Brevet Privacy Policy

Brevet Capital Management, LLC (together with its affiliates, “Brevet”) places a high priority on maintaining the confidentiality and security of your non-public personal information.

This policy (this “Privacy Policy”) sets out how Brevet collects, utilizes, and maintains your non-public personal information, including through this website. This Privacy Policy is intended to comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK Data Protection Act 2018 (“DPA”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27^th April 2016 on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of Such Data (United Kingdom General Data Protection Regulation) (together with the DPA, “UK DPR”), and the California Consumer Privacy Act of 2018 (the “CCPA”) and the California Privacy Rights Act (the “CPRA”, and together with the GDPR, the UK DPR, and the CCPA, the “Data Protection Legislation”).

Your personal information will be processed by Brevet, and by persons engaged by Brevet. To the extent the Data Protection Legislation applies, you have rights, and Brevet has obligations, with respect to your personal information. The purpose of this Privacy Policy is to explain how and why Brevet, and persons engaged by Brevet, will collect, use, store, share, erase, transfer, and otherwise process your personal information. This notice also sets out your rights under the Data Protection Legislation (to the extent applicable), and how you may exercise them.

Please read this notice carefully to understand Brevet’s privacy policies and procedures.

The type of personal information Brevet may collect

By virtue of making an investment with Brevet (including your initial application and ongoing interactions with Brevet and persons engaged by Brevet) or by virtue of your otherwise providing Brevet with personal information on individuals connected with you as an Investor (for example, directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners, or agents), you will provide Brevet with certain personal information within the meaning of the Data Protection Legislation.

Brevet may collect and process the following types of personal information, without limitation:

Categories of Personal Information	Specific Types of Personal Information
Identifiers	Real names, postal addresses, email addresses, passport numbers, social security numbers, and driver’s license numbers or other identification numbers
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual	Real names, signatures, postal addresses, email addresses, telephone numbers, fax numbers, birth dates, passport numbers, social security numbers, driver’s license numbers or other identification numbers, credit history, bank account details, and other financial and tax-related information
Characteristics of protected classifications under California or federal law	Age (40 years or older), national origin, citizenship, marital status, race, color, sex, veteran or military status, sexual orientation, religion or creed, medical condition, physical or mental disability, or genetic information (including familial genetic information)
Commercial information	Records and information related to source of funds, source of wealth, investor qualification, financial sophistication, contributions, withdrawals, distributions, account statements, other account-related information, past transactions entered into, meetings with, and visits to, Brevet, and tax-related information
Internet or other electronic network activity information	IP addresses, browser types and versions, device identifiers, location and time zone settings, network and/or service providers, operating systems and platforms, page response times and download errors, browsing history, search history, and length of visits to certain pages of websites
Professional or employment-related information	Professional relationships and background, employment, and employment history
Sensitive personal information	Social security, driver’s license, state identification card, or passport number and account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account

How Brevet collects this personal information

Brevet collects your personal information from the following sources:

Subscription documents as well as certain other information provided in writing, in person, by telephone, electronically, or by any other means;
Transactions in which you have invested, including account balances, investments, redemptions, management fees, and performance allocations;
Publicly available sources such as the corporate website of the organization you are working for;
Directly from third parties and/or service providers
From interactions with social media and use of other websites that display our advertisements;
By means of cookies (that are placed when you visit this website or opt-in for Brevet’s mailings and/or any other marketing that Brevet sends you); and/or
Other interactions you may have with Brevet (for example, discussions with employees).

Additionally, like many organizations, Brevet may place a “cookie” (a small data file) on the hard drive of your computer when you first connect to this website. First-party cookies are cookies set by the website you are visiting. A website may also use external services that set their own cookies, known as third-party cookies.

Brevet may use first-party cookies to let us know that you have visited this website before, and recognize you so that you can avoid re-entering information each time you visit the website. We may also use first-party cookies to help us analyze the use of this website.

You can set your browser to refuse these types of cookies from this website. However, some portions of the website may not function properly or may function more slowly if you choose to reject cookies. For information on how to limit, delete, or disable cookies for some commonly used browsers, please visit:

Google Chrome: https://support.google.com/chrome/answer/95647
Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471
Internet Explorer: https://support.microsoft.com/en-us/help/260971/description-of-cookies

Some or all of this website may make use of Google Analytics, a web analytics service that uses cookies, including Google Analytics Demographics and Interest Reporting. This website may also make use of Google Analytics for Display Advertising features, including Remarketing, Display Network Impression Reporting, and/or the DoubleClick Campaign Manager integration.

Brevet is required by Google to disclose the following information to you in our Privacy Policy to the extent we use any Google Analytics features on our website:

You may opt-out of Google Analytics for Display Advertising or customize Google Display Network ads by using the Google Ads Settings page, which can be found at https://adssettings.google.com.
If this website makes use of the Google Analytics for Display Advertising Remarketing feature, Brevet will use such Remarketing feature to advertise online and third-party vendors, including Google, which may show Brevet ads on websites across the Internet.
Brevet and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to (a) inform, optimize, and serve ads based on a user’s past visits to this website and/or (b) report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to this website.
Data from Google Analytics Demographics and Interest Reporting may be utilized by Brevet to help recognize and understand user preferences, to make improvements to this website, to choose content and advertising to display to you, and for other business purposes that will allow us to better serve you.
You may prevent your data from being collected and used by Google Analytics by opting-out through the use of the Google Analytics Opt-out Browser Add-on, which can be found at https://tools.google.com/dlpage/gaoptout?hl=en.

Brevet may use third-party advertising companies to serve advertisements on other websites you may visit. To accomplish this, these companies may employ anonymous cookies and web beacons (also known as Internet tags, pixel tags, and clear GIFs) that allow this website to collect web log information. A web beacon is a graphic on a web page or in an email message designed to track pages viewed or messages opened. Web log information would be gathered when you visit our website. The web server automatically recognizes some non-personal information, such as the date and time you visited our website, the pages you visited, the website you came from, the type of browser you are using, the type of operating system you are using, and the domain name and address of your ISP. Brevet may also include web beacons in promotional email messages in order to determine whether messages have been opened. You have the right to opt-out of receiving such promotional emails and beacons at any time by clicking on the “unsubscribe” link in every email Brevet sends you or by contacting us at [email protected].

How Brevet legally collects this personal information

Brevet is able to legally collect and use your personal information because:

You have consented to its doing so;
Collecting and using your personal information is necessary to fulfill legitimate business interests, which may include (i) fulfilling contractual obligations or otherwise performing services for you or (ii) investigating, defending against, or prosecuting any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum or otherwise protecting your legal rights; and/or
It is necessary to comply with any applicable regulatory, judicial, or other legal obligation.

Who Brevet shares your personal information with

Brevet may share your personal information in accordance with the applicable laws with:

Any and all of the Brevet entities;
Non-affiliated service providers, such as attorneys, auditors, accountants, tax advisers, administrators, custodians, depositaries, distribution managers, brokerage firms, event organizers, or other agents, advisers, or service providers engaged by Brevet;
Other third parties and/or service providers we use to help run our business, such as marketing partners and technology providers; and
Regulatory, prosecuting, and other governmental agencies or departments and parties to litigation (whether pending or threatened) in any country or territory, to comply with our legal and regulatory obligations.

As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as administration services, tax compliance services, reporting, preparing account statements and other information, organizing events, conducting research on client satisfaction, and gathering shareholder proxies. These companies may have access to your personal information but are permitted to use the information solely to provide the specific service or as otherwise permitted by law.

Brevet may share your personal information with its affiliates that are subject to privacy policies that protect your information from disclosure to third parties in a manner similar to this Privacy Policy. In the event that Brevet (or its parent corporation) goes through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of its assets, our users’ personal information will, in most instances, be part of the assets transferred. Brevet may in its discretion notify you of any such business transition via email, to the extent you have elected to provide Brevet such information and elected to receive such communications, and/or notice on this website.

To the extent that Brevet engages a third party to sub-process any of your personal information covered by the applicable laws for one of the purposes listed in this Privacy Policy, Brevet will enter into a contract with that third party that is compliant with its obligations under the applicable laws.

Third-party offers and advertising

Brevet may allow other companies, such as its marketing partners and affiliated companies, to offer their products and services to you, to register you on their websites, or to communicate with you about their products and services at a future date, through Brevet’s website or by email. Whether or not you decide to participate in such an offer is up to you.

Brevet may use your personal information to provide you with advertisements that are targeted to your specific needs and interests. Such advertisements link directly to third-party websites. Brevet has no control over the content or privacy policies of any such websites, and therefore Brevet encourages you to review such content and policies prior to submitting any personal information to them.

Brevet may allow certain companies to display advertisements on this website. Some of these ad networks may place a persistent cookie on your computer. Doing this allows such advertisers to recognize your computer each time it sends you an online advertisement. In this way, ad networks may compile information about where you, or others who are using your computer, saw its advertisements and determine which ads are clicked on. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you. Brevet does not have access to or control over the cookies that may be placed by these parties on your computer and has no control over these parties’ privacy policies or information-collection practices.

How Brevet uses your personal information

Brevet, and/or any service providers or processors that Brevet engages (including any of their affiliates, agents, employees, delegates, or sub-contractors), may process your personal information for the following purposes, as applicable:

To facilitate your investment and the management and administration thereof on an ongoing basis as necessary to fulfill contractual and regulatory obligations related thereto;
To operate and improve this website, such as resolving technical issues, supporting security, analyzing user trends, detecting fraud or other types of abuse, and gathering broad demographic information for aggregate use;
In order to carry out anti-money laundering checks and related actions that Brevet considers appropriate or necessary to fulfill any of its legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with Brevet’s anti-money laundering policies and procedures;
To comply with their legal obligations and, in particular, to report tax-related information to tax authorities;
To disclose information to other third parties and/or service providers of Brevet and/or its service providers, regulatory authorities, and technology providers in order to comply with any legal obligation imposed on Brevet and/or its service providers or in order to pursue the legitimate interests of Brevet;
To monitor and record electronic communications and, if applicable, calls for any of the purposes specified herein; and/or
To otherwise pursue the legitimate interests of Brevet and/or third parties and service providers engaged by Brevet relating to your investment or potential investment.

Personal information that Brevet discloses or sells for a business purpose

In the preceding 12 months, Brevet has disclosed to one or more third parties and/or service providers the following categories of personal information for a business purpose:

Identifiers;
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual;
Characteristics of protected classifications under California or federal law;
Commercial information;
Internet or other electronic network activity information;
Professional or employment-related information; and
Sensitive personal information.

In the preceding 12 months, Brevet has not sold any personal information to a third party.

Cross-border transfers of personal information

Brevet has service providers that are located in jurisdictions outside of the United Kingdom (“UK”), the European Union (“EU”) and the European Economic Area (“EEA”) whose personnel will have access to your personal information. Transfers to these service providers are necessary to facilitate your investment with Brevet.

To the extent that your personal information is processed by third parties in jurisdictions outside the UK, EU, and/or EEA, and to the extent that you are a citizen or resident of the UK, EU or EEA, Brevet will ensure appropriate safeguards are in place as required by applicable law to adequately protect your personal information. If such jurisdictions do not afford an adequate level of protection for your personal information as determined under the Data Protection Legislation, then Brevet’s agreements with its service providers will incorporate clauses the same or substantially similar to the standard contractual clauses (as well as other relevant provisions contained in the Data Protection Legislation) and obligations no less protective than those contained in this Privacy Policy.

Retention of your information

Brevet and its service providers will retain your personal information for the purposes described in this Privacy Policy as long as required for the purposes described above. In particular, and without limiting the foregoing, Brevet and its service providers have legal obligations imposed on them under applicable legal systems that require them to retain your personal information for certain minimum time periods.

Automated decision-making

Brevet will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your personal information, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the applicable requirements under the Data Protection Legislation.

Browser “do not track” signals

Brevet does not honor “Do Not Track” (also known as “DNT”) signals or similar mechanisms transmitted by your web browsers. More information about browser tracking signals and Do Not Track signals can be found at http://allaboutdnt.org.

Protecting children

Brevet takes special care to protect the safety of children in accordance to the Children’s Online Privacy Protection Act of 1998. While this website is a general audience website, Brevet does not permit children under the age of 13 to register or purchase any products or services. Brevet also does not collect or maintain personal information about children under the age of 13.

Rights under the Data Protection Legislation

To the extent the Data Protection Legislation applies, individuals have certain specific rights provided thereunder. For personal information that Brevet collects about you, Brevet hereby notifies you that you have the following rights:

GDPR & UK DPR Rights

Delete Personal Data:You can ask Brevet to erase or delete all or some of your personal data in some limited circumstances.
Right to Rectification:You also have the right to ask Brevet to change, update, or fix your personal data in certain cases, particularly if it is inaccurate.
Object to, or Limit or Restrict, Use of Personal Data:You can ask Brevet to stop using all or some of your personal data (g., if Brevet has no legal right to keep using it) or to limit Brevet’s use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your Data:You can ask Brevet for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
Right to be Informed: You have the right to be informed about the purposes for which your personal data is processed and to be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you).

CCPA Rights

The following information is provided for California residents pursuant to the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (the “CPRA”). This information supplements this Privacy Policy for individuals who have rights pursuant to California law and shall not be construed as creating any right or duty that is not otherwise provided by law.

Brevet may collect the categories of personal information described in the section of this Privacy Policy titled “The Type of Personal Information Brevet May Collect”.

We may collect such categories of personal information directly from you, such as when you complete forms; indirectly from you, such as observing your actions on this site; and from publicly available sources.

In the preceding 12 months, (i) we have not sold personal information about California residents and (ii) we have collected, used, and disclosed for business purposes the categories of personal information listed in the section of this Privacy Policy titled “Personal Information That Brevet Discloses or Sells for a Business Purpose”.

California residents have the following rights, subject to certain exceptions as set forth in the CCPA:

Disclosure of Personal Information We Collect About You. You have the right to know:

The categories of personal information we have collected about you, including sensitive personal information;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting, selling, or sharing personal information;
The categories of third parties with whom we share personal information, if any; and
The specific pieces of personal information we have collected about you.

Please note that we are not required to:

Retain any personal information about you if, in the ordinary course of business, that information about you is not retained;
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
Provide the personal information to you more than twice in a twelve- (12) month period.

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose. In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and
The categories of personal information about you that we disclosed for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.

Right to Opt-Out of the Sale or Sharing of Personal Information. You have the right to opt-out of the sale or sharing of your personal information.
Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services.
Right to Delete Personal Data: On receipt of a verifiable request from you, subject to certain exceptions set out below, we will:

Delete your personal information from our records;
Direct any service providers to delete your personal information from their records; and
Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.

Please note that we are not required to delete your personal information if it is necessary to:

Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
Debug to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act;
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
Enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us;
Comply with an existing legal obligation; or
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Correction. You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection from Discrimination: You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA and CPRA. This right includes, but is not limited to, protection from discrimination by:

Denying goods or services to you;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing a different level or quality of goods or services to you; or
Suggesting that you will receive a different price or rate for goods or services or a different quality level of goods or services.

Notwithstanding the foregoing, Brevet may charge different prices or rates, or provide a different level or quality of services, if such difference is reasonably related to the value provided to Brevet by your data.

How to Exercise Your Rights

To make any requests as listed above (to the extent the relevant Data Protection Legislation applies), please:

Complete a data subject request form, which is available at the bottom of this page;
Call us, toll-free, at (855) 650-0317; or
Email us at [email protected].

If you choose to contact us directly by email or phone, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or matter reference number);
Proof of your identity and address (e.g., a copy of your driver’s license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification. We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Brevet will disclose and deliver the required information free of charge within forty-five (45) days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional forty-five (45) days when reasonable necessary and with prior notice.

Under California law, if you are a resident of California, you are entitled once per year to request and obtain certain information regarding Brevet’s disclosure, if any, of your personal information to third parties for their direct marketing purposes during the immediately prior calendar year. To make such a request, please send an email to [email protected] with your full name, email address, and postal address in your message. In response to your request, Brevet will provide you with a notice describing the cost-free means to opt-out of our sharing your personal information with third parties with whom Brevet does not share the same brand name, if the third party will use it for their direct marketing purposes.

Withdrawal of your consent

You can tell Brevet to stop collecting, using, and retaining your personal information at any time by emailing [email protected]. You should note that notwithstanding your withdrawal of consent, Brevet may be legally required to retain some or all of your personal information. Where Brevet or one of its service providers requires your personal information to comply with anti-money laundering or other legal requirements, failure to provide this information will mean that you will be unable to invest with Brevet and/or Brevet may be required to terminate its relationship with you.

Protection of your information

Brevet maintains appropriate administrative, technical, and physical security measures to protect your information and data against loss, misuse, and alteration. Brevet uses standard industry practices to help prevent unauthorized use of, access to, or alteration of visitor and user information and hosted data. In addition, Brevet restricts access to personal and account information to those employees who need to know that information in the course of their job responsibilities. Brevet has no regulatory obligations under the GDPR or UK DPR to appoint a data protection officer (DPO) and has no DPO currently appointed.

At the same time, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while Brevet strives to protect your personal information to the best of its ability, Brevet cannot guarantee or warrant the security of information you transmit to our website or over the Internet.

Changes to this Privacy Policy

This Privacy Policy was last updated in June 2023. It provides a general overview of the ways in which Brevet uses your personal information and important information on electronic communication. This Privacy Policy may be changed at any time to reflect changes in Brevet’s practices concerning the collection and use of personal information or where required to comply with applicable law. Any revised Privacy Policy will be effective immediately upon delivery to you and/or posting to Brevet’s website. Brevet recommends checking this section of the website frequently to view the latest updates.

Further information

The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive. You may have additional rights under other foreign or domestic privacy laws in addition to those that are described above. If you have any questions about this Privacy Policy, please email [email protected].

Making a complaint

If you would like to make a complaint about the way Brevet has collected, used, or retained your personal information, please contact [email protected].

If you are a citizen of the EU or the EEA, then you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal information relating to you carried out by Brevet or its service providers infringes the GDPR. Individuals to whom the UK DPR applies have a right to lodge a complaint with the UK’s Information Commissioner’s Office (ICO).

Former customers and investors

This Privacy Policy also applies to former customers and investors in the UK, the EU, and the EEA.

Personal Information Requests