Privacy Policy

We are required by applicable law to make certain disclosures to you at least annually. Accordingly, below is a summary of our privacy policy. In addition, a complete copy of our privacy policy is available upon request, at no charge, by writing to us at CBAM Partners, LLC, 51 Astor Place, 12^th Floor, New York, NY  10003.

This policy was updated April 2019.

Financial institutions like CBAM are required to provide privacy notices to their clients.  We believe that protecting the privacy of your nonpublic personal information is of the utmost importance, and we are committed to maintaining the privacy of your nonpublic personal information in our possession.  As required by applicable rules, we are providing you with the following information.

We collect nonpublic personal information about you from the following sources: 

(i) Information we receive from you on fund subscription documents and related forms or employment agreements (for example, name, address, Social Security number, birth date, bank or broker account information, assets, income, and investment experience); and

(ii) Information about your transactions with us (for example, account activity and balances, and information regarding the account from which you make an investment or to which redemption or withdrawal proceeds are paid).

In order to service your account and process your transactions, we may provide your personal information to our affiliates and to firms that assist us in servicing your account or investment funds in which you invest and have a need for such information such as account or fund administrators and vendors that conduct anti-money laundering and background checks.  We require third party service providers to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them.  

We do not disclose any nonpublic information about our customers or former customers to anyone other than in connection with the administration, processing and servicing of customer accounts or investment funds as described above or to our accountants, tax preparers, attorneys and auditors or as otherwise permitted or required by law.  We do not sell your personal information and we do not discriminate in terms of fees or services among different categories of individual investors based upon their exercise of any rights relating to their personal information.

We restrict access to nonpublic personal information about you to our personnel who need to know that information in order to provide products or services to you.  We maintain physical, electronic and procedural controls in keeping with federal standards to safeguard your nonpublic personal information. 

If you would like further information about our collection and treatment of your personal information or would like to request that we delete your personal information from our records (to the extent we are not required by applicable rules, regulations or ongoing business needs to retain the information in our records), please contact us at compliance@cbam.com , by calling us at  212-603-6100.  We will take appropriate steps to verify the identity and authority of any parties (including you or your representatives) prior to responding to any inquiries or requests received relating to your personal information that we may possess.

Data That May Be Collected

CBAM may collect certain personal data with respect to Clients, for example, contact information (such as name, postal and email address, and telephone number); date of birth; information about your transactions with CBAM, CBAM funds or CBAM affiliates; information about your assets, net worth, source of funds or credit history; signatures; copies of identification documents; bank account details; and other personal information you provide to CBAM, such as through emails, subscription documents or agreements and other onboarding documents (that may include Social Security numbers, tax ID numbers or other government-issued identification numbers, to the extent permitted by applicable law), and other forms and documents you provide or that are provided by others on your behalf. In addition, with respect to employees or prospective employees of CBAM (each, an “Applicant”), CBAM may conduct a background check in connection with your employment and, as part of the background check or otherwise, collect the following types of personal data: gender; employment and education history; language proficiencies and other work-related skills; citizenship and work authorization status; military and veteran status; self-identified disability status; criminal background; information provided by references; and other information about your qualifications for employment such as information contained in your application for employment and materials submitted by you or on your behalf and compensation history and related information.

Use of Personal Data

CBAM will use Clients’ or Applicants’ personal data in the course of business where it is in the CBAM’s legitimate interests to contact Clients or Applicants, and to: respond to Clients or Applicants requests; send information about CBAM and its affiliates that may be of interest to Clients or Applicants; provide or manage CBAM services; create, manage and administer accounts you hold with CBAM or with an investment product or fund; send Clients promotional and advertising materials, newsletter and other communications; tax reporting; verify your identity and conduct identity and background checks for anti-money laundering purposes where you or your related organization are applying for CBAM products or services; manage career opportunities, including for recruitment purposes (such as processing job applications and conducting background checks in accordance with applicable law), employee onboarding and other human resources purposes; perform data analyses (such as market and customer research); develop, manage and improve CBAM business, products and services; determine and manage the effectiveness of CBAM communications; perform accounting, auditing, billing and reconciliation activities and other internal functions; protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities; conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and CBAM policies and terms; and for other purposes required or authorized by law, including other purposes for which you have provided your consent.

The provision of personal data by Clients may be necessary in order for CBAM to provide that Client with the requested services and communicate with Clients where in CBAM’s legitimate interests.

As a general matter, CBAM uses the personal information it obtains to comply with applicable legal requirements, carry out contractual obligations and pursue legitimate interests (such as managing CBAM’s Client relationships). Where required by applicable law, CBAM obtains consent to process personal information. 

Please note that you have a right to object to processing of your personal data where that processing is carried out for CBAM’s legitimate interest or for direct marketing.

Disclosure to Certain Third Parties

CBAM does not sell or otherwise share personal information about you, except as described in this notice. CBAM shares your personal information with its affiliates for the purposes identified in this notice. CBAM also shares the information with service providers who perform services on its behalf based on its instructions and record your information in one or more databases maintained by third parties in connection with the collection of data and communications and for legal or regulatory purposes, as described in this notice. CBAM does not authorize these service providers to use or disclose the information except as necessary to perform services on its behalf or comply with legal requirements. Examples of these service providers include fund administrators and entities that perform anti-money laundering testing services. In addition, CBAM may share your personal information with your authorized representatives.

CBAM also may disclose information about you (1) if CBAM is required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government entities based on a lawful disclosure request; (3) to establish, exercise or defend CBAM’s legal rights; (4) when CBAM believes disclosure is necessary or appropriate to prevent harm or financial loss; (5) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (6) otherwise with your consent. CBAM reserves the right to transfer personal information it has about you in the event of a potential or actual sale or transfer of all or a portion of CBAM’s business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution or liquidation).

Security and Retention

CBAM will take reasonable steps to protect Clients’ and Applicants’ personal data against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification, regardless of the format in which it is held. To the extent permitted by applicable law, CBAM retains personal information it obtains about you as long as: (i) it is needed for the purposes for which CBAM obtained it, in accordance with the provisions of this notice; or (ii) CBAM has another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data.

Updates

This notice and the policies described in this notice may be updated periodically and without prior notice to you to reflect changes in CBAM’s privacy practices or in applicable law, rules or regulations. The date as of which this notice was last updated appears at the beginning of the notice.