COALITION INVESTMENT PARTNERS
Last updated: January 17, 2020
This Policy applies directly to individuals who are data subjects in their interactions with Coalition. If business entities provide Coalition with personal data on individuals (e.g., employees, members, etc.) in relation to a relationship with Coalition, this Policy will apply to those individuals and such entity should transmit this document to such individuals or otherwise advise them of its content.
In this Policy, “personal data” refers to any data related to an identified or identifiable data subject. Coalition may collect personal data including, but not limited to, name, contact details (address, telephone, fax, email – both private and professional), date of birth, social security number, taxpayer identification number, bank account details, jurisdiction of tax residence, current or former employers, work authorization status, education, business activities, affiliations, investment objectives, assets, investment experience, transaction history, income, wire transfer instructions, signatures, member portal login credentials, and information related to an identified or identifiable data subject.
Coalition’s Website may contain links to other websites owned or operated by third parties. If data subjects visit one of these linked sites, they should review their separate privacy and other policies. Coalition has no control over and is not responsible for, and this Policy does not apply to, the privacy policies or practices of such sites.
The legal basis for Coalition’s processing of personal data generally includes one of the following: (a) the data subject has consented to the processing; (b) processing is needed to fulfill a request made by the data subject; (c) processing is required to comply with a legal or regulatory obligation; or (d) processing is necessary for reasons that are otherwise in Coalition’s legitimate interest as a company. For example, Coalition may use personal data:
- to communicate and respond to inquiries from data subjects,
- to provide advisory services,
- to open data subjects’ accounts or process transactions for such accounts (and to evaluate eligibility for accounts and participation in funds),
- to contact data subjects with information or promotional materials about Coalition,
- for recruitment and talent management,
- to develop new products or services,
- to review usage of and enhance experience with its Website,
- to operate, evaluate, and improve its business, and
- to comply with and enforce applicable regulatory and legal requirements and industry standards.
To opt-out of any marketing emails from Coalition, data subjects should follow the unsubscribe or opt-out instructions in such emails, and Coalition will use commercially reasonable efforts to promptly implement such requests. Data subjects may continue to receive non-marketing communications related to administrative or transactional matters regarding their existing relationship with Coalition.
Coalition does not sell personal data to any third parties. Coalition may share personal data as needed to fulfill the purposes described in the “Data Usage” section above, including:
- with nonaffiliated persons and entities that assist it in managing and operating its funds and investments or that perform other services for it, such as attorneys, tax advisors, broker-dealers, fund administrators, accountants, auditors, custodians, and entities that assist Coalition with the distribution of stock to its investors;
- to lenders who provide financing for relevant funds;
- to Coalition affiliates, for marketing purposes unless the data subject has opted out of such sharing, or for purposes of facilitating a data subject’s investments or requests for information;
- to the relevant funds in which a data subject has invested or is interested in investing;
- as permitted or required by law, including to verify eligibility under OFAC, for governmental permits or licensing, or other regulatory and compliance requirements; or
- as requested or approved by the applicable data subject (including to such data subject’s advisors, which can include, among others, accountants, investment advisors, and/or attorneys).
In the event of a merger, consolidation, sale, or transfer of all or substantially all of Coalition’s assets or business, one of the assets which would generally be transferred is the personal data that has been collected. Coalition will advise a successor or successors in interest of the terms of this Policy and the expectation that such successor(s) will comply with the terms hereof.
Coalition requires third-party service providers to protect the confidentiality of data subjects’ information and to use the information only for the purposes for which Coalition discloses the information to them. The following describes how nonpublic personal information may be disclosed to such persons:
Coalition takes commercially reasonable physical, administrative, and technical precautions designed to protect data subjects’ personal data from loss, misuse, or unauthorized alteration. While Coalition uses reasonable efforts to safeguard the confidentiality of data subjects’ personal data, it cannot guarantee that data will always remain secure due to transmission errors, outside events, third party hacking or other causes.
Coalition restricts access to any nonpublic personal data about data subjects to those employees who need to know that information to provide services to the partnership and its investors.
Coalition will typically maintain personal data so long as it can reasonably foresee such personal data may be required in connection with its relationship with the applicable data subject. Coalition may retain personal data for a longer period as necessary to comply with any applicable legal or regulatory requirements and reasonable records retention policies or as otherwise necessary for a legitimate reason (such as to resolve disputes and enforce its agreements and contracts).
Data subjects may access and correct personal data held by Coalition, except where the burden of providing such access would be disproportionate to the risks to the data subject’s privacy, or where the rights of other persons would be violated. Data subjects may also request erasure of their personal data in certain circumstances (and subject to any applicable legally required or permitted retention standards). To request access to, correction of, or erasure of personal data, data subjects should contact Coalition as set forth at the end of this Policy. In the case of a request to exercise one of the above listed rights, data subjects may be required to submit a valid personal identification proof to Coalition. Coalition will deal with such requests in accordance with applicable law and process the request within the time provided by applicable law.
Coalition’s Website and services are not directed toward children under 13. If a parent or guardian becomes aware that his or her child has provided Coalition with personal data, they should contact Coalition as set forth at the end of this Policy and Coalition will take reasonable steps to promptly remove such data from its systems (subject to any applicable, legally required or permitted, retention standards).
Coalition is based in the United States, and personal data collected by it and its affiliates worldwide (including within the EU and Switzerland) may be transferred to the United States for processing. By submitting personal data to Coalition or its affiliates, data subjects consent to the transmission of personal data to the United States. Coalition is generally the “data controller” as that term is used under applicable data privacy laws. Coalition may be liable in cases of onward transfers of personal data to third parties.
California law entitles California residents to certain additional protections regarding personal data. For purposes of this section alone, “personal data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. California residents have the right to request:
- information regarding their personal data Coalition has collected (the categories of personal data collected, the source of such data, and how such data has been used);
- a description of whether Coalition has disclosed their personal data to third parties, and if so what categories of data have been disclosed, and to what categories of third parties;
- a copy of their personal data collected by Coalition in the past 12 months; and
- that their personal data be deleted.
To make such a request, California residents should contact Coalition as set forth below. Coalition may require verification of the data subject’s identity before further processing the request. In certain instances, Coalition may be required or permitted by law to decline some or all of such request.
Should data subjects have any questions, comments or concerns about Coalition’s privacy practices or wish to exercise any of their rights under this Policy, they can contact firstname.lastname@example.org.
This Policy may be updated to reflect changes in its practice or to comply with applicable laws. Coalition will notify data subjects of any material changes to this Policy, as required by law, including by posting the updated version on the Website. The revised Policy will be effective immediately upon posting to the Coalition Website.