Introduction. This notice ("Privacy Notice") is provided by LTZF Capital Management LP (the "manager") as manager of certain pooled investment vehicles (the "Funds" and each "Fund" together with "Manager", constituting "we" or "us"). It sets forth our policies for the collection, use, storage, sharing, disclosure, processing, retention, and protection of personal data related to current, prospective, and former investors in the Funds or counterparties, as applicable, or other visitors to this site. References to "you" or an "investor" in this Privacy Notice may be used to mean any investor, counterparty, or other individual, or any individual connected to an investor who is a legal person, as applicable.
Who to contact if you have questions. This Privacy Notice is being provided under the applicable requirements relating to privacy and data protection laws in the jurisdictions where we operate (collectively, "Data Protection Laws"). The Funds and the Manager are considered to be data controllers in respect of any information we hold about you for the purposes of certain Data Protection Laws. This means that each of the Fund and the Manager (alone or jointly, as applicable) determines the purposes and the means of the processing of your personal information.
Should you have questions about this notice or requests with regard to personal data we may hold, please contact us in writing at info@LTZFCapital.com, via post at LTZF Capital Management LP (1742 Valley Avenue, McLean, VA USA 22101), or via telephone (+1 202 596 7571).
Please note that our affiliates and counterparts may also act as data controllers of your personal information in connection with the performance of their legal and contractual obligations for purposes of Data Protection Laws. For more specific information or requests related to processing of personal data by our affiliates and counterparts, please contact us using the information described in this subsection.
The types of data we may hold. The categories of personal data we may collect include 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 the applicable Data Protection Laws, that may be contained in any materials or documents, or obtained through background searches.
How we collect data. We may collect data about you through: (i) information provided directly to us by you, or by another person on your behalf; (ii) information we obtain by consequence of a transaction or proposed transaction between you and us; (iii) information we receive from third parties or other sources, including but not limited to our affiliates and contractors, publicly accessible databases or registers, tax authorities, governmental agencies, supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the internet.
What we might do with data. As applicable and depending on the purposes for which the information was obtained, we may utilize your data for the purposes of administering a relationship between you and us, marketing our products and services, monitoring and analyzing our activities and engagement, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, Foreign Corrupt Practices Act adherence, and sanctions compliance), or in response to request for information from regulatory authorities, supervisory bodies, or law enforcement agencies.
We will use one of the permitted grounds of the applicable Data Protection Laws to process your personal information. Some examples of circumstances include (i) where processing is necessary as part of our legal or contractual obligations for an actual or potential transaction between you and us; (ii) when we have a legal or regulatory obligation necessitating the use of your data for compliance; or (iii) if we, or a third party on our behalf, have determined in our sole discretion that it is in our legitimate business interest to collect and use your personal information.
What happens if you refuse to provide data. When personal data is required to meet a statutory obligation, contractual requirements, or regulatory burdens (including compliance with applicable anti-money laundering or sanctions rules), failure to provide any such information may result in a termination of your relationship with us, including a suspension of your subscription to an applicable fund, the rejection of any potential transactions, or the compulsory redemption or withdrawal of any material interests. If there is any suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.
How we might share your data. As applicable, depending on the purpose for which the information was obtained, we may disclose information about you to our affiliates, service providers, contractors, or other third parties to process our transactions with you, accept your subscription, administer and maintain your account(s), or otherwise perform our business obligations. We may also need to share your personal information with regulatory, tax, or law enforcement authorities to comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. We will also release information about you if you direct us to do so. It may also be necessary, under anti-money laundering and similar laws, to disclose information about you to facilitate the establishment of trading relationships for the Funds with prime brokers, executing brokers, or other trading counterparties. We may also choose, in our sole discretion, to disclose information about you, or your transactions and experiences with us, to our affiliates or service providers for our everyday business purposes, such as administration of our business, record-keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, and compliance with applicable legal and regulatory requirements.
How we retain your data and keep it safe. We will not retain personal data for longer than the period necessary to serve the purpose for which it was collected, subject to applicable Data Protection Laws. Personal data will be retained for the duration of your transaction or investment in the applicable Fund and for a minimum of five years after the termination of your transaction or a redemption, or withdrawal, as applicable, of your investment, or liquidation of the applicable Fund. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.
To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with applicable Data Protection Laws. These measures include digital device safeguards, regular digital security audits, secured files and servers, and protected buildings. Our information security protocols exceed industry standards.
In the unlikely event of a material personal data breach or the unauthorized access of your personal data, we will notify you in accordance with the requirements of applicable Data Protection Laws.
Additional Information under the US Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM). For purposes of US federal law, this Privacy Notice applies to current and former investors who are individuals or Individual Retirement Accounts. We are providing this additional information under US federal law.
We may disclose information about our counterparties, 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 or appropriate, under anti-money laundering and similar laws, to disclose information about the Fund’s investors in order to accept subscriptions from them or about counterparties in order to process transactions. We will also release information about you if you direct us to do so.
We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at +1 (202) 596-7571. If you are a new investor or counterparty, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our investor or counterparty, we may continue to share your information with our affiliates for such purposes.
You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. US state laws may give you additional rights to limit sharing.
We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by the Funds.
Additional Information under the EU General Data Protection Regulation. You may have certain rights under EU General Data Protection Regulation (“GDPR”) in relation to our processing of your personal data and any processing carried out on your behalf. These rights include: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of your personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities); (vi) where relevant, the right to request the portability of the data; (vii) if your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. Please note that the right to be forgotten that applies in certain circumstances under GDPR is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above. Due to the international nature of our business, your personal data will be processed in the United States, or other jurisdictions that do not offer equivalent protection to personal data as under the GDPR.
Additional Information under the Cayman Islands Data Protection Law 2017 (“DPL”). We may share your personal information with our services providers, including the Investment Manager, the Administrator, the Sub-Administrator, the Prime Broker or others who are located outside the Cayman Islands. It may also be necessary to share your information with the Cayman Islands Monetary Authority or the Tax Information Authority, which may, in turn, exchange this information with foreign tax authorities, regulatory or law enforcement agencies. Any transfer of your personal data by us, our affiliates or service providers outside the Cayman Islands will be carried out in accordance with the DPL. You have certain rights under the DPL including: (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to stop or restrict processing; (v) the right to stop direct marketing; (vi) rights in relation to automated decision making; (vii) the right to seek compensation; and (viii) the right to complain to the supervisory authority. A complaint in respect of the Offshore Fund may be lodged with the Office of the Ombudsman in the Cayman Islands. Please use the contact details provided above if you wish to exercise these rights.
