Gresham Investment Management LLC and its subsidiaries including its affiliated investment advisers and funds (together, the “Gresham”, “us” or “we”) consider your privacy our utmost concern.
This privacy notice (the “Notice”) outlines the information we may collect about you and describes the basis on which we process your Personal Information, as defined by the Brazilian Data Protection Regulation (“LGPD”). This Notice also gives information regarding the basis on which we process your Personal Information and your privacy rights under the LGPD.
This Notice is addressed to any natural person who is located in Brazil who is any of the following: an investor or prospective investor in any fund or account managed or advised by Gresham (each, a “Gresham Fund”), a member, distributor, sales representative, business affiliate, or other representative of any client or prospective client of Gresham, a business contact working with service providers and vendors, or an individual on a Gresham mailing list (“you”) whose Personal Information Gresham collects, controls and processes in the conduct of its business.
Our primary goal in collecting Personal Information from you is to effectively conduct business with our business partners and when applicable provide services and features to our clients, investors and potential clients and investors. You may make a data request by emailing firstname.lastname@example.org
Gresham may, in the conduct of our business, obtain Personal Information about you that may include, subject to the type of business or service relationship we have with you, without limitation:
In the course of our business, we may collect Personal Information about you from sources including, but not limited to:
We process your Personal Information to fulfill our contractual obligations, our statutory obligations and/or the legitimate interests of Gresham and for other purposes for which Gresham has a lawful basis under the LGPD, including:
We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Personal Information should be kept may also be governed by specific business-sector requirements and agreed practices. Personal Information may be held in addition to these periods depending on individual business needs.
Gresham collects certain information that you provide to us when electing to receive regular reporting from Gresham or otherwise by joining one of Gresham’s mailing lists, which may include your name, email address and other contact details. Some of your Personal Information collected, in accordance with this Notice, may be used by us and third-party service providers to contact you by email, fax, telephone and/or post for sending information or promotional material pertaining to Gresham’s products and services.
In addition, we may process your Personal Information in order to communicate with you for marketing purposes. In this event, we may provide additional information that we believe may be of interest, including about services, news updates, research or market commentary, conferences, or events offered by or in conjunction with Gresham.
We give you the opportunity to opt-out of receiving marketing communications and may in certain circumstances need to obtain your consent before sending such communications to you.
So that we can better understand our users' needs, we track responses to our emails. To do this, we may use small image files that are placed within the body of our email messages. If used, these files enable us to tell if a message has been opened and to track click-throughs on links within the message.
We may pass your Personal Information on to third-party service providers contracted to us in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service that they provide you on our behalf.
Gresham may share your Personal Information with Gresham entities including with Gresham Funds for any of the purposes set forth above. In any such business purposes set out above, Gresham may share your Personal Information with third parties, including:
We may transfer, sell or assign any of the information described in this Notice to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganization of our business.
Where your Personal Information is processed by third parties outside Brazil, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law.
We are committed to keeping the data you provide us secure and will take reasonable precautions to protect your Personal Information from loss, misuse, or alteration. Once we have received your information, we will use procedures and security features to try to prevent unauthorized access. We have implemented information security policies, rules, and technical measures to protect the Personal Information that we have under our control from:
At your request, we can confirm what information we hold about you and how it is processed. If we do hold Personal Information about you, you can request the following information:
Where appropriate in accordance with the LGPD, you may:
Upon request, we will provide you with a readable copy of the Personal Information which we keep about you. We require proof of your identity before providing you with this copy.
We will allow you to challenge the date that we hold about you and, where appropriate in accordance with applicable laws and policies, you may request to have your Personal Information:
If you would like to make a data request, please contact email@example.com.
We will occasionally update this Notice to reflect new legislation or industry practice, changes to Gresham’s business and/or customer feedback. We encourage you to review this Notice periodically to be informed of how we are protecting your Personal Information.