Maintaining the trust and confidence of our clients is a high priority therefore privacy is one of the central tenets of IPI Partners, LLC’s(collectively with its affiliates, “IPI” or “we”) value proposition. That is why we want you to understand how we protect your privacy when wecollect and use information about you, and the steps that we take to safeguard that information. This notice applies generally to all members and partners of private investment funds advised by IPI.
Information We Collect
In connection with providing investment products, financial advice, or other services, we may obtain non-public personal information about you,
- Information we receive from you on account applications and Subscription Agreements, such as your address, date of birth, Social Security Number, occupation, financial goals, assets and income;
- Information about your holdings and transactions with us, our Affiliates, or others (including lenders, auditors, service providers, and fund administrators), such as information regarding investments and credit facilities;
- Information received from credit or service bureaus or other third parties, such as your credit history or employment status; and
- Information documents provided in connection with your subscription agreement (e.g., copy of driver’s license or passport).
Our Security Policy
We restrict access to nonpublic personal information about you to those individuals who need to know that information to perform their respective duties. We maintain physical, electronic, and procedural security measures to safeguard confidential client information.
All employees of IPI and its affiliates are required to sign a confidentiality agreement which strictly governs their employment status with IPI or such affiliate.
We may disclose all categories of non-public personal information that we collect in accordance with this policy, however we will not disclose information regarding you or your account except under the following circumstances. Only the minimum amount of information will be shared.
- To entities that perform services for us or you, or function on your behalf, including, but not limited to: financial service providers, such as a custodian, broker-dealer, investment company, portfolio manager, portfolio reporting vendor, insurance company, lenders, fund administrators and audit and tax preparation firms;
- To consumer reporting agencies; and
- With your approval, to your attorney, accountant, trustee or anyone else who represents you in a fiduciary capacity.
We may share your information with affiliates under common control with IPI in order to provide services or offer additional products and services (e.g., the opportunity to invest in products managed by affiliates). We may also share your information as required by law or to comply with regulatory inquiries to government entities or other third parties in response to subpoenas or other legal process.
Closed or Inactive Accounts
Right to Limit Sharing
You may have the right to opt-out of the disclosure of your non-public personal information to nonaffiliated third parties or of the disclosure to affiliated parties about your creditworthiness, unless otherwise permitted by law. To exercise such right, please contact us at (202) 396-1907 or email@example.com.
Please direct complaints to: Jason Craig, Chief Compliance Officer at IPI Partners, LLC, 394 Pacific Avenue, Suite 200, San Francisco, CA 94111, or via email at firstname.lastname@example.org.
IPI Partners, LLC and our affiliates and subsidiaries (collectively, “IPI”, “we”, “our” or “us”) recognize the importance of protecting personal information. This European Union Privacy Notice (“EU Privacy Notice”) applies to personal information that we collect regarding EU data subjects. It also explains who we are and how you can exercise your privacy rights.
1. What personal information do we collect?
The personal information that we collect about you broadly falls into the following categories:
1.1 Information that you provide voluntarily
If you are (or are prospectively) our client or an investor in one of our affiliated financial vehicles, during or before the provision of our services we will ask you to provide personal information voluntarily. To the extent applicable for the provision of our services, we will ask for:
- Identifying and contact information (including your name, date of birth, tax identification number, copies of your government-issued identification document and the relevant information thereon, physical and mailing addresses, phone number, email, and other types of contact information)
- Information related to your finances and financial accounts (including your net worth, gross assets, investment sophistication and goals, financial account information, asset/investment-specific information, income, trust and estate information, tax status and other relevant tax information, and transactionspecific information)
- Information related to your various activities and relationships (including information related to your businesses and professional engagements, your professional relationships, your familial relationships, your charitable activities, your personal undertakings, and your service providers)
If you are not our client or an investor in one of our affiliated financial vehicles but nonetheless have a relationship with us in any other capacity, we will ask you for:
- Identifying and contact information (including your name, mailing address, phone number, email and other types of contact information)
- Information related to your affiliations (including information related to your business(es) or professional engagements, and information related to your relationship with any of our clients or investors, but not including any special categories of information as described in Section 1.4)
1.2 Information that we collect as part of our services
If you are our client or an investor in one of our affiliated financial vehicles, during the provision of our services as applicable we also collect certain information about you which may be considered personal information under applicable law, including:
- Information related to your interactions with us (including written communications between you and us, notes related to in-person meetings or telephone calls between you and us, and information related to your IP address or other device identifiers when using our website or electronic delivery portals)
- Information related to the provision of our services for you (including fees and billing information, records related to acts we take on your behalf, notes regarding your service preferences, and transaction-specific information)
1.3 Information that we obtain from third party sources
If you are our client or an investor in one of our affiliated financial vehicles, during or before the provision of our services we collect certain information about you which may be considered personal information under applicable law from third party sources (including our and your service providers), including:
- Information related to your finances and financial accounts (including financial account information, transaction-specific information, information regarding the value of your portfolio and assets, tax information, and trust and estate information)
- Information related to your various activities and relationships (including information related to your businesses and professional engagements, your professional relationships, your familial relationships, your charitable activities, and your personal undertakings, but not including special categories of information as described in Section 1.4)
If you are not our client or an investor in one of our affiliated financial vehicles but nonetheless have a relationship with us in any other capacity, we collect certain information about you which may be considered personal information under applicable law from third party sources (including our and your service providers), including:
- Identifying and contact information (including your name, mailing address, phone number, email and other types of contact information)
- Information related to your affiliations (including information related to your business(es) or professional engagements, and information related to your relationship with any IPI client or investor in IPI’s affiliated financial vehicles, but not including special categories of information as described in Section 1.4)
1.4 Special categories of information
We do not directly request or intend to collect special categories of information, including information about your health, race, religion, political opinions, philosophical beliefs, sexual preferences, sexual orientation, genetics, biometric data, or information regarding participation in trade union membership. However, please note that certain other types of information we collect may allow us to indirectly infer the corresponding special category of information notwithstanding that we are not collecting or otherwise processing such information; for example, transaction information regarding a charitable donation to a religious organization or political entity may imply a religious or political preference, information regarding joint financial accounts with your spouse may imply your sexual orientation, and information related to your business activities that do not show trade union membership implies that you are not participating in trade union membership.
2. How do we use your personal information?
We use your information for the following purposes:
- To provide investment and financial recommendations or products
- To support our interactions with you, including responding to your communications with us
- To open financial accounts or assist in the opening of financial accounts
- To facilitate transactions with third parties
- To refer third party service providers
- To comply with our legal and regulatory obligations, including the retention of records required by the U.S. Securities and Exchange Commission’s rules promulgated under the U.S. Investment Advisers Act of 1940, to participate in required audits and regulatory examinations, to detect and prevent fraud and fraudulent behavior, and applicable anti-money laundering laws and regulations
- To exercise, establish or defend our legal rights, or to protect your vital interest or those of any other person
- To detect potential conflicts of interest in the provision of our services and operation of our business
- To provide any other specific services for which you have engaged us
We will only use your personal information for the purposes described above, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
3. What is our legal basis for processing your personal information?
Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. If you are our client or an investor in one of our affiliated financial vehicles, we collect and use personal information as necessary for the performance of the contract between you and us. If you are not our client or an investor in one of our affiliated financial vehicles, we collect and use personal information where such processing is in our legitimate interest and is not overridden by your rights. Our legitimate interests in processing your personal information include detecting potential conflicts of interest in the provision of our services and the operation of our business, as well as supporting our interactions with you.
4. Who do we share your personal information with?
We share personal information to the following categories of recipients:
- With our employees, officers, directors, partners, affiliates, advisors, independent contractors and service providers; provided that within such categories, we restrict access (time and entry) to personal information to those who access the personal information to provide our services. Service providers include accountants, administrators, attorneys, auditors, compliance and IT consultants, custodians, SAAS (software as a service) providers, and other third parties engaged by us to assist with or support our provision of services.
- As part of a transaction, with third parties that require the personal information to execute the contemplated transactions.
- With the U.S. Securities and Exchange Commission and other competent law enforcement bodies, government agencies, courts or third parties where we reasonably believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
- As anonymized data, to third parties under obligations of confidentiality who request such information as part of our services or as part of a business transaction with us.
- With any other person with your consent to the disclosure.
5. Where do we transfer your personal information?
In performing our services, we may have to transfer your personal information outside of the European Economic Area (“EEA”) or to countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country or those of the EEA.
Specifically, our servers are in the United States, and we have an affiliate that operates in Singapore. This means that when we process your personal information, we process it in either of these countries. Additionally, we may transfer data to service providers for processing in these countries or other countries, for the purposes described in this policy.
6. How do we secure and safely store your personal information?
We use reasonable and appropriate technical and organizational measures designed to protect your personal information. We have in place a robust framework to ensure the security of your information. Specific measures we undertake include the logical separation of data structures and enhanced encryption processes.
7. How long do we keep your personal information?
How long we keep your personal information will vary primarily depending on:
- The purpose for which we are using your personal information – we will keep your personal information for as long as is necessary to provide the relevant services, and
- Our legal obligations – laws or regulation set a minimum period for which we are required to keep certain of your personal information.
We only store data that identifies you so long as it is necessary to carry out the purposes described in this policy. When we no longer need your personal information, we will either erase or de-identify it, or if this is not possible (because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from further processing until erasure is possible.
8. What are your data protection rights?
You have the following data protection rights:
- To access, correct, update, port or request deletion of your personal information that we process. Due to applicable regulatory requirements, there may be instances in which we cannot completely delete your personal information, although we will delete personal information to the extent consistent with our worldwide regulatory obligations.
- To object to or restrict processing of your personal information (so long as we are processing such personal information on the legal basis of pursuing our legitimate interest).
- To complain to a data protection authority about our collection and use of your personal information.
To contact us about any of your rights, see Section 10 (How can we be contacted?).
9. How do we notify you regarding changes to this Privacy Notice?
If we make changes to this Privacy Notice, we may notify you by updating the Privacy Notice with a “Last Updated” date at the top. We may also provide additional notice in some cases, such as by providing a statement on our website, or by sending an email notification. The most current version of our Privacy Notice will be available on our website.
10. How can we be contacted?
For the purposes of the EU General Data Protection Regulation (“GDPR”), we are the data controller for the processing of any personal information which we process about you. This EU Privacy Notice is effective as of February 22, 2019.
For questions about this EU Privacy Notice or to exercise your rights under the GDPR, please contact us at: email@example.com or by calling (202) 396-1907.
Information on this website is for informational purposes only and is not an offer or solicitation with respect to the purchase or sale of any security. SEC registration does not imply any level of skill or training or approval by the SEC. The content contained on this site is provided to users “AS IS” without an express or implied warranty.
Nothing on this website is intended as marketing of any fund in the United Kingdom or any member state of the European Economic Area within the meaning of the Directive 2011/61/EU on Alternative Investment Fund Managers.
Assets under management are calculated using net asset value plus uncalled capital commitments of all ICONIQ or Iron Point Partners accounts and funds (as applicable) including, in each case, IPI assets, as of a recent date. Such figures are approximate, unaudited and subject to change.