Ramsey Quantitative Systems, Inc.
Privacy Notice Policy
The following defined terms are used throughout this Privacy Notice Policy:
1. Clients – (1) RQSI’s separately managed accounts (“SMAs”), (2) current Investors, and (3) potential investors or prospects.
2. Investors – Shareholders in the RQSI Global Asset Allocation Master Fund, Ltd and the RQSI Global Asset Allocation Fund, Ltd.
3. Natural Person – A living, breathing human being, as opposed to a legal entity.
4. Non-Public Personal Information – Personally identifiable financial information, including any information a client provides to obtain a financial product or service; any information about a client resulting from any transaction involving a financial product or service; or any information otherwise obtained about a client in connection with providing a financial product or service to that client; and any list, description, or other grouping of Clients (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available information. Examples of Non-Public Personal Information include: name, address, phone number (if unlisted), social Security and tax identification numbers, financial circumstances and income, and account balances.
5. Personal Information – information identifying an individual or from which they can be identified and which is protected under applicable data protection laws.
In developing this Privacy Notice Policy, Ramsey Quantitative Systems, Inc. (“RQSI”) considered the material risks associated with protecting Non-Public Personal Information and, as applicable, Personal Information. This analysis includes risks such as:
• Information about activities of RQSI and its Clients that is required to be maintained is not accurately recorded and stored and is not protected from unauthorized access, alteration, and destruction.
• Information about Clients is not maintained or used in ways that ensures such information is safe from unauthorized use.
• False or misleading disclosures are made to Clients about how their Non-Public Personal Information and/or Personal Information is used and protected from unauthorized use.
RQSI has established the following guidelines as an attempt to mitigate these risks.
RQSI will not disclose Client records and information including Non-Public Personal Information and, as applicable, Personal Information (collectively, “Client Information”) to anyone unless such disclosure is permitted or required by law or this Policy. To the best of its knowledge and ability, RQSI shall record and maintain Client Information accurately and shall safeguard against unauthorized access to this information. This Privacy Notice Policy gives information regarding the collection and use of Client Information (where subject to applicable privacy laws including the General Data Protection Regulation (“GDPR”) and other UK, US and European data privacy laws (the “Data Privacy Laws”)) and describes the basis on which we process Client Information, for what purposes, the applicable privacy rights under the Data Privacy Laws and how we protect Client Information.
The Client Information that we collect
In the conduct of our business, we obtain Client Information about Clients including, without limitation, the name, date of birth, address and other contact details, social security number, tax or other identification number, identity documents and information about the income, assets and other financial information. This information may come from sources such as application, subscription or other forms or material completed or supplied by actual or prospective Clients, other written, electronic or verbal correspondence which relate to transactions by or on behalf of a Client. We may also collect Client Information provided in recorded calls. We may also collect special categories of Client Information (as defined in the GDPR and including health, disability and religious or ethnicity information) where provided by Clients, with consent, such as disability information or religious data for purposes required by Clients such as scheduling of meetings or access to RQSI premises.
How we use Client Information
We collect Client Information to fulfill our contractual obligations, our statutory obligations and/or the legitimate interests of RQSI and for other purposes for which RQSI has a lawful basis under the Data Privacy Laws, including: (i) for compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing or “Know your Client” requirements, as well as to verify the status and / or eligibility of RQSI clients for funds or services offered by RQSI and for compliance with tax reporting requirements, (ii) for purposes of reporting to, or communicating with, RQSI clients concerning their investment in RQSI Funds or appointment or engagement of RQSI consistent with our obligations to such RQSI clients; (iii) in connection with our investment activities, including investment due diligence or investment monitoring activities or in response to “Know your Client” requirements of counter-parties; (iv) in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving RQSI, RQSI funds or RQSI clients, and (v) for other legitimate business interests. If Clients have provided special categories of Client Information to us to enable us to respond to certain requests by Clients such as access requests or scheduling of meetings or similar requirements, we do so with consent and/or on the grounds of legal necessity.
In addition, we may, in compliance with the requirements of the Data Privacy Laws, process Client Information in order to communicate with them for marketing purposes. In this event, we may provide additional information that we believe may be of interest, including about funds or services, news updates, research or market commentary, or events offered by or in conjunction with RQSI. Clients have the right to unsubscribe by contacting us at the contact details provided below or by following the instructions in any such communication, e.g. by clicking on the link to unsubscribe.
The disclosure of Client Information
We may share Client Information with RQSI entities and third-parties for any of the purposes set-out above. These recipients are located in the US and other jurisdictions which may have a lower standard of data protection laws compared to the country from which the Client Information was collected.
We may share Client Information with third-parties for any of the purposes set out above, including:
• Service providers e.g., attorneys, auditors, accountants, tax advisers, administrators, custodians, depositaries, distribution managers and brokerage firms, event organizers or other agent, adviser or service provider of any Fund.
• Other counter-parties e.g., managers, general partners or investment advisers or administrators or any of their respective agents or representatives.
1. RQSI shall not sell Client Information to anyone.
2. RQSI will restrict access to Client Information to individuals within RQSI who require the information in the ordinary course of servicing Clients’ accounts. Client Information is used only for business purposes.
3. RQSI maintains physical (e.g. locked file cabinets and doors), electronic (e.g. logins and passwords), and procedural (e.g. employee training) safeguards to protect Client records and information. We maintain appropriate physical, electronic, and procedural safeguards to protect against unauthorized access to or use of Client Information.
4. Client Information may only be given to third-parties under the following circumstances:
• To other firms as directed by Clients, such as accountants, lawyers, etc.;
• To specified family members (as authorized by law and/or the Investor);
• To third-parties as needed to provide requested services; and
• To regulators and others, when required by law.
6. RQSI retains Client Information for as long as necessary to provide service to the Client, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.
7. RQSI shall provide a Privacy Notice Policy to Clients who are Natural Persons upon inception of the relationship and annually thereafter if a material change occurs. The Privacy Notice Policy shall be furnished to Investors and SMAs in a written format and disseminated to potential investors or prospects via direct link on performance newsletters. RQSI will maintain a record of the dates when the Privacy Notice Policy is provided to Investors and SMAs.
10. If an Employee receives a complaint regarding a potential identity theft issue (be it from a Client or other party), the Employee should immediately notify the CCO. The CCO will thoroughly investigate any valid complaint, and maintain a log of all complaints as well as the result of any investigations.
11. In the event that unintended parties receive access to Client Information, RQSI will promptly notify those Clients of the privacy breach.
12. Extraneous documents containing any Client Information or sensitive consumer information shall be burned, shredded, or destroyed (this includes documents earmarked for recycling). In addition, any Client Information saved in a storage medium that is being sold or disposed of, must be removed from the medium. In the event that RQSI maintains contracts with service providers for services involving the disposal or destruction of consumer report information, the contracts must explicitly require the “proper” disposal of documents containing Client Information.
Clients have certain rights relating to the Client Information we hold in accordance with and subject to the Data Privacy Laws to: (i) check whether we hold Client Information about Clients and to access such information; (ii) request the correction of Client Information that is inaccurate; (iii) have a copy of the Client Information we hold about Clients provided to them or another fund where technically feasible; (iv) request the erasure of Client Information; and (v) request the restriction of processing concerning Clients. To do so, please send the request us at the details specified below. Clients are required to ensure the Client Information we hold about them is up-to-date and accurate and they must notify us of any changes to the Client Information provided to us. If Clients provided consent for us to use their Client Information, including for marketing purposes, they have the right, under applicable Data Privacy Laws, to withdraw consent and we will process this withdrawal promptly.
The CCO will monitor for compliance with the Privacy Notice Policy and will coordinate the dissemination of the Privacy Notice Policy. The CCO’s contact details are as follows:
Jeff Gregory, CCO
Ramsey Quantitative Systems, Inc.
1515 Ormsby Station Court
Louisville, KY 40223
Under applicable Data Privacy Laws, Clients may also make a complaint to a supervisory authority in their country of residence.
Changes to this Privacy Notice Policy
We may change this Privacy Notice Policy from time to time. The latest version will be posted on our website.