This policy was last updated January 2019
Financial institutions like Millburn Ridgefield Corporation are required to provide privacy notices to their clients. We believe that protecting the privacy of your nonpublic personal information is of the utmost importance, and we are committed to maintaining the privacy of your nonpublic personal information in our possession. As required by applicable rules, we are providing you with the following information.
We collect nonpublic personal information about you from the following sources:
(i) Information we receive from you on managed account agreements or fund subscription documents and related forms (for example, name, address, Social Security number, birth date, assets, income, and investment experience); and
(ii) Information about your transactions with us (for example, account activity and balances, and information regarding the account from which you make an investment or to which redemption or withdrawal proceeds are paid).
In order to service your account and process your transactions, we may provide your personal information to our affiliates and to firms that assist us in servicing your account or investment funds in which you invest and have a need for such information such as account or fund administrators. We require third party service providers to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them.
We do not disclose any nonpublic information about our customers or former customers to anyone other than in connection with the administration, processing and servicing of customer accounts or investment funds as described above or to our accountants, tax preparers, attorneys and auditors or as otherwise permitted or required by law.
We restrict access to nonpublic personal information about you to our personnel who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural controls in keeping with federal standards to safeguard your nonpublic personal information.
This policy applies to Millburn Ridgefield Corporation, Millburn International (Europe) LLP and to each investment vehicle sponsored by Millburn Ridgefield Corporation and to which Millburn Ridgefield Corporation serves as the general partner, investment manager, investment adviser or in a similar capacity.
This policy was last updated January 2019
This notice sets forth the privacy practices of Millburn International (Europe) LLP (the “Company”) with respect to the personal data of business contacts of the Company (each, a “Client”). This notice only applies to Clients whose personal data is processed by Company. For the purposes of European data protection laws, Company is the data controller of your personal data.
Data That May Be Collected
Company may collect certain personal data with respect to Clients, for example, contact information (such as name, postal and email address, and telephone number); date of birth; information about your transactions with Company, Company funds or Company affiliates; information about your assets, net worth, source of funds or credit history; signatures; copies of identification documents; bank account details; and other personal information you provide to Company, such as through emails, subscription documents or agreements and other onboarding documents (that may include Social Security numbers, tax ID numbers or other government-issued identification numbers, to the extent permitted by applicable law), and other forms and documents you provide or that are provided by others on your behalf. In addition, with respect to employees or prospective employees of Company (each, an “Applicant”), Company may conduct a background check in connection with your employment and, as part of the background check or otherwise, collect the following types of personal data: gender; employment and education history; language proficiencies and other work-related skills; citizenship and work authorization status; military and veteran status; self-identified disability status; criminal background; information provided by references; and other information about your qualifications for employment such as information contained in your application for employment and materials submitted by you or on your behalf and compensation history and related information.
Use of Personal Data
Company will use Clients’ or Applicants’ personal data in the course of business where it is in the Company’s legitimate interests to contact Clients or Applicants, and to: respond to Clients or Applicants requests; send information about Company and its affiliates that may be of interest to Clients or Applicants; provide or manage Company services; create, manage and administer accounts you hold with Company or with an investment product or fund; send Clients promotional and advertising materials, newsletter and other communications; tax reporting; verify your identity and conduct identity and background checks for anti-money laundering purposes where you or your related organization are applying for Company products or services; manage career opportunities, including for recruitment purposes (such as processing job applications and conducting background checks in accordance with applicable law), employee onboarding and other human resources purposes; perform data analyses (such as market and customer research); develop, manage and improve Company business, products and services; determine and manage the effectiveness of Company communications; perform accounting, auditing, billing and reconciliation activities and other internal functions; protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities; conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and Company policies and terms; and for other purposes required or authorized by law, including other purposes for which you have provided your consent.
The provision of personal data by Clients may be necessary in order for Company to provide that Client with the requested services and communicate with Clients where in Company’s legitimate interests.
As a general matter, Company uses the personal information it obtains to comply with applicable legal requirements, carry out Company contractual obligations and pursue Company legitimate interests (such as managing Company Client relationships). Where required by applicable law, Company obtains consent to process personal information. Company also may use the personal information obtained in other ways for which Company provides specific notice at the time of collection.
Please note that you have a right to object to processing of your personal data where that processing is carried out for Company legitimate interest or for direct marketing.
Disclosure to Certain Third Parties
Company does not sell or otherwise share personal information about you, except as described in this notice. Company shares your personal information with its affiliates, including Millburn Ridgefield Corporation, for the purposes identified in this notice. Company also shares the information with service providers who perform services on its behalf based on its instructions and record your information in one or more databases maintained by third parties in connection with the collection of data and communications and for legal or regulatory purposes, as described in this notice. Company does not authorize these service providers to use or disclose the information except as necessary to perform services on its behalf or comply with legal requirements. Examples of these service providers include fund administrators and entities that perform anti-money laundering testing services. In addition, Company may share your personal information with your authorized representatives.
Company also may disclose information about you (1) if Company is required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government entities based on a lawful disclosure request; (3) to establish, exercise or defend Company’s legal rights; (4) when Company believes disclosure is necessary or appropriate to prevent harm or financial loss; (5) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (6) otherwise with your consent. Company reserves the right to transfer personal information it has about you in the event of a potential or actual sale or transfer of all or a portion of Company’s business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution or liquidation).
Transfer of Personal Data Outside the EEA
Company may disclose Client personal data to other recipients located in countries outside of the EEA, including affiliates located in the United States, which may not have data privacy laws equivalent to those in the EEA. By submitting your personal data to Company, each Client and Applicant consents to the transfer of their personal data to Company and the other recipients described in this notice that are located in countries outside of the EEA. Clients or Applicants may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Data Subject Rights
Under applicable EU data privacy laws, Clients and Applicants may have a right to: (i) request access to and rectification or erasure of their personal data; (ii) obtain restriction of processing or to object to processing of their personal data; and (iii) the right to ask for a copy of your personal data to be provided to you, or to a third party, in a digital form. If you wish to exercise any of these rights you should contact firstname.lastname@example.org. Clients and Applicants also have the right to lodge a complaint about the processing of their personal data with their local data protection authority.
Security and Retention
Company will take reasonable steps to protect Clients' and Applicants’ personal data against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification, regardless of the format in which it is held. To the extent permitted by applicable law, Company retains personal information it obtains about you as long as: (i) it is needed for the purposes for which Company obtained it, in accordance with the provisions of this notice; or (ii) Company has another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data.
This notice and the policies described in this notice may be updated periodically and without prior notice to you to reflect changes in Company’s privacy practices or in applicable law, rules or regulations. The date as of which this notice was last updated appears at the beginning of the notice.