- 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 additional disclosures, our Notice at Collection, and 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
- 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.
- Sensitive personal information under the CCPA such as your passport number, driver’s license, Social Security Number state identification card, account log-in, or financial account, in combination with any required security or access code, password, or credentials allowing access to an account.
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 various business or commercial purposes, including:
- 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,” antimoney 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.
Please note that for purposes of this section (“Sharing Personal Data”) “sharing” does not mean “sharing” as defined under the CCPA. For additional disclosures and information on our CCPA practices, please review “Additional Information for California Residents,” below.
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
Cookies and Similar Technologies
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 http://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
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 (firstname.lastname@example.org), 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 and disclose 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.”
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.”
Purpose for Collection and Use of Information
We may collect and use your personal information for the purposes listed above in the section
“Purposes for Collecting, Using, and Processing Personal Data.”
Sale or Sharing of Personal Information
We do not sell or share your personal information (as such terms are defined under the CCPA).
How Long We Keep Information
We retain your personal information as described above in the section “Retention of Personal Data” above.
Our Collection, Use, and Disclosure, of Personal Information and Sensitive 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 collect personal information from all or some of the categories of sources listed in the section, “Sources of Personal Data.” We may collect 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 of Personal Information
HonTe does not sell or share your personal information (as those terms are defined under the CCPA). We do not knowingly sell or share 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:
|Category of Personal Information||Category of Third Party|
|Identifiers (for example, your name, address, DOB, SSN, driver’s license, passport number, and online identifiers)||
|Additional information subject to Cal. Civ. Code § 1798.80(e) (for example, a signature, state identification card number, financial information, or bank account information)||
|Characteristics of protected classifications under certain federal or state laws (for example, gender, age, national origin, citizenship, or marital status)||
|Commercial Information (for example, records of products or services purchased, obtained, or considered or purchasing histories or tendencies, including funds in which you are invested, investments considered, or sources of wealth)||
In addition, in the preceding 12 months, we may have disclosed 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. We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in “Purposes for Collecting, Using, and Processing Personal Data.”
HonTe may also disclose or make available 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 peritted by the CCPA.
Use and Disclosure of Sensitive Personal Information
As noted above in “Personal Data Collected” under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.
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) Correct inaccurate personal information (“Request to Correct”).
(4) 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 disclose personal information.
- The specific pieces of personal information we have collected about you.
(5) Not be discriminated against because you exercised any of your rights under the CCPA.
(6) 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).
(7) Opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not).
(8) Limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit).
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 GrammLeach-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 Requests to Know, Requests to Correct and Requests to Delete (“Consumer Rights Request”) through the following methods: 415-801-4250, or on HonTe’s website at www.honteinv.com.
HonTe is only required to respond to verifiable Consumer Rights Requests made by a California resident or their legally authorized agent. When you submit a Consumer Rights Request to, 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 Consumer Rights Request 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
One Market Street
Steuart Tower, Suite 2600
San Francisco, CA 94105