Privacy Policy

Updated March 2023

Introduction

This notice sets forth the privacy policy and practices of Taconic Capital Advisors L.P. and its affiliates including the Cayman Islands investment funds they manage (“Taconic”, “we”, “us” and “our”) with respect to the personal data we receive. This includes personal data provided by or relating to (i) current, former and prospective investors (each, an “Investor”) in the funds for which Taconic serves as investment adviser or general partner or in some similar capacity; and (ii) any other individual whose personal data Taconic collects or acquires. If you are a corporate Investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal data on individuals connected to you for any reason in relation to your investment with us, this may be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content. You should review this Privacy Notice, our Terms and Conditions, and our Cookie Policy carefully because by using our products, services and/or our website (www.taconiccap.com) you agree to the terms of this Privacy Policy, the Terms and Conditions, and the Cookie Policy. You should also review the fund administrator’s Privacy Notice, where applicable.

The Types of Personal DataThat We Collect About You

For purposes of this Notice, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Below we describe the categories of personal data we collect. The categories of personal data we collect from you may vary according to your relationship with us.

Categories of Personal Data

Identifiers: name, email address, address, phone number, facsimile number, IP address or similar identifier, account number and password social security number, driver’s license, state identification card, passport information.

Commercial and financial information: records of personal property, products or services purchased, obtained, or considered, information on investments, assets, net worth, tax status, tax identification number, holdings, account balances, transaction history, bank account details and wire transfer instructions

Internet or other electronic activity information: information regarding an individual’s interaction with Taconic’s website, device and browser type, browsing and search history on our website.

Professional or employment-related information: Name of employer and position

Sensitive personal data: social security number, driver’s license, state identification card, or passport information

We collected the same categories of personal data in the 12 months prior to the date of this Privacy Policy.

The Purposes for Which We Collected Personal Data

Taconic may use personal data in the course of business, including for the tasks and purposes identified below, as applicable to you:

Providing Investors certain services, including: Onboarding new Investors and opening accounts, servicing existing accounts, including processing subscriptions, redemptions and transfers, responding to Investor requests and concerns

Carrying out our obligations arising under our contract with you and to enforce the same

For offering, providing, and marketing our products and services, connecting individuals with other products and services, and other legitimate business and commercial purposes

Conducting statistical research or analysis
Verifying or authenticating your identity, including for access to our systems

Protecting our facilities, systems and personnel; preventing fraud, abuse and crime; responding to emergencies

Managing and fulfilling legal and regulatory requirements; responding to valid legal requests; and to establish, assert and protect our legal interest

For other purposes in connection with fulfilling our legitimate commercial interests and our general business, administrative, analysis and statistical purposes.

No Sale of Personal Data or Sharing of Personal Data for Cross-Context Behavioral Advertising

We do not (a) sell personal data or (b) share personal data for purposes of cross-context behavioral advertising.

Data Retention Information

We retain personal data we collect for the period required to provide our services to you and the entities you represent and to comply with our legal obligations, including data reporting requirements and to defend against lawsuits or potential claims.

The Categories of Sources from Which We Collect Personal Data

From You When You Provide Information to Us: You may provide personal data to us.

From Other Sources:

We may obtain information about you from the following categories of third parties: investment fund managers, advisors or intermediaries, the administrator of a fund, public websites, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies and other public sources.

We may obtain information from your agents and advisers we use to verify your identity or to confirm your eligibility to use our services, in accordance with our legal obligations.

We may collect personal data about you through our use of “cookies” (small text files stored on your computer’s hard drive by websites that you visit) and similar technologies that we use to enhance the functionality of our website by, for example, keep you logged into the website when you move from page to page). To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org, which will also explain how you can delete cookies that are already stored on your device. However, without certain cookies, you may not have access to many features that may make your browsing of our website smoother, and some of our services may not function properly.

We may also collect certain technical information from your computer, for example, the IP address used to connect your computer to the Internet and other computer and connection information.

Disclosure of Personal Data For Business Purposes in the Past 12 Months

The following chart describes the categories of personal data that, in the 12 months prior to the date of this Policy, we disclosed to third parties for a business purpose, and the categories of those third parties and the purpose for disclosure:

Categories of Consumers’ Personal Data	Categories of Third Parties With Which We Shared Personal Data for Business Purposes Identified
Personal identifiers: name, email address, address, phone number, facsimile number, IP address or similar identifier, account number and password, social security number, driver’s license, state identification card, passport information	Service providers that provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; provide website hosting; and provide legal, tax and accounting services. Transfer agents, fund administrators, custodians, broker-dealers, counterparties, consultants, professional advisors, that assist in facilitating transactions.
Financial information: records of personal property, products or services purchased, obtained, or considered, information on investments, assets, net worth, tax status, tax identification number, holdings, account balances, transaction history, bank account details and wire transfer instructions	Service providers that that provide customer relationship management (CRM) services; legal, tax and accounting services. Transfer agents, fund administrators, custodians, broker-dealers, counterparties, consultants, professional advisors, that assist in facilitating transactions.
Internet or other electronic network activity information: Device and browser type, browsing and search history on our website, and information regarding interaction with our website.	Service providers that provide data security services and cloud-based data storage, host our Site and assist with other IT-related functions, and provide analytics information.
Inferences from personal data we collect	Service providers that provide data security services and cloud-based data storage, host our website and assist with other IT-related functions and provide analytics information

Categories of sensitive personal data are identified with an asterisk (*).

We may also share your personal data as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share personal data with third parties to help detect and protect against fraud or data security vulnerabilities. We may transfer personal data to a third party in the event of an actual or contemplated sale, merger, reorganization of our entity or other restructuring.

No Use of Sensitive Personal Data to Infer Characteristics

We do not use sensitive personal data to infer characteristics about individuals.

Transfer of Personal Data Outside the UK or EEA of Individuals Located in the EEA

For those individuals who are located in the United Kingdom (“UK”) or the European Economic Area (“EEA”), Taconic may disclose such individuals’ personal data to recipients (including affiliates) located in countries outside of the UK/EEA, including in the U.S., which may not have data privacy laws equivalent to those in the UK/EEA. In such a case, Taconic will take all necessary steps to ensure the safety of your personal data in accordance with applicable data protection laws. For Investors, by signing the relevant Taconic Subscription Booklet, each such Investor consents to the transfer of their personal data to Taconic and the other recipients described in this notice that may be located in countries outside of the UK/EEA.

Cayman Islands Data Protection Measures

Any transfer of personal data by us or our duly authorized affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the Data Protection Law, 2017 of the Cayman Islands (“DPL”).

We and our duly authorized affiliates and/or delegates shall apply appropriate technical and organizational information security measures designed to protect against unauthorized or unlawful processing of personal data, and against accidental loss or destruction of, or damage to, personal data.

We shall notify you of any personal data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant personal data relates.

Rights of Individuals Located in the EEA and Investors in Cayman Islands Investment Funds

Under applicable EU data protection laws and regulations, individuals who are located in the EEA may have a right to: (i) request access to and rectification or erasure of your personal data; (ii) obtain restriction of processing or to object to processing of your personal data; (iii) withdraw consent; (iv) request data portability; and (v) request a copy of applicable standard contractual agreements entered into by us. If you wish to exercise any of these rights you should contact Taconic’s EU Representative, TCA Opportunity Investment S.a.r.l, at luxoffice@taconiccap.com. You also have the right to lodge a complaint about the processing of your personal data with your local data protection authority. Investors in Cayman Islands investment funds have broadly analogous rights under the DPL. Investors in Cayman Islands investment funds also have the right to lodge a complaint under the DPL with the Office of the Ombudsman in the Cayman Islands.

Rights of California Residents

The California Consumer Privacy Act of 2018 (the “CCPA”), as amended, grants residents of California certain rights with respect to their personal data, including, as described below, the right to access, delete or correct their personal data. These rights are subject to certain limitations, however, such as that they do not apply to data collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach Bliley Act (Public Law 106-102) and its implementing regulations. Where exceptions to the CCPA apply to a request you submit, we will provide you with an explanation.

Right to know or access personal data we collect and share about you. You can submit a request for the following types of personal data that we have collected on or after January 1, 2022:

Specific pieces of personal data we have collected about you;
Description of the categories of personal data we have collected about you;
Description of the categories of sources from which such personal data was collected;
Description of the categories of personal data that the business sold or disclosed for a business purpose about the consumer;
Description of the categories of third parties to whom the personal data was sold or disclosed for a business purpose; and
Description of the business or commercial purpose for collecting or selling your personal data.

Right to request the deletion of personal data we have collected from you. Upon request, we will delete the personal data we have collected from you, except for situations where specific data is necessary for us to: provide you with a product or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law.

The CCPA also permits us to retain specific data for our exclusively internal use, but only in ways that are compatible with the context in which you provided the data to us or that are reasonably aligned with your expectations based on your relationship with us.

Right to request correction of inaccurate personal data. If we are holding personal data in relation to you that is inaccurate, out of date, incomplete, irrelevant or misleading and you request to correct such information, we will take reasonable action to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading.

Right to Be Free From Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

How can you make a request to exercise your rights? To exercise your right to know, access, delete or correct your personal data, you may call us toll-free at 833-822-6642 or 212-209-3100 or you may email legal&compliance@taconiccap.com.

How we will handle a request to exercise your rights. For requests to know, access, delete or correct your personal data, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although it may take longer to process your request under certain circumstances. If we expect your request is going to take longer than 45 days, we will notify you.

When you make a request to access or delete your personal data, we will take steps to verify your identity. These steps may include asking you for personal data, such as your name, address, or other data we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.

You may also designate an authorized agent to submit requests on your behalf. If you do so, you will be required to verify your identity by providing us with certain personal data as described above. Additionally, we will also require that you provide the agent with written permission to act on your behalf, and we will deny the request if the agent is unable to submit proof to us that you have authorized them to act on your behalf.

Policies and Practices Regarding the Confidentiality and Security of Such Personal Data

Taconic has implemented reasonable security policies and procedures designed to safeguard personal data against loss or theft, and against unauthorized access, disclosure, copying, use or modification. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

Minors’ Information

This site and our products and services are not directed to minors under the age of 18. We do not sell personal data or share personal data for purposes of cross-context behavioral advertising, including the personal data of minors under 16 years of age.

Do-Not-Track Requests

“Do Not Track” signals are options available on your browser to tell operators of websites that you do not wish to have your online activity tracked.

We do not respond to the “DNT” signal at this time. We do not recognize universal opt-out signals because we do not sell personal data or share such data for purposes of cross-context behavioral advertising.

Third-party links

Please note that our website may contain links to third-party websites, including the fund administrator’s website. Please be aware that we are not responsible for the privacy practices of other websites. Our website offers no guarantees on the safety or suitability of websites featured on third-party links, and any user who chooses to follow such links does so at his or her own risk.

Changes to This Privacy Notice

We may revise this Notice at our discretion. We will post any changes to our website and update the “Last Updated” date, so be sure to check back periodically. Your continued use of our website and services after changes have been posted will constitute your acceptance of this Privacy Notice and any changes.

Accessibility

We are committed to ensuring that our communications are accessible to people with disabilities and welcome accessibility-related requests or reports of barriers in respect thereof. Please direct such requests or reports to the address or number below.

Getting In Touch

If you have any questions or comments about this notice, the ways in which we collect and use your personal data, your choices and rights regarding such use, wish to exercise your privacy rights under California law, or would like to request changes to any of your personal data, please do not hesitate to contact us at:

Phone: 212-209-3100 or toll free at 833-822-6642
Email: legal&compliance@taconiccap.com
Website: www.taconiccap.com
Attention: Flaurine St Louis (Chief Compliance Officer)

If you wish to exercise your privacy rights under European law, please do not hesitate to contact the European Representative at:

TCA Opportunity Investments S.à r.l.
26 Boulevard Royal, L-2449 Luxembourg
luxoffice@taconiccap.com

If you wish to exercise your privacy rights under UK law, please do not hesitate to contact us at:

Phone: +442075182512
Email: legal&compliance@taconiccap.com
Website: www.taconiccap.com
Attention: William Cannon (Compliance Officer)

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