Privacy Policy

Brevet Capital Management, LLC (together with its affiliates, “Brevet”) places a high priority on maintaining the confidentiality and security of your non-public personal data.

This policy (this “Privacy Policy”) sets out how Brevet collects, utilizes, and maintains your non-public personal data, including through this website. This Privacy Policy is intended to comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Please read this notice carefully to understand Brevet’s privacy policies and procedures.

Privacy Policy Updates

This Privacy Policy was last updated on December 2018. It provides a general overview of the ways in which Brevet uses your personal data and important information on electronic communication. This Privacy Policy may be changed at any time to reflect changes in Brevet’s practices concerning the collection and use of personal data or where required to comply with applicable law. Any revised Privacy Policy will be effective immediately upon delivery to you and/or posting to Brevet’s website. Brevet recommends checking this section of the website frequently to view the latest updates.

The Type of Personal Data Brevet May Collect

Brevet may collect and process the following types of personal data, without limitation:

  • Contact details (including names, mailing addresses, email addresses, telephone numbers, and fax numbers);
  • Information required for Brevet to meet legal and regulatory requirements, in particular in respect of anti-money laundering legislation, including information on source of funds, source of wealth, investor qualifications, and tax-related information;
  • Information provided in the course of the provision of its services (g., information on professional relationships and background, financial wealth and assets held, transactions entered into, birth date, nationality, passport or other identification number, and employment information);
  • Financial information, such as distribution and other account related information;
  • Meetings attended and visits to Brevet offices; and/or
  • Any other information you may provide to Brevet.

How Brevet Collects This Personal Data

Brevet collects your personal data from the following sources:

  • Subscription documents as well as certain other information provided in writing, in person, by telephone, electronically, or by any other means;
  • From publicly available sources such as the corporate website of the organization you are working for;
  • From interactions with social media and use of other websites that display our advertisements; and/or
  • Other interactions you may have with Brevet (for example, discussions with employees).

Additionally, like many organizations, Brevet places a “cookie” (a small data file) on the hard drive of your computer when you first connect to this website to help analyze web traffic and improve the content or functions of this website. The cookie lets Brevet know that you have visited this website before, and recognizes you so that you can avoid re-entering information each time you visit this website. The cookie also helps Brevet analyze use of this website.

You can set your browser to refuse cookies from this website. However, some portions of the website will not function properly or may function more slowly if you choose to reject cookies. By using our website and not disabling cookies, you consent to allowing their use for the described purposes.

Brevet may use third-party advertising companies to serve advertisements on other websites you may visit. To accomplish this, these companies may employ anonymous cookies and web beacons (also known as Internet tags, pixel tags, and clear GIFs) that allow this website to collect web log information. A web beacon is a graphic on a web page or in an e-mail message designed to track pages viewed or messages opened. Web log information is gathered when you visit our website. The web server automatically recognizes some non-personal information, such as the date and time you visited our website, the pages you visited, the website you came from, the type of browser you are using, the type of operating system you are using, and the domain name and address of your ISP. Brevet may also include web beacons in promotional e-mail messages in order to determine whether messages have been opened. If you do not wish to receive such beacons, you can unsubscribe by clicking on the “unsubscribe” link in every e-mail Brevet sends you or by contacting us at privacy@brevetcapital.com.

Brevet may also work with a third-party vendor to analyze users’ browsing patterns on our website, who may place cookies on your computer to receive information about your browsing activity on the website, and help us to provide you with a more personalized experience.

In addition to cookie data, Brevet may also process other technical information about you, including but not limited to: (1) your IP address, browser type and version, device identifier, location and time zone setting, network and/or service provider, operating system and platform, page response times, and download errors; (2) details about your visit, including the websites you visit before and after our website and the products and services you viewed or searched for; and (3) length of visits to certain pages, interaction with elements on our website, and methods used to browse away from the page.

Brevet may use this information to analyze trends, administer the Site, detect fraud or other types of abuse, and gather broad demographic information for aggregate use. Brevet may associate this information with your personally identifiable information to resolve technical issues, support security for our users, and/or take action on any activity that may violate the Privacy Policy.

How Brevet Legally Collects This Personal Data

Brevet is able to legally collect and use your personal data because:

  • You have consented to its doing so;
  • Collecting and using your personal data is necessary to fulfill legitimate business interests, which may include (i) fulfilling contractual obligations or otherwise performing services for you; or (ii) investigating, defending against, or prosecuting any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum or otherwise protecting your legal rights; and/or
  • It is necessary to comply with any applicable regulatory, judicial, or other legal obligation.

Who Brevet Shares Your Personal Data With

Brevet may share your personal data between any and all of the Brevet entities as well as with non-affiliated third parties for any of the purposes described in this Privacy Policy. Brevet may share your personal data with attorneys, auditors, accountants, tax advisers, administrators, custodians, depositaries, distribution managers and brokerage firms, event organizers, or other agents, advisers, or service providers engaged by Brevet. As is common in the industry, non-affiliated third party companies may from time to time be used to provide certain services, such as administration services, tax compliance services, reporting, preparing account statements and other information, organizing events, conducting research on client satisfaction, and gathering shareholder proxies. These companies may have access to your personal information but are permitted to use the information solely to provide the specific service or as otherwise permitted by law.

If you are a citizen or resident of the European Union (“EU”) or the European Economic Area (“EEA”), Brevet will ensure appropriate safeguards are in place as required by applicable law to adequately protect your personal information if it is processed by third parties outside the EU and EEA, including the execution of standard contractual clauses if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission).

Third-Party Offers and Advertising

Brevet allows other companies, such as its marketing partners and affiliated companies, to offer their products and services to you, to register you on their websites, or to communicate with you about their products and services at a future date, through Brevet’s website or by e-mail. Whether or not you decide to participate in such an offer is up to you.

Brevet may use your personal data to provide you with advertisements that are targeted to your specific needs and interests. These advertisements link directly to third-party websites. Brevet has no control over the content or privacy policies of such websites, and therefore Brevet encourages you to review such content and policies prior to submitting any personal data to them. Brevet shares certain aggregate information, such as demographic information and the number of times users have viewed an advertisement, with third-party advertisers.

Brevet may allow certain companies to display advertisements on this website. Some of these ad networks may place a persistent cookie on your computer. Doing this allows such advertisers to recognize your computer each time it sends you an online advertisement. In this way, ad networks may compile information about where you, or others who are using your computer, saw its advertisements and determine which ads are clicked on. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you. Brevet may share certain non-personally identifiable information about you, such as your gender, age, or zip code, with ad networks to help them deliver more relevant advertisements through their ad networks. Brevet does not have access to or control over the cookies that may be placed by these parties on your computer and has no control over these parties’ privacy policies or information-collection practices.

Google Analytics

Some or all of this website makes use of Google Analytics Demographics and Interest Reporting. This website may also make use of other Google Analytics for Display Advertising features, including Remarketing, Google Display Network Impression Reporting, and/or the DoubleClick Campaign Manager integration.

Brevet is required by Google to disclose the following information to you in our Privacy Policy in connection with our use of any Google Analytics for Display Advertising features on our website:

  • You may opt out of Google Analytics for Display Advertising or customize Google Display Network ads by using the Google Ads Settings page. You may also prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on.
  • If this website makes use of the Google Analytics for Display Advertising Remarketing feature, Brevet will use such Remarketing feature to advertise online and third-party vendors, including Google, may show Brevet ads on websites across the Internet.
  • Brevet and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to (a) inform, optimize, and serve ads based on a user’s past visits to this website and/or (b) report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to this website.
  • Data from Google Analytics Demographics and Interest Reporting may be utilized by Brevet to help recognize and understand user preferences, to make improvements to this website, to choose content and advertising to display to you, and for other business purposes that will allow us to better serve you.]

How Brevet Uses Your Personal Data

Brevet, and/or any third-party service providers that Brevet engages (including any of their affiliates, agents, employees, delegates, or sub-contractors), may process your personal data for the following purposes, as applicable:

  • To facilitate your investment and the management and administration of your investment on an ongoing basis as necessary to fulfill all contractual and regulatory obligations related to your investment, including without limitation the acceptance and processing of subscription documents and redemption and transfer requests;
  • In order to carry out anti-money laundering checks and related actions that Brevet and/or Brevet’s service providers consider appropriate or necessary to fulfill any of their legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with Brevet’s and/or Brevet’s service providers’ anti-money laundering policies and procedures;
  • To comply with their legal obligations and, in particular, to report tax-related information to tax authorities;
  • To disclose information to other third parties such as service providers of Brevet and/or its service providers, regulatory authorities, and technology providers in order to comply with any legal obligation imposed on Brevet and/or its service providers or in order to pursue the legitimate interests of Brevet and/or its service providers;
  • To monitor and record electronic communications for any of the purposes specified herein; and/or
  • To otherwise pursue the legitimate interests of Brevet and/or its service providers relating to your investment or potential investment.

Transfers of Personal Data

With respect to citizens of the EU or the EEA, Brevet relies on legally-provided mechanisms to lawfully transfer data across borders. Brevet has service providers whose personnel will have access to your personal data and that are located in jurisdictions outside of the EU and EEA. These jurisdictions either (i) afford an adequate level of protection for your personal data (as declared by the European Commission) or, (ii) if they do not, then Brevet has entered into an agreement with these service providers incorporating clauses the same or substantially similar to the standard contractual clauses, as well as other relevant provisions contained in the GDPR, and obligations no less onerous than those contained in this Privacy Policy.

Affiliates and Business Transitions

Brevet may share your personal data with its affiliates that are subject to privacy policies that protect your information from disclosure to third parties in a manner similar to this Privacy Policy. In the event that Brevet (or its parent corporation) goes through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of its assets, our users’ personal data will, in most instances, be part of the assets transferred. Brevet may in its discretion notify you of any such business transition via e-mail, to the extent you have elected to provide Brevet such information and elected to receive such communications, and/or notice on this website.

Retention of Your Information

Brevet and its service providers will retain your personal data for the purposes described in this Privacy Policy as long as required for the purposes described above. In particular, and without limitation to the foregoing, Brevet and its service providers have legal obligations imposed on them under applicable legal systems that require them to retain your personal data for certain minimum time periods.

Browser “Do Not Track” Signals

Brevet does not honor “Do Not Track” (also known as “DNT”) signals or similar mechanisms transmitted by your web browsers. More information about browser tracking signals and Do Not Track signals can be found at http://allaboutdnt.org.

Protecting Children

Brevet takes special care to protect the safety of children in accordance to the Children’s Online Privacy Protection Act of 1998. While this website is a general audience website, Brevet does not permit children under the age of 13 to register or purchase any products or services. Brevet also does not collect or maintain personal data about children under the age of 13.

Rights Individuals Have or May Have in Relation to Data Processing

Citizens of the EU or the EEA have certain specific rights provided under the GDPR. For personal data that Brevet collects about you, Brevet hereby notifies you that you have the following rights:

  • Delete Personal Data: You can ask Brevet to erase or delete all or some of your personal data (g., if it is no longer necessary to provide services to you).
  • Right to Rectification: You also have the right to ask Brevet to change, update, or fix your personal data in certain cases, particularly if it’s inaccurate.
  • Object to, or Limit or Restrict, Use of Personal Data: You can ask Brevet to stop using all or some of your personal data (g., if Brevet has no legal right to keep using it) or to limit Brevet’s use of it (e.g., if your personal data is inaccurate or unlawfully held).
  • Right to Access and/or Take Your Data: You can ask Brevet for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

To make any requests as listed above, to the extent permitted by applicable law, please contact Brevet by emailing privacy@brevetcapital.com. Brevet will respond to any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.

Under California law, if you are a resident of California, you are entitled once per year to request and obtain certain information regarding Brevet’s disclosure, if any, of your personal data to third parties for their direct marketing purposes during the immediately prior calendar year. To make such a request, please send an e-mail to privacy@brevetcapital.com with your full name, email address, and postal address in your message. In response to your request, Brevet will provide you with a notice describing the cost-free means to opt-out of our sharing your personal data with third parties with whom Brevet does not share the same brand name, if the third party will use it for their direct marketing purposes.

Withdrawal of Your Consent

You can tell Brevet to stop collecting, using, and retaining your personal data at any time by emailing privacy@brevetcapital.com. You should note that notwithstanding your withdrawal of consent, Brevet may be legally required to retain some or all of your personal data.

Protection of Your Information

Brevet maintains appropriate administrative, technical, and physical security measures to protect your information and data against loss, misuse, and alteration. Brevet uses standard industry practices to help prevent unauthorized use of, access to, or alteration of visitor and user information and hosted data. In addition, Brevet restricts access to personal and account information to those employees who need to know that information in the course of their job responsibilities.

At the same time, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while Brevet strives to protect your personal data to the best of its ability, Brevet cannot guarantee or warrant the security of information you transmit to our website or over the Internet.

Further Information

The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive. You may have additional rights under other foreign or domestic privacy laws in addition to those that are described above. If you have any questions about this Privacy Policy, please email privacy@brevetcapital.com.

Making a Complaint

If you would like to make a complaint about the way Brevet has collected, used, or retained your personal data, please contact email privacy@brevetcapital.com.

If you are a citizen of the EU or the EEA, then you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by Brevet or its service providers infringes the GDPR.

Former Customers and Investors

This Privacy Policy also applies to former customers and investors in the EU and the EEA.