This privacy notice (“Privacy Notice”) describes the ways that PDT Partners, LLC (together with its affiliates, “PDT” “we,” “our,” or “us”) collects, uses, and discloses information that we collect through (i) our website at www.pdtpartners.com (the “Website”), (ii) our social media pages (the “Social Media Pages”), and (iii) HTML-formatted email messages that we send to you that link to this Privacy Notice or other communications with you, offline business interactions you have with us, and other sources. Collectively, we refer to the Websites, Social Media Pages, emails, and offline business interactions as the “Services”.
A separate Job Applicant Privacy Notice applies to PDT’s recruiting efforts. A separate Global Investor Privacy Notice and GLBA Privacy Notice applies if you are an investor, former investor, or prospective investor in funds managed by PDT.
Information We Collect
We and our service providers collect information that you provide us, including without limitation, via email, via telephone, in person, or when you log in to and use our Services. As an example, when you contact us and provide your name and email address, we will store and process that information and any other information you provide. We may also receive your personal information from other sources, for example, publicly available databases, or joint marketing partners, when they share the information with us.
We need to collect personal information 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 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.
We and our service providers also automatically collect certain technical information from the device(s) you use to access our Website over time and across different devices such as your IP address, your ISP provider, your browser type, the pages you view on the Website, the pages you view immediately before and after you access the Website, date/time stamps, and the search terms you enter on the Website. We and third parties, including our service providers, collect this information using “cookies”, web beacons, and similar technologies. For more information about these technologies, please see our Cookies & Similar Technologies Notice.
How We Use Information
We use the information we collect for the following purposes:
- Identification and Authentication: We may use your information to verify your identity when you communicate with us and to secure your personal information. It is in our legitimate business interests to authenticate the identity of individuals using our Services.
- Improving our Website: We analyze information about how you use our Website to provide an improved experience for all of our Website users. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our Website and improve them.
- Communicating with You: We may use your personal information when we communicate with you—for example if you contact us with questions. Except in cases where we are required to obtain your consent, it is in our legitimate interest that we are able to provide you with appropriate responses.
- Exercising our Rights: We may use your personal information to exercise our legal rights as provided to us by applicable law and where it is in our legitimate interests and necessary to do so, for example, to detect, prevent, and respond to fraud claims, intellectual property infringement claims, or violations of law or misuse of our information or our Website.
- Aggregating and/or anonymizing personal information: 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.
How We Disclose Information
We may disclose your personal information to our affiliate, PDT Partners UK I Ltd., for the purposes described in this Privacy Notice.
We may share your information with PDT service providers, delegates, professional advisors, regulatory bodies, auditors, technology providers, and any duly authorized agents or related, associated or affiliated companies of the foregoing for the same or related purposes and in connection with our business operations.
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: 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. Our Website is hosted in the United States. Certain service providers we share your information with are located in the United States and Canada and potentially other countries. In each case, these countries may not be regarded as providing the same level of protection for your information as your country of residence. Some of these countries may or may not be regarded as providing the same level of protection for your information as your country of residence. 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 contact us at the contact information set forth 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 in light of the purpose(s) for which it was obtained and consistent with applicable law. With respect to personal information where data retention is restricted by law, the criteria used to determine our retention periods include: (i) The length of time we have an ongoing relationship with you and we provide the Services to you (for example, for as long as you have an account with us and keep using the Services); (ii) 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 (iii) 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).
Third Party Services
This Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with our Social Media Pages.
Your Rights Over Your Personal Information
You may have certain rights, depending on where you are located and how or why your personal information was collected, regarding the personal information we hold about you, subject to applicable local law. These may include the rights to access, correct, delete, restrict or object to our use of, or receive a portable copy in a usable electronic format of your personal information.
We encourage you to contact us at the contact information set forth below 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.
Please note that we may require additional information from you in order to honor your requests.
Subject to applicable law, you may also lodge a complaint with an EU/EEA 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 data protection authorities is available here.
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.
Use of Services by Minors
The Services are not directed at individuals under the age of sixteen (16), and we do not knowingly collect personal information from individuals under that age.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to 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 Law, the controller is the relevant Cayman Islands investment fund.
If you have any questions about this Global Investor Privacy Notice or our processing of your information as described above, you may contact both PDT Partners, LLC and our EU/UK representative at email@example.com. You may also address relevant privacy-related communications regarding investments in the Cayman Islands investment funds we manage to firstname.lastname@example.org.
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.
Changes to this Notice
We may modify or update this Privacy Notice from time to time. The “Effective Date” legend at the bottom of this Privacy Notice indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice.
Effective Date: December 27, 2021.
PDT Partners, LLC. All Rights Reserved.