Effective Date: September 1, 2021
Welcome to the web site (the “Site”) of Cambrian Asset Management. The terms “Cambrian,” “we,” “us,” and “our” include Cambrian Asset Management and our affiliates. This Site is operated by Cambrian and has been created to provide information about our company and the services we offer, including one or more investment funds (“Funds”) (together with the Site, the “Services”) to our Service visitors and users (“you”, “your”). This Privacy Policy sets forth our policy with respect to information including personally identifiable data (“Personal Information”)and other information that is collected from visitors to the Site and Services.
This Privacy Policy is incorporated by reference into the Cambrian Terms of Service (the “Terms”). Any defined terms used and not defined herein shall have the meanings given to such terms in the Terms.
By creating an account on the Site or by otherwise submitting Personal Information to us through the Site, you give your consent to the collection and use of your Personal Information as explained in this Policy you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Cambrian and the authorized third parties referred to herein located in the United States.
When We Collect Your Information
Information Requests.
If you request information through the Site or to us, we may require you to provide us with certain information, such as your name, country, email address, and investor accreditation status.
Registration.
If you register an Account on the Service, then you must provide us with certain information, such as your name, address, and contact email address. Additionally, as a part of the subscription process, we may collect certain other information from you, such as your tax ID number, social security number, and information concerning your financial history, income, and net worth. If you are accessing the Service on behalf of an organization, you may be required to provide the information about the organization, such as its certificate of incorporation and date of formation.
In Connection with an Investment.
In order to process payments of amounts you invest in a Fund, we collect certain payment information, including your bank routing numbers, bank account numbers, and billing address.
Using the Service.
We collect information about your use of the Service. For example, we collect the information that you provide to us in connection with accessing the Investor Portal to view the performance of a Fund or your investment in a Fund.
Communications.
If you contact us directly, we may receive additional information about you. For example, when you contact us through our general investor email address, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.
Location Information.
We collect and store your location information if you enable your device to send it to us, such as by use of geolocation features in the device(s) through which you access the Service, or by inference from other information we collect (for example, your IP address indicates the general geographic region from which you are connecting to the Internet).
Cookies, Automatic Data Collection, and Related Technologies.
The Service collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics.
When you visit the Service, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Our service providers may collect information about your online activities over time and across different online services. Cookies are small text files placed on your computer browser when you visit a website. Most browsers allow you to block and delete cookies. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.
We work with analytics providers who may use cookies and similar technologies to collect and analyze information about use of the Service and report on activities and trends. These services may also collect information regarding the use of other websites, apps and online resources. One of the service providers that we use for data analytics is Google Analytics. If you do not want Google Analytics to collect and use information about your use of the Service, then you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/).
By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.
How We may use or Disclose your Information
Internal and Service-Related Usage.
We are not in the business of selling your Personal Information; however there are certain circumstances in which we may share your Personal Information with certain third parties without further notice to you, as set forth below. We use information, including unique identifiers and your location for internal and service-related purposes, such as data analytics, and may share this information with service providers to allow us to provide, maintain, and improve the Service.
Communications.
We may send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, system maintenance, or to inform you about additional products or services that may be of interest to you.
Aggregate Data.
In an ongoing effort to better understand and serve the users of the Services, we often conduct research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregated and/or de-identified basis, and we may share this aggregated and/or de-identified data with our affiliates, agents and business partners. We may also disclose aggregated and/or de-identified user statistics and other metrics related to our Services in order to describe our products or services to current and prospective business partners and to other third parties for other lawful purposes.
Legal Rights.
We may use the information collected through the Service to enforce our Terms of Service or other legal rights.
We Use Vendors and Service Providers.
We may share any information that we receive through the Service with vendors and service providers retained in connection with the provision of the Service, including our payment processors, auditors, and other vendors for data analytics purposes.
As Required by Law and Similar Disclosures.
We may access, preserve, and disclose your information and/or other account information or content if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) enforce this Privacy Policy or other agreements; (iii) respond to your requests; or (iv) protect your, our, or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your information following any of the foregoing events will be governed by the provisions of the Privacy Policy in effect at the time Cambrian collected such information. We may also share your information within our group of companies.
With Your Consent.
We may also disclose your information with your permission.
Exclusions: This Privacy Policy does not apply to any Personal Information collected by us other than Personal Information collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to us through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
How We Protect Your Information
Keeping Your Information Safe
We limit access to the Personal Information you provide us to those employees who need access to that information in order to provide you with services related to the transactions you are entering into through the Sites. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards, and controls designed to protect your Personal Information.
We have invested in software, systems and procedures aimed at offering you a safe and secure transaction environment and protect your personal, financial and historical transaction information. While no security system is absolutely impenetrable, we plan to constantly review, refine and upgrade our security technology as new tools become available.
We will delete your Personal Information when it is no longer needed for these purposes. If we cannot delete it, for technical reasons, entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
The Importance of Being Accurate
We have security standards and procedures in place designed to prevent unauthorized access to your Personal Information. A key part of this process helps ensure that the Personal Information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. We only use your Personal Information as appropriate to provide you with quality services and to ensure security. For example, we may use the information collected from you to verify your identity and contact information.
Your Rights Over Personal Information
Subject to applicable local law, you have rights regarding your Personal Information, including: access, rectification, erasure and blocking, restriction of use, objection to use, data portability, and the lodging of a claim to your local data protection authority.
If you would like to discuss or exercise the above rights, please contact us using the details set out at the end of this Privacy Policy.
An Ongoing Commitment to Your Privacy
We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, your Personal Information will continue to be protected by the privacy policies and principles described in the then-current version of this Policy. Should you redeem or otherwise dispose of your investments with us, Cambrian will retain your information for regulatory compliance, internal record-keeping and other legal purposes.
Security of your Information
We take commercially reasonable steps to protect the Personal Information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Information to us via the Internet.
CalOPPA Disclosures
Some web browsers incorporate a “Do Not Track” feature. Because there is not yet an accepted standard for how to respond to Do Not Track signals, our website does not currently respond to such signals.
Children’s Privacy
We do not knowingly collect, maintain, or use personal information, as defined by the Federal Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”) Rule, from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If we learn that we have collected any personal information from children under 13, then we will promptly take steps to delete such information and terminate the child’s account.
International Users
If you visit the Service from the European Union or other regions with laws governing data collection and use, then please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information to the Service, you consent to any transfer and processing in accordance with this Privacy Policy.
Links to Other Web Sites
This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Cambrian endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
Changes to Our Privacy Policy
The Services and our business may change from time to time. Asa result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
New Uses of Information.
From time-to-time, we may desire to use information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, then we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.
Access to Information; Contacting Us.
To keep your Personal Information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via the Services. Please also feel free to contact us if you have any questions about our Privacy Policy or the information practices of the Services.
You may contact us at ir@Cambrianasset.com.
