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Privacy Policy

Introduction

The purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Law, 2017 (as amended from time to time) (“DPL”). In this document, “we”, “us” and “our” refers to Liquibit USD Market Neutral Arbitrage Fund (the “Fund”), Liquibit Capital (the “Manager“) or their affiliates and/or delegate.

Investor Data

By virtue of visiting our website, or engaging either the Fund or the Manager for the purposes of making an investment (or potential investment) into the Fund and your associated interactions with us (including any subscription OR capital commitment and/or capital contribution (whether past, present of future), including the recording of electronic communications or phone calls where applicable, visiting our website) or by virtue of you otherwise providing us with personal information on individuals connected with you as an investor (for example directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents), you will provide us with certain personal information which constitutes personal data within the meaning of the DPL (the “Investor Data”). We may also obtain Investor Data from other public sources. Investor Data includes, without limitation, the following information relating to you and/or any individuals connected with you as an investor: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your investment activity.

In our use of Investor Data, the Fund will be characterised as a “data controller” for the purposes of the DPL. The Fund’s affiliates and delegates may act as “data processors” for the purposes of the DPL.

Data Retention

We will maintain Investor Data for our records for as long as required or until you ask us to delete this information.

Who this affects

If you are a natural person, this will affect you directly. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with Investor Data on individuals connected to you for any reason in relation to your investment with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Children

We do not knowingly collect information from minors. To use the website, you must be the age of legal majority in your place of residence. By using the website, you hereby represent that you are at least the age of legal majority in your place of residence. We do not use an application or other mechanisms to determine the age of users of the website. All information provided to Liquibit Capital will be treated as if it was provided by an adult. If, however, we learn that a minor has submitted information about himself/herself to us, we delete the information as soon as possible.

Links to Other Sites or Third-Party Services

If a link to a third-party site is included on the website and you click on it, you will be taken to a website that we do not control. This Policy does not apply to the privacy practices of that website. Read the privacy policy of other websites carefully. Liquibit Capital is not responsible for these third-party sites.

How We May Use Your Personal Data

The Fund, as the data controller, may collect, store and use Investor Data for lawful purposes, including, in particular:

  • where this is necessary for the performance of our rights and obligations under the subscription application and/or the constitutional and operational documents of the Fund;
  • (where this is necessary for compliance with a legal and regulatory obligation to which the Fund is subject (such as compliance with anti-money laundering and FATCA/CRS requirements); and/or
  • where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.

Additionally, the Manager, Trident Fund Services (Malta) Limited (the “Administrator”) and RSM Cayman Ltd. (the “Auditors”), may use Investor Data, for example to provide its services to the Fund or to discharge the legal or regulatory requirements that apply directly to it or in respect of which the Fund relies upon the Manager, the Administrator and the Auditors, but such use of Investor Data by the Manager, the Administrator and the Auditors will always be compatible with at least one of the aforementioned purposes for which we process Investor Data.

Should we wish to use Investor Data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.

Why We May Transfer Your Personal Data

In certain circumstances we and/or our authorised affiliates or delegates may be legally obliged to share Investor Data and other information with respect to your interest in the Fund with the relevant regulatory authorities such as the Cayman Islands Monetary Authority or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities. We anticipate disclosing Investor Data to the following parties who provide services to the Fund and their respective affiliates (which may include certain entities located outside the Cayman Islands or the European Economic Area), who will process your personal data on our behalf:

  • the Manager;
  • the Administrator;
  • the Auditors.

The Data Protection Measures We Take

Any transfer of Investor Data by us or our duly authorised affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL. We and our duly authorised affiliates and/or delegates shall apply appropriate technical and organisational information security measures designed to protect against unauthorised or unlawful processing of Investor Data, and against accidental loss or destruction of, or damage to, Investor Data. We shall notify you of any Investor Data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant Investor Data relates.

Disclaimer and Policy Updates

This Policy should not be construed as giving business, legal, or other advice or warranting as fail-proof the security of information provided through the website. The Internet is not 100% secure, and we cannot promise that your use of the website or software will be completely safe. The Fund and the Manager therefore disclaims any liability with respect to any information obtained by a third party through illegal entry into or breach of the website. We will maintain all information as long as needed to comply with internal policies or applicable laws or for record-keeping purposes.

This policy was last updated on 9th March 2020.

Contact Information

For questions regarding this privacy policy, please contact info@liquibit.io.