This notice sets forth Hudson Structured Capital Management, L.P.’s (“HSCM”) policies with respect to any personal information we obtain from our current, prospective, and former investors. These policies only apply to individuals and are subject to change.
How and Why We Obtain Personal Information
The information we obtain may include your name, address, e-mail address, social security number, financial situation, transaction history, assets, investment experience, income information and other personal information. We may collect personal information about you from the following sources:
- Subscription agreements or other documents obtained in the course of establishing or maintaining a relationship with you;
- Transactions with us, our affiliates or others, such as when you purchase an interest in any fund managed by us, direct us where to send money or make a wire transfer; and
- Nonaffiliated third parties and other companies.
We may share personal information received by us with respect to investors or former investors with affiliated parties such as our pooled investment vehicles and our general partners. We may share such personal information with nonaffiliated parties, including our administrators, accountants, counsel, prime brokers and regulatory or self-regulatory authorities for our everyday business purposes, such as to process your transactions, maintain your account(s), or respond to court orders and legal investigations. We may share your personal information to nonaffiliated companies for the purpose of performing marketing services on our behalf.
Federal law gives you the right to limit: (i) sharing information about your creditworthiness with affiliates for their everyday business purposes, (ii) affiliates from using your information to market to you and (iii) sharing for non-affiliates to market to you. State laws may give you additional rights to limit sharing. Please contact hscm.com/contact if you have any questions about or wish to limit our sharing of your personal information.
How We Protect Information About You
We use a variety of commercially reasonable physical, electronic, and procedural controls to protect personal information from unauthorized access and use. Consistent with security best practices, we also restrict access to your personal information within HSCM to those individuals who require it to develop, support, offer, and deliver products and services to you.
Online Privacy
When you visit our website, we may collect technical and navigation information, such as device type, browser type, Internet protocol address, pages visited, and the average time spent on our website. We use this information for a variety of purposes, such as maintaining the security of our website and your personal information, facilitating site navigation, and improving website design and functionality.
Cookies and Similar Technologies. HSCM and our third-party service providers may use cookies and similar technologies to support the operations of this website. Cookies are pieces of information that a website places on the hard drive of your computer when you visit the website. Cookies may involve the transmission of information from us to you and from you to us, to another party on our behalf, or to another party in accordance with this privacy policy. We may also use cookies to bring together information we collect about you. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. If you refuse a cookie when on this website, or if you delete cookies, you may experience some inconvenience in your use of our website.
[Does HSCM use or plan to use another tracking technologies?]
Do Not Track Browser Settings. We support the Do Not Track browser setting. Do Not Track is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain about you. For more information about Do Not Track, including how to enable or disable this preference, please visit Do Not Track.
Protecting Children’s Privacy Online. Our website is not directed to individuals under the age of thirteen (13), and HSCM does not knowingly collect personal information from individuals who are under 13.
Additional Information
These policies are subject at all times, to the extent applicable, to the Executive Order on Terrorist Financing as issued by the United States of America, the anti-money laundering rules of the Cayman Islands and to similar governmental action.
If you have questions on this policy, please contact Investor Relations at hscm.com/contact. You may request access to your personally identifiable information by contacting Investor Relations (hscm.com/contact). We endeavor to ensure that the personal information we hold is accurate and up-to-date. To assist us, we recommend that you advise hscm.com/contact Investor Relations if there are any errors in your personally identifiable information and promptly update hscm.com/contact Investor Relations with any changes to your personally identifiable information. We will notify you if we make any material changes to this privacy policy.
Dated: February 2016