Privacy Notice for Clients/Investors in Products managed by US-Regulated Man Entities

 

This Privacy Notice is dated 1 April 2021.

Respecting and protecting investor privacy has always been vital to our business. We are providing you this notice (“Privacy Notice”) to help you better understand the privacy policies of the US-Regulated Man Entities1 (collectively the “Firm”, ”us” and “we”). Please read this Privacy Notice carefully to understand what we do.

 

Who is Covered by this Privacy Notice?

This Privacy Notice applies to clients of the Firm who are natural persons and to prospective investors and current and former investors in Funds or Separately Managed Accounts (together, “Products”) who are natural persons.

Natural persons who are resident in the UK or the European Economic Area (EEA) or have a relationship with Man’s UK or EEA entities, may also be afforded protection under the EU General Data Protection Act (EU) 2016/679 or its UK equivalent (together, the “GDPR”). More information in relation to our arrangements for holding and protecting personal data under the GDPR is available in the privacy notices on Man’s website which can be located at https://www.man.com/privacy-policy.

 

What Personal Information Might We Have About You?

You may have provided us with personal information in connection with our solicitation and administration of your investment in a Product which may include your U.S. social security number, national insurance number, or other tax or government identification number, address, risk tolerance, wire transfer instructions, and the amount of your assets or income.

We collect such information, for example, when you: (i) provide it to us in the relevant Product’s Subscription Agreement/Application Form and related documents, where applicable; (ii) provide it to us in correspondence and conversations with representatives of the Firm which may be recorded as required by law in certain jurisdictions; or (iii) make transactions such as when you purchase securities from us, tell us where to send money or make a wire transfer. We also may collect your personal information from other sources, such as affiliates.

 

With Whom Do We Share Your Personal Information?

Except as described below, we do not disclose to affiliates or to non-affiliates any non-public personal information about you. We do disclose information to non-affiliated third parties for everyday business purposes, such as processing your investments or deposits and withdrawals and responding to court orders and legal investigations, as permitted or required by law. We also provide such information to our attorneys, banks, auditors, securities brokers and service providers as may be necessary to facilitate the acceptance and management of your investment and to enable them to perform services on our behalf.

We may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary, under anti-money laundering and similar laws, to disclose information about the Product's investors in order to accept subscriptions or deposits from them. We will also release information about you if you direct us to do so.

For further details of the purposes for which we may use or process your personal information and the third parties to whom we may disclose your personal information, please see our Privacy Policy, a copy of which is available on request. Your personal information may be transferred to and processed in any country in the world for any of the purposes described in our Privacy Policy. The countries to which your personal information is transferred may not offer an equivalent level of protection for personal information to the laws of your home country.

 

How Can You Limit Sharing of Your Personal Information?

As discussed above, we may share your personal information for a variety of reasons. You may limit our ability to share your information as set forth below:

Reasons we can share your personal information Do the US Man Regulated Entities Share? Can you limit this sharing?
For our everyday business purposes - such as to process your transactions, maintain your accounts(s) or respond to court orders and legal investigations. Yes No
For our marketing purposes - to offer our products and services to you Yes No
For joint marketing with other financial companies Yes No
For our affiliates' everyday business purposes - information about your transactions and experiences Yes No
For our affiliates' everyday business purposes - information about your creditworthiness Yes Yes
For our affiliates to market to you Yes Yes
For non-affiliates to market to you Yes We do not share
TO LIMIT OUR SHARING

Please note:
If you are a new customer, we can begin sharing your information 30 days from the date we provided this Privacy Notice with the Product’s Subscription Document/Application Form. When you are no longer our customer, we continue to share your information as described in this Privacy Notice. However, you can contact us at any time to limit our sharing.

 

Protecting the Confidentiality of Our Investor Information

We maintain physical, electronic and procedural safeguards to store and secure information about you from unauthorized access, alteration and destruction. Our control policies, for example, authorize access to investor information only by individuals who need such access to do their work.

To protect your personal information from unauthorized access and use and from accidental damage, loss or destruction, we use technical and organizational security measures that comply with applicable law. These measures include electronic and computer safeguards and secured files and buildings.

This Privacy Notice may be updated from time to time. Please regularly check this page for any updates we might make to reflect changes in our practices or changes in applicable regulation.

If you have any questions about this Privacy Notice or to request a copy of our Privacy Policy, call (212) 649-6600 and request to speak to the Legal or Compliance Department.

 

1 The US Regulated Man Entities include FRM Investment Management (USA) LLC, GLG LLC, Man Global Private Markets (USA), Inc, Man Investments Inc., Man Solutions (USA) LLC, Numeric Investors LLC and Silvermine Capital Management LLC and, in respect of US clients/investors only, AHL Partners LLP, GLG Partners LP, Man Global Private Markets UK Ltd and Man Solutions Limited.

 

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