This privacy policy (“Privacy Policy”) sets forth the privacy practices of Politan with respect to our collection, use, sharing, and disclosure of Personal Information (as defined herein), including, but not limited to, Personal Information collected through this Site, how it is used, and the circumstances under which it may be shared and disclosed. This Privacy Policy constitutes a legally binding agreement between you and Politan that conditions your use of the Site, where and as permitted by applicable law.
If you are a California resident, please also read our Privacy Notice for California Consumers below.
1. Personal Information We Collect
When you visit the Site and during our ordinary business activities, Politan may collect or ask you to provide certain nonpublic personal information (“Personal Information”) in order to help us manage our relationship with you and serve your investment needs. The Personal Information we may collect from you may include personally identifiable information including names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under applicable law, that may be contained in the relevant materials, documents, or obtained through background searches.
2. Sources of Personal Information
We may collect Personal Information from:
3. How We Use Personal Information
We use Personal Information for the following business purposes:
4. How We Share Personal Information
Your privacy is important to us. Politan does not disclose any Personal Information to nonaffiliated third parties, except to service or manage a client’s account or as permitted or required by law. We do not sell any Personal Information.
Every client has the right to direct Politan not to disclose the Personal Information about that client to a nonaffiliated third party. If a client would like to exercise its right to opt out of this Privacy Policy, each client must provide a written statement exercising that right. This right to opt out may be exercised at any time and will remain in effect until written notice revoking said right is received by Politan from the client. However, in the event Politan encounters circumstances where it is compelled by law to disclose a client’s Personal Information, Politan must provide, to non-affiliated third parties, a client’s Personal Information even if the client has exercised its right to opt out.
5. How We Protect Personal Information
Politan seeks to carefully safeguard Personal Information. We will use commercially reasonable efforts to ensure that Personal Information is kept secure and safe from any loss or unauthorized disclosure or use. We restrict access to our client’s Personal Information to employees or other personnel requiring that Personal Information to provide our products or services.
6. Notice for Residents of the European Economic Area and United Kingdom
Politan does not currently offer its products or services to natural persons residing in the European Union or the United Kingdom (“EEA/UK”) and, accordingly, is not required to comply with the EU General Data Protection Regulation (“GDPR”). Any personal data provided to us by you will be processed in the United States or other jurisdictions outside the EEA/UK which may not afford the same protections of personal data as under the GDPR or equivalent laws in the UK.
7. Contact Us
If you have any questions or comments about this Privacy Policy, please contact Politan at politan@Longacresquare.com.
Privacy Notice For California Consumers
Last updated: June 8, 2024
This notice contains disclosures required by the California Privacy Rights Act (“CPRA”). Terms defined in the CPRA have the same meaning when used in this notice. This notice is only relevant to California residents (“consumers” or “you”), who may include the following: prospective investors, representatives of entities we do business with, employees/job applicants, and users of our website. Consumers with disabilities may access a printable copy of this notice in pdf format by clicking here.
Information We Collect Through this Site. In the past 12 months, we have collected and shared for a business purpose the following categories of personal information (“Personal Information”) through this Site:
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Category
Identifiers
Examples
A real name, alias, email address, postal address, other contact details, Internet Protocol (IP) address, account name, copies of identification documents, Social Security number, driver’s license number, tax identification or passport number, or other similar personal identifiers.
Shared for Business Purpose
YES
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Category
Other personal information categories, as listed in the California Customer Records Statute
Examples
A signature, telephone number, employment, bank account number, information about assets or net worth, credit history, information on investment activities or any other financial information.
Shared for Business Purpose
YES
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Category
Protected classification characteristics under California or federal law
Examples
Age (40 years or older), race, citizenship, marital status, sex, veteran or military status.
Shared for Business Purpose
YES
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Category
Commercial information
Examples
Account activity, records of products or services purchased, obtained, or considered, or other purchasing histories.
Shared for Business Purpose
YES
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Category
Internet or other similar network activity
Examples
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Shared for Business Purpose
YES
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Category
Professional or employment-related information
Examples
Current or past job history.
Shared for Business Purpose
YES
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Category
Inferences drawn from other personal information
Examples
Profile reflecting a person’s preferences, characteristics and interests.
Shared for Business Purpose
YES
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Category
Sensitive Personal Information
Examples
A consumer’s Social Security number, driver’s license, state ID card, or passport number; account log-in or debit/credit card number in combination with any access code, password, or account credentials; precise geolocation; racial/ethnic origin, religious/philosophical beliefs, or union membership; contents of mail, email, and text messages; genetic data; biometric information; protected health information; or sex life or sexual orientation.
Shared for Business Purpose
YES
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Personal Information does not include information that is publicly available, de-identified/aggregated, or subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) or the Gramm-Leach-Bliley Act (“GLBA”).
We collect Personal Information from the following categories of sources:
We also may receive your personal data from other third parties or sources, such as the administrator, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or publicly accessible sources, such as the Internet.
We do not knowingly collect, solicit or sell Personal Information from anyone under the age of 16 without the prior consent of a parent or guardian.
Purpose for Collection and Use of Personal Information. We may collect or use Personal Information for one or more of the following purposes:
Sharing Personal Information. We may disclose Personal Information in one or more of the categories identified above to:
In the past 12 months, we have not sold any Personal Information we collect to third parties, and we have shared the categories of Personal Information we collect only as set forth above.
Length of Time. We will keep your Personal Information for as long as necessary to comply with our regulatory or other legal obligations.
Rights of California Consumers. The CPRA provides a California consumer the following rights, subject to certain exceptions and limitations:
You may submit requests relating to your exercise of CPRA rights to us via email at politan@Longacresquare.com.
We may need to request additional information from you to verify your identity or understand the scope of your request. In verifying requests, we will require you to provide, at a minimum, your telephone number and mailing address. We will use the information you submit and the information we have in our systems to try to verify your identity and to match the Personal Information we have collected about you, if any, to your identity. We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
You may designate an authorized agent to make a CPRA request on your behalf. In such case, we will ask the agent to provide proof that you have given the agent signed permission to act on your behalf. In addition, we will ask you to (1) verify your identity directly with us in the manner described above and (2) directly confirm with us that you have provided the agent permission to make the request on your behalf.
You may only make a verifiable request for access or data portability twice within a 12-month period.
Questions
If you have questions regarding this notice, please contact us at politan@Longacresquare.com.
Persons who access the information made available Politan Capital Management (together with its affiliates, “Politan”, “we” or “us”)via this website (the “website”) agree to the following:
While the material on this website is often about investments, none of it is offered as investment advice. For members of the public, this means that neither the receipt nor the distribution of information through this website constitutes the formation of an investment advisory relationship, or any similar client relationship. The materials on this website are for informational purposes only and may not be relied on by any person for any purpose and are not, and should not be construed as investment, financial, legal, tax or other advice, recommendation or research.
This website is not an offer to sell or the solicitation of an offer to buy interests in any fund or investment vehicle (a “fund”) managed by Politan. An offering of interests in a fund will be made only by means of a confidential private offering memorandum and only to qualified investors in jurisdictions where permitted by law. An investment in a fund is speculative and involves a high degree of risk. Any fund has substantial limitations on investors’ ability to redeem or transfer their interests in a fund, and no secondary market for a fund’s interests exists or is expected to develop. All of these risks, and other important risks, would be described in detail in a fund’s confidential private offering memorandum. Prospective investors are strongly urged to carefully review the applicable confidential private offering memorandum and consult with their own financial, legal, and tax advisors before investing in a fund.
This website may contain forward-looking statements on our current expectations and projections about future events. Statements that are predictive in nature, that depend upon or refer to future events or conditions or that include words such as “expects,” “anticipates,” “intends,” “plans,” “believes,” “estimates,” “thinks,” “seeks,” “targets,” “forecasts,” “could” or the negative of such terms or other variations on such terms or comparable terminology. Similarly, statements that describe Politan’s objectives, plans or goals are forward-looking. Any forward-looking statements are based on Politan’s current intent, belief, expectations, estimates and projections. These statements are not guarantees of future performance and involve risks, uncertainties, assumptions and other factors that are difficult to predict and that could cause actual results to differ materially. Accordingly, you should not rely upon forward-looking statements as a prediction of actual results and actual results may vary materially from what is expressed in or indicated by the forward-looking statements.
No representation or warranty is given in respect of the correctness of the information contained herein as at any future date. Certain information included in this communication is based on information obtained from third-party sources considered to be reliable. Any projections or analysis provided to assist the recipient of this communication in evaluating the matters described herein may be based on subjective assessments and assumptions and may use one among alternative methodologies that produce different results. Accordingly, any projections or analysis should not be viewed as factual and should not be relied upon as an accurate prediction of future results. In addition, this website may contain performance and other data. Past performance is not indicative of future performance.
This website contains hyperlinks to websites operated by Politan and other parties. Politan does not control the content or accuracy of information on third-party websites and does not otherwise endorse the material placed on such sites.
All information and content on this website is furnished “AS IS,” without warranty of any kind, express or implied. Politan will not assume any liability for any loss or damage of any kind arising, whether direct or indirect, caused by the use of any part of the information provided. Politan and its licensors do not warrant that the content is accurate, reliable or correct; that the website will be available at any particular time or location; that any defects or errors will be corrected; that unauthorized access to or misappropriation of the content will not occur; or that the content is free of viruses or other harmful components. Your use of the website is solely at your risk.
The entire website is subject to copyright with all rights reserved. No permission is granted to copy, distribute, modify, post or frame any text, graphics, video, audio, software code, or user interface design or logos. The information contained herein shall not be published, rewritten for broadcast or publication or redistributed in any medium without prior written permission from Politan.