Global Investor Privacy Notice
This Global Investor Privacy Notice (“Privacy Notice”) describes the ways that PDT Partners, LLC (together with its affiliates, “PDT” “we,” “our,” or “us”) and/or the funds managed by PDT collect, use, and disclose personal information provided to us in connection with an investment in, or the consideration of an investment in, a fund managed by PDT. PDT values and respects the privacy rights of the prospective, current, and former investors (herein “Investors”) in the private investment funds we operate, and the protection of such individuals’ nonpublic personal information is of the utmost importance to us.
If you are or were previously an Investor in any fund managed by PDT Partners, the collection and use of your information is governed by the terms of the Subscription Agreement you have entered into in connection with your subscription to such fund(s). To the extent the terms of this Privacy Notice and the Subscription Agreement conflict, the terms of this Privacy Notice will govern.
If you are an Investor that obtains or has obtained a financial product or service from us used primarily for personal, family, or household purposes, or such an Investor’s legal representative, the Privacy Notice applies to you and the person whom you represent. For the purposes of this Privacy Notice, the term “you” also refers to such an Investor.
If you are a corporate Investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal information on individuals connected to you for any reason in relation to your investment with us, this Privacy Notice will be relevant for those individuals whose information you share with us and you should transmit this document to such individuals or otherwise advise them of its content.
Various laws and regulations use different terms and definitions for personal information of individuals that should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories. This Privacy Notice adopts the broader approach to what information is classified as “personal information” (including nonpublic personal information) and therefore must be protected and kept as private as possible.
How We Collect Personal Information
We may obtain personal information about you in connection with providing investment advisory services to you or to a fund in which you are invested or evaluating your request for such services or investment. A non-exclusive list of examples includes your name, address, e-mail address, social security number, tax identification number, state or national identification information, investment history, account balance and transaction information, bank account information, and other financial information.
We may collect the following types of personal information about you in the following ways or from the following sources:
- Information you provide to us in investor questionnaires, subscription documents, account opening forms, or otherwise;
- Information about your transactions with us, PDT funds, and our affiliates; and/or
- Information you provide to us in your communications with us, including communications in person, by phone, by email, via our website, or by other means.
We collect personal information from you in order to provide the requested services to you. If you do not provide the information requested, we may not be able to provide the services. If you disclose any personal information relating to other people to us or to our service providers in connection with the requested services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
How We Use Personal Information
PDT will only use and disclose personal information for a purpose for which it was originally collected and any related, compatible purposes. The personal information collected by us or by our service providers, agents, or delegates will be used for the purposes set out below:
- We may use your personal information to verify your identity when you communicate with us or our service providers, agents, or delegates to ensure compliance with our legal obligations, or to otherwise authenticate you within our legitimate business interests.
- We use your personal information as required by or in connection with an investment, prospective investment, or former investment in our funds. We also use your information to provide any other services to you (such as arranging access to your registered account, and providing you with related customer service), to complete your transactions and verify your information, or to send administrative information to you (such as changes to our terms, conditions, and policies).
- Personal information may also be processed to comply with legal and regulatory obligations applicable to us or our funds from time to time, such as applicable anti-money laundering, counter terrorism and proliferation financing legislation or to exercise our legal rights where it is necessary to do so, such as to detect, prevent, or respond to fraud claims, intellectual property infringement claims, or violations of law or misuse of our information or our website.
- We may use your personal information to communicate with you as necessary in connection with your investment, prospective investment, or former investment in our funds, which may be necessary to perform a contract with you and is also in our legitimate business interest of providing investment advisory services to you or to a fund to which you subscribe.
- We may aggregate and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
- We may process personal information as we or our service providers, agents, or delegates may consider necessary in connection with your affairs and our affairs or the affairs of the funds managed by us, and generally in connection with the management and administration of your investment, prospective investment, or former investment in a fund managed by us and accounts related to that investment. This may be necessary to perform a contract with you and is also in our legitimate business interest of providing investment advisory services to you or to a fund to which you subscribe.
How We Use Sensitive Personal Information
Subject to the relevant jurisdictional regulatory requirements, PDT may process sensitive personal information while doing business with you. Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or identifiers such as social security or driver’s license numbers, passport numbers, state IDs, or account, credit card, or debit card numbers in combination with the relevant credentials) to us.
The sensitive information that PDT processes may include:
- A person’s social security, driver’s license, state identification card, or passport number.
- The contents of a person’s email, mail, or text messages where PDT is not the intended recipient of the communication.
If PDT purposefully collected sensitive personal information from or about you, PDT will only use and disclose that sensitive personal information for the purpose for which it was originally collected. In the case of emails sent by you to PDT inadvertently, to the extent known by PDT and as reasonably practicable, PDT will take steps to alert you to the inadvertent receipt of the email or delete it.
How We Disclose Personal Information
In the normal course of business, we may disclose personal information to:
- The funds which you are subscribing to;
- Affiliates that have a legitimate business need for the information;
- Nonaffiliated third party service providers (such as administrators, accountants, attorneys and other professional advisors, custodians, auditors, and technology providers) as is necessary to service our funds and their prospective, current, and former Investors; and
- As allowed or required by applicable law or regulation.
Parties that receive personal information from PDT agree to use it only for the services required and as allowed by applicable law and regulation. These individuals are required by contract and/or applicable law or regulation to maintain and protect the confidentiality of personal information they process.
We may share information that is anonymized or aggregated for any purpose and without any limitations.
We restrict access to personal information about you to those employees, agents, or other parties whom we believe need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to guard your personal information.
Except as described in this Privacy Notice or as required or allowed by applicable law and regulation, we will not use personal information for any incompatible purposes without providing a notice describing how it will be used and if any relevant opt-out options may apply.
We do not sell our client’s information and only disclose it to our service providers, agents, or delegates in connection with an investment in a fund managed by us as allowed by law.
Other Uses and Disclosures
We also use and disclose your personal information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations, which may include laws outside your country of residence.
- To cooperate with public and government authorities: For example, to respond to a request or to provide information we believe is necessary or appropriate (these can include authorities outside your country of residence).
- To cooperate with law enforcement: For example, when we respond to law enforcement requests and orders or provide information we believe is important.
- For other legal reasons: For example, to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others.
- In connection with a sale or business transaction: We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
International Transfer of Personal Information
PDT Partners, LLC is based in the United States. Certain service providers, agents, and delegates with which we share your information are located in the United States and Canada and potentially countries other than the European Economic Area (“EEA”), U.K., or Cayman Islands.
In each case, these countries may not be regarded as providing the same level of protection for your information as your country of residence, or where applicable, the Cayman Islands. For a full list of countries covered by an EEA adequacy decision, see this webpage.
In order to provide additional protection for your information, in certain circumstances, we have put in place appropriate safeguards, such as standard contractual clauses for transfers of data to countries not considered adequate by the relevant data protection regulator. Depending on the laws applicable to your personal information, you may have a right to request information on these safeguards and to obtain a copy of them. If you would like to do so, please immediately notify us in accordance with the Contact Information section below.
Safeguarding Your Information
We implement administrative, technical, and physical safeguards designed to safeguard the information collected by us. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contact Information section below.
We retain personal information for as long as needed or permitted under applicable data protection law (if any) for the purpose(s) for which it was obtained and/or as required by applicable law or regulation. We retain data based on policy and timing schedules for all data types.
Criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you (for example, for as long as you have an investment in a fund managed by PDT);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of transactions for a certain period of time before we are allowed to delete them); and/or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations; for example, to comply with our legal or regulatory obligations or our document retention policy, resolve disputes, enforce our agreements, and investigate or defend against potential legal claims).
Your Rights Over Your Personal Information
Depending on where you are located and how or why your personal information was collected, you may have certain rights regarding the personal information we hold about you. These rights may include the right to access, correct, delete, restrict, object to, opt-out or limit our use of, or receive a portable copy in a usable electronic format, of your personal information.
We encourage you to contact us to update or correct your information if it changes, or if the personal information we hold about you is inaccurate. Depending on where you are located and how or why your personal information was collected, as well as where you have provided your consent to any use of your personal information, you can withdraw this consent at any time by contacting us at the Contact Information below.
Please note that we may require additional information from you to verify your identity in order to honor your requests.
Subject to applicable law, you may also lodge a complaint with a data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of EU/EEA data protection authorities is available here. Investors in our Cayman Islands investment funds also have a right to make a complaint to the Cayman Islands Ombudsman, pursuant to the Data Protection Act (As Revised) of the Cayman Islands. California residents can register complaints with the California Office of the Attorney General and/or the California Privacy Protection Agency (after July 1, 2023).
If you would like to discuss or exercise any rights you may have under applicable local law, please contact us at the Contact Information set forth below.
Depending on where you are located and which PDT funds you subscribe to, the General Data Protection Regulation (Regulation (EU) 2016/679), the U.K. Data Protection Act (2018 c 12), the Cayman Islands Data Protection Act (As Revised), or the California Privacy Rights Act (CPRA) and related laws and regulations may apply to personal information that is collected and processed by us or by our service providers, agents, or delegates in connection with an investment in a fund managed by us.
With respect to information subject to the GDPR or the U.K. Data Protection Act, PDT Partners, LLC is the controller responsible for the personal information we collect and process. Our representative in the European Union/UK is PDT Partners UK, LLP. With respect to information subject to the Cayman Islands Data Protection Act (As Revised), the controller is the relevant Cayman Islands investment fund.
If you have any questions about this Privacy Notice or wish to ask us a privacy-related question or make an individual rights request regarding your personal information as described above, you may contact PDT Partners, LLC representatives at email@example.com.
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.
Changes to this Global Investor Privacy Notice
We may modify or update this Global Investor Privacy Notice from time to time. The “Effective Date” legend at the bottom of this Global Investor Privacy Notice indicates when this Global Investor Privacy Notice was last revised. Any changes will become effective when we post the revised Global Investor Privacy Notice.
Effective Date: February 6, 2023
PDT Partners, LLC. All Rights Reserved.