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 information.

This policy (this “Privacy Policy”) sets out how Brevet collects, utilizes, and maintains your non-public personal information, including through this website. This Privacy Policy is intended to comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the California Consumer Privacy Act of 2018 (the “CCPA”, and together with the GDPR, the “Data Protection Legislation”).

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

Privacy Policy Updates

This Privacy Policy was last updated in December 2019. It provides a general overview of the ways in which Brevet uses your personal information 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 information 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 Information Brevet May Collect

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

Categories of Personal Information Specific Types of Personal Information
Identifiers Real names, postal addresses, email addresses, passport numbers, social security numbers, and driver’s license numbers or other identification numbers
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual Real names, signatures, postal addresses, email addresses, telephone numbers, fax numbers, birth dates, passport numbers, social security numbers, driver’s license numbers or other identification numbers, credit history, bank account details, and other financial and tax-related information
Characteristics of protected classifications under California or federal law Age (40 years or older), national origin, citizenship, marital status, race, color, sex, veteran or military status, sexual orientation, religion or creed, medical condition, physical or mental disability, or genetic information (including familial genetic information)
Commercial information Records and information related to source of funds, source of wealth, investor qualification, financial sophistication, contributions, withdrawals, distributions, account statements, other account-related information, past transactions entered into, meetings with, and visits to, Brevet, and tax-related information
Internet or other electronic network activity information IP addresses, browser types and versions, device identifiers, location and time zone settings, network and/or service providers, operating systems and platforms, page response times and download errors, browsing history, search history, and length of visits to certain pages of websites
Professional or employment-related information Professional relationships and background, employment, and employment history

 

How Brevet Collects This Personal Information

Brevet collects your personal information 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;
  • Transactions in which you have invested, including account balances, investments, redemptions, management fees, and performance allocations;
  • Publicly available sources such as the corporate website of the organization you are working for;
  • Directly from third parties and/or service providers
  • From interactions with social media and use of other websites that display our advertisements;
  • By means of cookies (that are placed when you visit this website or opt-in for Brevet’s mailings and/or other marketing that Brevet sends you); and/or
  • Other interactions you may have with Brevet (for example, discussions with employees).

Additionally, like many organizations, Brevet may place a “cookie” (a small data file) on the hard drive of your computer when you first connect to this website. First-party cookies are cookies set by the website you are visiting. A website may also use external services that set their own cookies, known as third-party cookies.

Brevet may use first-party cookies to let us know that you have visited this website before, and recognize you so that you can avoid re-entering information each time you visit the website. We may also use first-party cookies to help us analyze the use of this website.

You can set your browser to refuse these types of cookies from this website. However, some portions of the website may not function properly or may function more slowly if you choose to reject cookies. For information on how to limit, delete, or disable cookies for some commonly used browsers, please visit:

Some or all of this website may make use of Google Analytics, a web analytics service that uses cookies, including Google Analytics Demographics and Interest Reporting. This website may also make use of Google Analytics for Display Advertising features, including Remarketing, 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 to the extent we use any Google Analytics 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, which can be found at https://adssettings.google.com.
  • 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, which 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.
  • You may 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, which can be found at https://tools.google.com/dlpage/gaoptout?hl=en.

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 email message designed to track pages viewed or messages opened. Web log information would be 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 email messages in order to determine whether messages have been opened. You have the right to opt-out of receiving such promotional emails and beacons at any time by clicking on the “unsubscribe” link in every email Brevet sends you or by contacting us at privacy@brevetcapital.com.

How Brevet Legally Collects This Personal Information

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

  • You have consented to its doing so;
  • Collecting and using your personal information 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 Information With

Brevet may share your personal information with:

  • Any and all of the Brevet entities;
  • Non-affiliated service providers, such as attorneys, auditors, accountants, tax advisers, administrators, custodians, depositaries, distribution managers, brokerage firms, event organizers, or other agents, advisers, or service providers engaged by Brevet;
  • Other third parties and/or service providers we use to help run our business, such as marketing partners and technology providers; and
  • Regulatory, prosecuting, and other governmental agencies or departments and parties to litigation (whether pending or threatened) in any country or territory, to comply with our legal and regulatory obligations.

As is common in the industry, non-affiliated 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.

Brevet may share your personal information 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 information will, in most instances, be part of the assets transferred. Brevet may in its discretion notify you of any such business transition via email, to the extent you have elected to provide Brevet such information and elected to receive such communications, and/or notice on this website.

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 may allow 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 email. Whether or not you decide to participate in such an offer is up to you.

Brevet may use your personal information to provide you with advertisements that are targeted to your specific needs and interests. Such advertisements link directly to third-party websites. Brevet has no control over the content or privacy policies of any such websites, and therefore Brevet encourages you to review such content and policies prior to submitting any personal information to them.

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 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.

Personal Information That Brevet Discloses or Sells for a Business Purpose

In the preceding 12 months, Brevet has disclosed to one or more third parties and/or service providers the following categories of personal information:

  • Identifiers;
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual;
  • Characteristics of protected classifications under California or federal law;
  • Commercial information;
  • Internet or other electronic network activity information; and
  • Professional or employment-related information.

In the preceding 12 months, Brevet has not sold any personal information to a third party.

How Brevet Uses Your Personal Information

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

  • To facilitate your investment and the management and administration thereof on an ongoing basis as necessary to fulfill contractual and regulatory obligations related thereto;
  • To operate and improve this website, such as resolving technical issues, supporting security, analyzing user trends, detecting fraud or other types of abuse, and gathering broad demographic information for aggregate use;
  • In order to carry out anti-money laundering checks and related actions that Brevet considers appropriate or necessary to fulfill any of its 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 anti-money laundering policies and procedures;
  • To comply with its legal obligations, including the obligation to report information to regulatory, governmental, law enforcement, and tax authorities, to carry out audit checks and instruct auditors, and to maintain statutory registers;
  • To disclose information to other third parties and/or 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;
  • To monitor and record electronic communications for any of the purposes specified herein; and/or
  • To otherwise pursue the legitimate interests of Brevet, third parties, and/or service providers relating to your investment or potential investment.

Transfers of Personal Information

With respect to citizens of the EU or the EEA, Brevet relies on legally-provided mechanisms to lawfully transfer information across borders. Brevet has service providers whose personnel will have access to your personal information 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 information (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.

Retention of Your Information

Brevet and its service providers will retain your personal information 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 information 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 information about children under the age of 13.

Rights under the Data Protection Legislation

To the extent the Data Protection Legislation applies, individuals have certain specific rights provided thereunder. For personal information that Brevet collects about you, Brevet hereby notifies you that you have the following rights:

GDPR Rights

  • Delete Personal Data: You can ask Brevet to erase or delete all or some of your personal data in some limited circumstances.
  • 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 is inaccurate or incomplete.
  • 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

CCPA Rights

  • Right to Access and/or Take Your Personal Information: On receipt of a verifiable request from you, we will disclose:
  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any;
  • The specific pieces of personal information we have collected about you; and
  • If we sold or disclosed your personal information for a business purpose:
    • The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
    • The categories of personal information that we disclosed about you for a business purpose.
  • Right to Delete: On receipt of a verifiable request from you, subject to certain exceptions permitted under applicable law, we will:
  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.
  • Protection from Discrimination: You have the right to not be discriminated against by us because you exercised any of the CCPA rights described above; provided that Brevet may charge different prices or rates, or provide a different level or quality of services, if such difference is reasonably related to the value provided to Brevet by your data.

To make any requests as listed above (to the extent the relevant Data Protection Legislation applies), please either call us, toll-free, at (855) 650-0317 or email us at privacy@brevetcapital.com. You will need to provide us with enough information to identify you, including proof of your identity and address, and a description of what right you wish to exercise. Please note that you may only make a CCPA access request twice within a 12-month period.

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 information to third parties for their direct marketing purposes during the immediately prior calendar year. To make such a request, please send an email 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 information 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 information 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 information.

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. Brevet has no regulatory obligations under the GDPR to appoint a data protection officer (DPO) and has no DPO currently appointed.

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 information 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 information, please 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 information 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.