our” includes the Cayman Islands Funds as the context requires.
YOUR DATA
PAAMCO Prisma (and/or the Cayman Islands Fund, where applicable) as a Data Controller, is committed to safeguarding your data. We do not sell, rent, or trade your Personal Data to any other party.
WHAT IS PERSONAL DATA?
The term “Personal Data” as used in this Privacy Notice means any identifiable information relating to you, such as:
- Identification data (e.g., names, addresses, phone numbers, e-mail addresses, business contact information);
- Personal characteristics (e.g., date of birth, country of birth);
- Professional information (e.g., employment and job history, title, qualifications);
- Identifiers used by public agencies (e.g., passport, ID card, tax identification number, social security number);
- Financial information (e.g., financial and credit history information, bank details); and
- Transactional / Investment data (e.g., current and previous investments, investment profile, investment preferences, invested amounts, number and value of shares held, role in a transaction, transaction details).
Personal Data does not include data from which you can no longer be identified such as anonymised aggregate data.
WHY DOES PAAMCO PRISMA COLLECT PERSONAL DATA?
PAAMCO Prisma may collect, use, share, and process your Personal Data as part of your relationship with PAAMCO Prisma as a PAAMCO Prisma client, current or prospective PAAMCO Prisma employee, PAAMCO Prisma prospective client, PAAMCO Prisma service provider, PAAMCO Prisma subadviser / investment manager, client representative, or if you are generally interested in PAAMCO Prisma’s services or publications.
WHAT PERSONAL DATA DOES PAAMCO PRISMA COLLECT?
We may collect Personal Data including your contact details and job title; and collect other Personal Data that you provide to us via letter, telephone, e-mail, or other means of communication. Additionally, we may obtain information from your agents and representatives, online sources, and from or through other services such as background checks.
We will only collect and process Personal Data for and to the extent necessary for the specific purpose(s) we have arranged with you.
WHEN WILL PAAMCO PRISMA PROCESS MY PERSONAL DATA?
We will only process your Personal Data if there is a lawful basis for doing so. That means we will only process your Personal Data if:
- We, or a third party, have a legitimate interest in your Personal Data that is not overridden by your interests, fundamental rights, or freedoms. Examples of PAAMCO Prisma’s legitimate interests include, without limitation, the provision of legal, administrative, or operational processes both internally and externally;
- We require your Personal Data to perform the contract we have entered into with you; or
- We require your Personal Data to comply with legal or regulatory obligations, such as those relating to accounting, compliance with securities legislation, bookkeeping requirements, cooperation with authorities or law enforcement, or fraud prevention.
HOW WILL PAAMCO PRISMA PROCESS MY PERSONAL DATA?
We will use your Personal Data to deliver services to you or the institution you are acting on behalf of.
We may also use your Personal Data to inform you of our services and new developments.
Some examples of Personal Data processing we may perform include:
- Assessing your needs as a client or prospective client;
- Undertaking relevant review procedures and analysis to guard against fraud, money laundering, bribery and other illegal activities;
- Receiving and processing complaints; and
- Analyzing data, identifying trends, and developing the firm’s business services.
In order to ensure that our processing of your data is lawful, such processing will only be undertaken if it is:
- Necessary for the purposes of legitimate interests pursued by us or by a third party, except where those interests are overridden by your interests, fundamental rights, or freedoms requiring the protection of Personal Data;
- Necessary for the performance of a contract to which you are, or will be, a party;
- Necessary for compliance with a legal obligation to which we are subject;
- Necessary to protect your vital interests; or
- To perform a task in the public interest or in the exercise of official authority vested in us.
HOW LONG WILL PAAMCO PRISMA RETAIN MY PERSONAL DATA?
PAAMCO Prisma will only retain your Personal Data for as long as is necessary for it to fulfil the purposes of its collection and processing, including for the purposes of satisfying any legal, contractual, regulatory, accounting, or reporting requirements.
In determining the appropriate retention period for your Personal Data, we will consider the quantity, nature, and sensitivity of the Personal Data; the potential risk of harm from unauthorised use or disclosure of your Personal Data; the purposes for which we process your Personal Data and whether we can achieve those purposes through other means; and the applicable legal or regulatory requirements for such retention.
Following the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.
WHO WILL MY PERSONAL DATA BE SHARED WITH?
We may use or disclose your Personal Data if we are required by law to do so, or if we reasonably believe that use or disclosure of your Personal Data is necessary to protect our rights.
When using your Personal Data for the purposes and on the legal basis described above we may share your Personal Data with other PAAMCO Prisma offices around the world as well as with affiliates we work with. Where we use third parties to undertake functions on our behalf, we will share relevant information with such third parties (e.g. administrators, custodian banks, and background check service providers). We may also be required to share your Personal Data with regulators; government institutions; courts; or other third parties that have the power to demand disclosure.
Generally, we will not transfer your Personal Data outside of the EEA (or, in the case of the Cayman Islands Fund, the Cayman Islands) without your knowledge, and any such transfer will be conducted in accordance with the standards expressed through EU Commission’s Decisions on standard contractual clauses relating to such transfers under Directive 95/46/EC or as amended under the GDPR or, where relevant, the applicable equivalent measures under the Cayman DPL.
YOU HAVE RIGHTS OVER YOUR PERSONAL DATA
You have rights as an individual which you may exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:
- Request access to your Personal Data;
- Request information about how your Personal Data is processed;
- Request rectification of your Personal Data where it is inaccurate or incomplete;
- Request the deletion of your Personal Data;
- Request information about the recipients or categories of recipients of your Personal Data;
- Request restriction of the processing of your Personal Data;
- Object to the processing of your Personal Data;
- Complain to the relevant supervisory authority; and
- Withdraw consent for the processing of your Personal Data.
If you wish to exercise one of these rights, please contact us at Privacy@PaamcoPrisma.com.
WHAT IF I DON’T WANT TO PROVIDE MY PESONAL DATA?
It is entirely up to you to provide Personal Data to PAAMCO Prisma. If you do not provide us with all or some of the Personal Data we request, or request its deletion, we may not be able to enter into a relationship with you or the institution you represent, to provide all or some of our services, or be able to send you requested marketing information.
ACCURACY OF INFORMATION
We want to ensure any Personal Data we hold on you is accurate and up to date. Please let us know if there are any changes to your Personal Data during your relationship with us.
ANONYMIZATION, CHANGE OF PURPOSE
We will only use your Personal Data for the purposes for which we collect it, unless we reasonably conclude that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
FEES
You generally should not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Notice. However, we may charge a reasonable fee if your request to exercise your individual rights as set out above is unreasonable, unfounded or excessive. Alternatively, we may refuse to grant such a request, provided there is a lawful basis for doing so.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this Privacy Notice at any time, and we will make an updated copy of such privacy notice available on our website.
CONTACT INFORMATION
Should you have any questions about our privacy policy or about the Personal Data we hold about you, please send an e-mail to Privacy@PaamcoPrisma.com.
[1] PAAMCO Prisma’s group companies include Prisma Capital Partners LP (“Prisma”), PAAMCO Prisma Europe LLP (“PAAMCO Prisma Europe”), PAAMCO Launchpad, LLC (“PAAMCO Launchpad”), and Prisma Capital Management LLC (“PCM”). “PAAMCO Prisma” collectively refers to PAAMCO Prisma, LLC, Prisma, PAAMCO Prisma Europe, PAAMCO Launchpad, and PCM.