Privacy Policy | Quantedge

The Manager and the Fund (together, “Quantedge”) are required by applicable laws and regulations, including the Singapore Personal Data Protection Act 2012, Data Protection Act (As Revised) of the Cayman Islands, CFTC Regulation 160 and other US federal and state regulations to adopt certain procedures designed to maintain and secure the Personal Data of its current, former, and prospective Shareholders from inappropriate disclosure to third parties. The following policy (this “Privacy Policy”) is designed to meet the standards set forth in the aforementioned laws and regulations. This Privacy Policy sets out the terms on which the Manager, its associated or affiliated companies, the Fund, the Administrator and their respective employees, agents or contractors may collect, use, retain, disclose and transfer Personal Data of the current, former and prospective Shareholders of the Fund. For the purposes of European data protection laws, Quantedge are the data controllers of Shareholder Personal Data.

Quantedge is committed to keeping Personal Data collected from current, former and prospective Shareholders confidential and secure. The proper handling of Personal Data is one of our highest priorities. Quantedge never sells Personal Data relating to its Shareholders to any outside third parties, other than in the context of a reorganization or other corporate transaction, such as the sale of Quantedge or its assets.

Shareholder Information

Quantedge collects, directly from a Shareholder or through the Administrator, through the agent or financial adviser of the Shareholder, or any other third party who communicates with Quantedge on behalf of the Shareholder, and keeps, Personal Data about its Shareholders to provide the services requested by its Shareholders, to administer the Fund and the Shareholder’s business with Quantedge, and as otherwise provided in this Privacy Policy. This may include, without limitation, processing the Personal Data for the purposes of providing administrative services in connection with its/his/her investment, preventing fraud, carrying out money laundering checks or conflict checks, complying with any applicable laws or regulations and reporting to and auditing by national and international regulatory bodies (collectively, the “Services”).

In particular, Quantedge may collect and process Personal Data from Shareholders in the following situations and for the following purposes:

In the normal conduct of business of Quantedge in relation to a Shareholder’s subscription for Participating Shares in the Fund, such as, when a Shareholder completes a subscription agreement or other form. This includes information such as name, address, social security number, assets, income, net worth, copies of financial documents and other information deemed necessary to evaluate the Shareholder’s identity and financial standing.
As a result and for the purposes of transactions with Quantedge, its affiliates if any, its Shareholders or others. This could include transactions completed with Quantedge or information received from outside vendors to complete transactions or to effect financial goals.
To fulfill other legal or business purposes as required for Quantedge’s business operations, such as dealing with possible complaints or future legal claims or investigations concerning a Shareholder, or tax, accounting, audit and recordkeeping purposes.
Quantedge also assembles background information, including background reports, credit reports, and other information about Shareholders from third party sources as part of its obligations to know its clients and for its internal purposes.

In connection with a prospective Shareholder’s subscription for Participating Shares in the Fund, Quantedge may collect and process Personal Data from the prospective Shareholder for the following purposes:

(a) ascertaining whether a prospective Shareholder meets the applicable suitability standards imposed by the jurisdiction of its/his/her residence and any laws, rules, regulations, guidelines, notices or directions that apply to Quantedge or the Administrator;

(b) enabling service providers who assist Quantedge or the Administrator to render the appropriate assistance to Quantedge or the Administrator, in relation to a prospective Shareholder’s subscription for Participating Shares in the Fund;

(c) enabling the Manager to provide a Shareholder with information (including via telephone calls, messages and any other means of electronic communication) about its investment products or those of its associates; and

(d) ensuring that Quantedge and the Administrator meet their obligations under any applicable laws, rules, regulations, guidelines, notices or directions, including:

(i) verifying compliance with the relevant laws, rules, regulations, guidelines, notices or directions that apply to Quantedge or the Administrator;

(ii) any obligations related to tax matters (such as identification or tax reporting and tax audit);

(iii) any obligations related to anti-money laundering and countering the financing of terrorism legislation or regulations; and

(iv) responding to any request for information made by a governmental or other regulatory body, any exchange or self-regulatory organization.

The provision of Personal Data by a Shareholder may be necessary in order for Quantedge to provide that Shareholder with the requested services, for the performance of any contractual relationship with that Shareholder, for the Shareholder and/or Quantedge to comply with any applicable legal or regulatory obligations or for the other purposes as set out in this Privacy Policy where in furtherance of Quantedge’s legitimate interests.

Quantedge will not use Personal Data of its Shareholders for purposes that are incompatible with the purposes for which it was collected.

Please note that Shareholders may have a right to object to processing of their Personal Data where that processing is carried out for Quantedge’s legitimate interest.

Sharing Information

In order to provide Shareholders with the Services, Quantedge will disclose the Personal Data to its associated or affiliated companies, the Administrator, the financial adviser of a Shareholder and other third parties who will process the Personal Data on the Fund’s behalf for the purposes and in the manner set out in this Privacy Policy.

Save as otherwise provided in this Privacy Policy, Quantedge will not transfer or disclose the Personal Data of its Shareholders to any external organization, unless such transfer or disclosure is made after Quantedge has the consent of the relevant Shareholder, or is required by any law or regulation, or Quantedge has previously informed the relevant Shareholder.

Where disclosure is necessary to fulfil the purposes for which the Personal Data was collected, or a directly related purpose:

Quantedge may share the Personal Data of its Shareholders with non-affiliated companies or individuals:
(i) as permitted by law or as required to provide services to its Shareholders, such as with representatives within Quantedge, securities clearing firms, mutual fund companies, insurance companies and other financial services providers, or
(ii) to comply with any legal or regulatory requirements or otherwise in connection with the establishment and defense of any legal claim.
Quantedge may also disclose Personal Data to another financial services provider in connection with the transfer of an account to such financial services provider.
Further, in the normal course of its business, Quantedge may disclose information it collects about Shareholders to companies or individuals that contract with Quantedge to perform servicing functions such as:
(a) client due diligence;
(b) recordkeeping;
(c) computer-related services; and
(d) good faith disclosure to regulators who have regulatory authority over Quantedge.

Quantedge does not provide Personal Data to mailing list vendors or companies that market Personal Data for any purpose.

When Quantedge provides Personal Data to service providers, it requires these providers to agree to safeguard such information, to use the information only for the intended purpose and to abide by applicable law.

As Quantedge and the parties mentioned above have places of business outside of Singapore, the Personal Data of Shareholders may be transferred to places outside of Singapore. Further information on International Data Transfers is set out below.

Employee Access to Information

Only employees with a valid business reason have access to Shareholder’s Personal Data. These employees are educated on the importance of maintaining the confidentiality and security of this information. They are required to abide by Quantedge’s information handling practices.

Protection of Information

Quantedge maintains security standards to protect Shareholder information, whether written, spoken, physical or electronic. Quantedge updates and checks its physical mechanisms and electronic systems to ensure the protection and integrity of information. Given the nature of information security, there is no guarantee that such safeguards will always prevent a leak of information security. Quantedge may be prone to information security and related risks resulting from breaches in cybersecurity, which can result from deliberate attacks such as hacking or other unintentional events, notwithstanding reasonable steps having been taken by Quantedge to prevent or repel them. If the security of Personal Data is compromised, the affected individuals will receive notice of the data security breach where required by and consistent with applicable law.

Rights relating to Personal Data

Quantedge’s goal is to maintain accurate, up to date Shareholder records in accordance with industry standards. Quantedge has procedures in place to keep information current and complete, including requesting Shareholders for updates on their information from time to time. Shareholders may request to access the information maintained about them, and any inaccurate information will be rectified as soon as the matter is brought to Quantedge’s attention by contacting the Administrator and the Manager. Shareholders may also object to any future dissemination or processing of information relating to that Shareholder that is likely to cause or is causing damage or distress, or request for erasure of Personal Data for legitimate reasons, including where the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed. Shareholders may also ask for a copy of Personal Data to be provided to them, or a third party, in a digital format. Shareholders may also have the right to lodge a complaint with the relevant supervisory authority in the event that any applicable laws or regulations have been breached.

International Data Transfers

The Personal Data of current, former and prospective Shareholders will be transferred internationally, including from the European Economic Area (“EEA”), to Singapore, the U.S. and other countries which the European Union has deemed do not provide “adequate” protection for Personal Data. By submitting its Personal Data to Quantedge, each Shareholder consents to the transfer of its personal data to Quantedge and the other recipients described in this Privacy Policy that are located outside of the EEA. Shareholders may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before a Shareholder’s withdrawal. This Privacy Policy applies regardless of the international transfer or processing of Personal Data.

E-Mail and Electronic Communications

Communications with Quantedge may be conducted via email, telephone call, official instant messaging channels (if any) or such other means as may from time to time be permitted by the Manager. Should Shareholders send Quantedge questions and comments via such channels, Quantedge will share the Shareholder’s correspondence only with those employees or agents addressing the Shareholder’s questions and concerns.

Quantedge will retain all written communication until it has provided the Shareholder with a complete and satisfactory response. Ultimately, Quantedge will either discard the communication or archive it according to the requirements under applicable securities laws or in accordance with the retention periods set out below.

Please note that, unless expressly advised otherwise, Quantedge’s e-mail facilities and communication channels via Whatsapp do not provide a means for completely secure and private communications. Although every attempt will be made by Quantedge to keep Shareholder information confidential, from a technical standpoint, there is still a risk and Quantedge is not able to ensure confidentiality of information by the respective service providers. For that reason, please do not use e-mail or Whatsapp to communicate information to Quantedge that is considered to be confidential. If the Shareholder wishes, confidential communications with Quantedge may be conducted via telephone call, or sent as encrypted or password protected attachments. To improve services and for security reasons Quantedge may monitor or record telephone calls and electronic communications.

Disclosure of Privacy Policy

Quantedge recognizes and respects the privacy concerns of its potential, current and former Shareholders, and is committed to safeguarding their Personal Data. As a member of the financial services industry, Quantedge is providing this Privacy Policy for informational purposes to Shareholders and employees and will distribute and update it as required by law. It is also available upon request.

Retention

Quantedge intends to retain the information of each former Shareholder for a period of at least 5 years following the cessation of that Shareholder’s investment in the Fund, or such longer period as permitted or required under any applicable law or regulation.

Consequences of Not Providing Personal Data

Where Quantedge requires Shareholder Personal Data to comply with anti-money laundering or other legal or regulatory requirements, failure to provide this information means Quantedge may not be able to accept the Shareholder as a subscriber in the applicable Fund or may result in Quantedge terminating its relationship with the Shareholder either by effecting a compulsory redemption of such Shareholder’s Participating Shares or by carrying out such other acts Quantedge determines to be necessary in order to comply with such requirements.

Contact

If you have any questions or comments regarding Quantedge’s Privacy Policy, or wish to amend or obtain more information on your Personal Data, please contact [email protected]. For the purpose of Singapore Personal Data Protection Act 2012, Quantedge’s data protection officer can be contacted at +65 6511 2388.