PRIVACY POLICY

HonTe Advisors, LLC, its affiliates and the Cayman Islands funds they manage (together, “HonTe,” “we,” “us,” or “our”) believe that protecting the privacy of our current, former, and prospective clients (who are natural persons), as well as our online visitors, is important.  The following privacy policy (“Privacy Policy”) explains how we collect, use, and disclose personal data (as defined below) from and about you through your interactions with us, including your interactions with our website, honteinv.com, (the “Website”).  Please review this Privacy Policy and our Terms & Conditions carefully.

This Privacy Policy provides information on our use of your personal data in accordance with relevant laws and regulations, including the Cayman Islands Data Protection Law, 2017 (“DPL”) and the California Consumer Privacy Act (“CCPA”).  The rights discussed in certain sections of this Privacy Policy may be subject to exemptions or other limitations under applicable law.

Depending on where you are located or the funds you invest in, different sections of this Privacy Policy may apply specifically to you.  Please review this Privacy Policy carefully to understand what we do in regards to your personal data, and where applicable, the following sections:

• For our investors who are, or are associated with, investors in our funds based in the Cayman Islands (the “Cayman Funds”), see the below section, “Additional Rights Relating to Investors in the Cayman Funds” for a description of your rights and other information related to the DPL.
• If you are a California resident and subject to the CCPA, see the below section, “Additional Information for California Residents” for a description of your rights with regard to your personal information (as defined by the CCPA) and other information related to the CCPA.

Personal Data Collected

HonTe may collect nonpublic personal information and other personal information about you to facilitate your investments and for our business and commercial purposes.  For purposes of California residents only, pursuant to the CCPA, “personal information” includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household.  “Personal data” for the purposes of this Privacy Policy means any information that can directly or indirectly identify you and includes nonpublic personal information and, with regard to California residents only, personal information as defined under the CCPA.  HonTe may collect the following categories of personal data from or about you:

• Identifiers and similar information such as a name, address, date of birth, email address, Social Security number, driver’s license number, passport number, online identifiers, or other similar identifiers.
• Additional information protected under certain federal or state laws, like a signature, education information, state identification number, credit card, bank account, or other financial information.
• Characteristics of protected classifications under certain federal or state laws, including gender, national origin, or marital status.
• Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth.
• Internet or other electronic network activity information, including interactions with our Website or use of certain online tools.
• Professional or employment-related information, including occupation, compensation, employer, and title.
• Audio, electronic, visual, or similar information, including interactions with us on video communications platforms.
• Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information.

Sources of Personal Data

HonTe may collect personal data about you directly from you and/or your intermediaries through sources such as:

• account applications, subscription agreements, and other forms or related documentation;
• written, electronic, or verbal correspondence with us or our service providers;
• client transactions;
• a client’s brokerage or financial advisory firm, financial advisor, or consultant; and/or
• information captured on applicable websites.

In addition, HonTe may collect personal data from different sources, such as:

• our affiliates, our service providers, or our affiliates’ service providers;
• public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or
• from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

Purposes for Collecting, Using, and Processing Personal Data

HonTe may collect, use, and process your personal data for the following business or commercial purposes:

• performing our contractual obligations to a client, including providing updates on performance, providing tax reporting, and other operational matters;
• complying with our legal or regulatory obligations;
• detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks; and
• pursuing our legitimate interests or those of a third party where we consider that, on balance, our (or their) legitimate interests are not overridden by your interests, fundamental rights, or freedoms, including performing services on behalf of a fund like fulfilling your requests, maintaining or servicing accounts, providing client relations services, processing subscriptions, verifying information, and processing payments or providing similar services, and enabling or effecting commercial transactions, including using bank account details to remit funds and process distributions.

Sharing Personal Data

HonTe may share all or some of your personal data that we collect with our affiliates in order to service your account.  Otherwise, we do not disclose any personal data about you, except:

• to counterparties and service providers, including administrators, banks, auditors, law firms, consultants, and placement agents and entities that have been advised as to the proper handling of such data;
• at your request or direction or with your consent;
• where we believe in good faith that the disclosure is required or permitted under law, to cooperate with regulators, tax or law enforcement authorities, or to protect our rights or property;
• as reasonably necessary to prevent fraud, unauthorized transactions or liability;
• in the event we seek to buy or sell any business or assets, we may release information about you to the prospective buyer or seller, and if we, or substantially all of our assets, are acquired by a third party, your personal data will be one of the transferred assets; and/or
• as otherwise required or permitted by law or regulation.

We require third-party service providers and financial institutions to protect the confidentiality of personal data and to use such personal data only for the purposes for which it was disclosed to them. HonTe restricts access to personal data it collects about clients to its employees and agents who have been advised as to the proper handling of such personal data and who need to know that personal data in order to provide products or services to clients.

Security of Personal Data

HonTe will take reasonable steps and use security measures, including physical, electronic, and procedural safeguards, appropriate to the nature of the information and that comply with applicable laws to protect clients’ and users’ personal data against unauthorized access and exfiltration, acquisition, theft, or disclosure.  Given the nature of information security, there is no guarantee that such safeguards will always be successful.

Retention of Personal Data

HonTe will retain your personal data for as long as we require it to perform our contractual rights and obligations or for our legitimate interests, or for such longer period as required by our legal or regulatory obligations.  In general, we will retain your personal data throughout your investment with us.  We will also retain certain of your personal data after you cease to be a client.

Links to External Websites

Our Website may contain links to third-party websites.  Any access to and use of such third-party websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third-party websites.  HonTe is not responsible for the information practices of such third-party websites.

Cookies and Similar Technologies

Cookies are small text files that are stored in your computer’s memory and hard drive or in your mobile device or tablet when you visit certain web pages.  They are used to enable websites to function or to provide information to the owners of a website or other third parties that receive data obtained from that website.  Our Website uses cookies and other tools to collect analytics information about your visit to our Website.  Service providers, including Google Analytics, may provide these tools.  The information does not identify a particular individual visitor or user. For more information on (a) how Google Analytics collects and processes such information, please click here, and (b) how to prevent the use of Google Analytics relating to your use of our Website by downloading and installing a browser plug-in, please click here.  You can change your cookie preferences by changing the setting on your web browser to delete or reject cookies.  If you delete or reject cookies, some websites may not function properly.

Please note that some of our third-party service providers may use cookies and similar technologies to support the operation of our digital offerings.  These entities may be collecting such information in order to provide services to or for us.  You should be aware that these third-party service providers may have different privacy policies and information security practices; as such, we encourage you to read the privacy statements provided by other websites before you provide personal data to them.

Do Not Track

Our Website currently recognizes “Do Not Track” signals.  Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page.  For details, including how to turn on Do Not Track, visit www.donottrack.us.  Please note that third-party websites may not recognize Do Not Track signals.  As previously noted, we encourage you to read the privacy statements provided by third party websites.

Additional Rights and Disclosures Relating to Investors in the Cayman Funds

For the purposes of the DPL, we are a data controller of personal data of individuals who are, or who are associated with, investors in our Cayman Funds (“you” or “your”), and such individuals’ personal data are processed for the purposes set out in this notice.  Under the DPL, HonTe is generally a data controller and our affiliates and/or delegates may be data processors (or, in some circumstances, data controllers in their own right).  “Personal data” as used in this section has the same meaning as provided in the DPL.  If you are a natural person, this Privacy Policy will be relevant to you directly.  If you are a non-natural person investor that provides us with personal data on individuals connected to you for any reason in relation to your investment with us, this Privacy Policy will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Additional Rights of Data Subjects Who Are, or Who Are Associated With, Investors in our Cayman Funds

Under the DPL, investors in our Cayman Funds who are individuals, wherever you are located, have certain rights under the DPL in relation to your personal data.  These include the right, in certain circumstances, to:

• be informed about the purposes for which your personal data are processed;
• request access to your personal data;
• stop direct marketing;
• restrict the processing of your personal data;
• have incomplete or inaccurate personal data corrected;
• ask us to stop processing your personal data;
• be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you);
• require us to delete your personal data in certain circumstances; and
• complain to the Cayman Islands Ombudsman, who may be contacted by email (info@ombudsman.ky), telephone (+1 345-946-6283) or post (PO Box 2252, Grand Cayman KY1-1107, Cayman Islands).

How to Exercise Your Rights under the DPL
To exercise your rights under the DPL, if applicable, you should contact us using the information provided below in the “Contact Information” section and include “DPL Rights Request” as the subject of your communication.

Transfers of Personal Data Outside of the Cayman Islands

HonTe may transfer your personal data to jurisdictions that do not have data protection laws equivalent to the DPL (should the DPL be applicable).  This may be necessary for a number of reasons, including for the performance of our rights and obligations under agreements with you or under an agreement with a third party that is in your interests or in connection with international cooperation arrangements between governmental, regulatory, tax and law enforcement authorities.

Additional Information for California Residents

The CCPA imposes certain obligations on HonTe and grants certain rights to California residents (“California Resident,” “you,” or “your”) with regard to “personal information.”  If you are a California Resident, please review the following information about our privacy practices surrounding how and why we collect, use, disclose, and share your personal information and your potential rights with regard to your personal information under the CCPA.  The rights described herein are subject to exemptions and other limitations under applicable law.

Terms used in this California-specific section have the meaning ascribed to them in the CCPA.  HonTe is a “business.”  “Personal information” as used in this section has the same meaning as in the CCPA.  It does not include deidentified information, aggregate consumer information, or publicly available information, as those terms are defined in the CCPA.

Notice at Collection and Use of Personal Information

Information We Collect

Depending on how you interact with us, we may collect the categories of personal information listed above in the section “Personal Data Collected.”

How We Use Collected Information

We may use your personal information for the business or commercial purpose listed above in the section “Purposes for Collecting, Using, and Processing Personal Data.”

For more information about our privacy practices, please review our Privacy Policy.

Our Collection, Use, Disclosure, and Sharing of Personal Information

What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information

In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information listed above in the section, “Personal Data Collected”.We may have collected personal information from all or some of the categories of sources listed in the section, “Sources of Personal Data.” We may have collected all or a few of the categories of personal information for the business or commercial purposes identified in the section, “Purposes for Collecting, Using, and Processing Personal Data.”

Our Disclosure and Sharing of Personal Information

HonTe does not sell your personal information.  We do not knowingly sell personal information of California Residents under 16 years old.

In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as describe in the below chart:

In addition, in the preceding 12 months, we may have disclosed for a business purpose all of the categories of personal information identified above in the section, “Personal Data Collected”, to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries, or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law.

HonTe may also share your personal information with our service providers, including our client relationship management, human resources, and information technology providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.

California Residents’ Rights under the CCPA

If your personal information is subject to the CCPA, you may have certain rights with regard to such personal information, including the right to:

1. Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
2. Request that HonTe delete any personal information about you that we collected, subject to certain exceptions (“Request to Delete”).
3. Request that HonTe, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”):
   • The categories of personal information we have collected about you.
   • The categories of sources from which we collected the personal information.
   • The business or commercial purpose for collecting or selling the personal information.
   • The categories of third parties with which we share personal information.
   • The specific pieces of personal information we have collected about you.
   • The categories of personal information we have disclosed about you for a business purpose.
4. Not be discriminated against because you exercised any of your rights under the CCPA.
5. Opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not).

The CCPA does not restrict HonTe’s ability to do certain things like comply with other laws or comply with regulatory investigations.  In addition, the CCPA does not apply to certain information like personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations.  HonTe also reserves the right to retain, and not to delete, certain personal information after receipt of a Request to Delete where permitted by the CCPA.

How to Submit a Request under the CCPA

If your personal information is subject to the CCPA, you may submit a Request to Know, as described above, through the following telephone number: 415-801-4250, or on HonTe’s website at www.honteinv.com. You may submit a Request to Delete via email ir@honteinv.com or through the following telephone number: 415-801-4250.

HonTe is required to provide certain information or to delete personal information only in response to verifiable requests made by a California resident or their legally authorized agent.  When you submit a Request to Know or Request to Delete, we may ask that you provide clarifying or identifying information to verify your request.  Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address.  Any information gathered as part of the verification process will be used for verification purposes only.

You are permitted to designate an authorized agent to submit a Request to Know or a Request to Delete on your behalf and have that authorized agent submit the request through the aforementioned methods.  In order to be able to act, authorized agents have to submit written proof that they are authorized to act on your behalf or have a power of attorney.  We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf.  We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

HonTe will deliver responses to verifiable consumer requests, free of charge, either through your online account with us, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election.  HonTe will try to respond to your Requests to Know or to Delete within forty-five (45) days of receipt of the request.  If we require more time, we will try to inform you of our need for an extension.  Even with an extension, we will try to provide a response within ninety (90) days of initial receipt of the request.

Keep in mind that HonTe is not required to provide information in response to Requests to Know more than twice in a 12-month period.  Any response to a Request to Know will only cover the 12-month period preceding the verifiable request.

Notification of Changes

Any changes to this Privacy Policy will be posted to this Website.  Accordingly, please refer back to this Privacy Policy frequently as it may change.  This Privacy Policy was last updated on August 24, 2020.

Contact Information

If you have any questions concerning this privacy policy, please contact us at 415-801-4250 and/or ir@honteinv.com.