The Types of Personal Information We May Collect About You and How We May Use and Share the Information
When you visit and browse this website (the “Site”), or otherwise interact with King Street, we may collect Personal Information about you. “Personal Information” 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. Such information might be provided in a subscription agreement or in other documents (as part of the subscription process or at other times), face-to-face, by telephone, by email or otherwise.
Below we categorize the types of such information we may collect or may have collected in the last 12 months and provide the sources from which that information was collected, why we collected the information, and with whom we may share the information. We anticipate continuing to collect the information discussed herein from the same sources, as well as continuing to use and share it as described below.
We do not and will not sell Personal Information to third parties.
Categories of Personal Information We May Collect
Identifiers, such as name, email address, address, telephone number, facsimile number, Internet protocol (“IP”) address, social security number or similar identification number, date of birth, gender, nationality or documentary information (such as copies of drivers’ license, passport, utility bills or other photograph identification).
Commercial and financial information, such as records of personal property, King Street products or services of interest to you, nature of your organization, information on investments including size of assets under management and investment style, assets, net worth, tax status, other holdings, account balances, transaction history, bank account details, wire transfer instructions.
Internet or other electronic activity information, including information regarding an individual’s interaction with our website, emails sent and received to King Street.
Professional or employment-related information.
User Profile Information, which may include information relating to your (or an investor’s) investment in a fund and emails (and related data).
Purposes of Collection
We have collected this Personal Information for the following purposes:
For the management and administration of our business, including assessing and processing subscriptions for shares or interests in a fund and other related dealings, including performing know-your-client procedures, issuing and redeeming shares or interests, receiving payments from and making payments to the investor, calculating net asset value and overseeing these processes.
For offering, providing, and marketing our products and services, connecting individuals with other products and services, and other legitimate business and commercial purposes.
For ongoing review and improvement of the information provided on the Site to ensure it meets the needs of users, and to conduct analysis required to detect malicious data and to prevent any potential disruptions or cyber attacks.
To personalize your visit to the Site and to assist you while you use the Site.
To allow you to use and access King Street’s services and to understand feedback relating to King Street’s services as a user of the Site or as a business contact.
To communicate with you as a user of the Site or as a business contact in order to provide you with services or information about King Street and King Street’s products.
Where you apply for a position with us, to review and process your application.
For human resource functions, including for recruiting and for performance and talent/practice management.
For fraud prevention and detection and to comply with and in order to assess compliance with applicable laws, rules and internal policies and procedures including in respect of your personal data that which is contained in recordings of communications to or from our systems (for example, our telephones, mobile devices, computers and email accounts).
The Sources from Which We Collected Personal Information
We have obtained this Personal Information from the following sources:
From You When You Provide Information to Us: In order to receive our services, you may have to provide information to us that we may collect and store in a way that allows us to relate it to you personally, including but not limited to your name, e-mail address, address, phone number, facsimile number and other information. You may provide such personal data by various means, including by responding to questions on this Site or contacting us directly via e-mail.
When We Collect or Generate Information About You: This includes, without limitation, files that we may produce as a record of our relationship with you and personal data that you provide during telephone and email communications with us which we may monitor and record to comply with our legal and regulatory requirements.
From Other Sources:
We may obtain information from affiliates.
We may obtain information from third parties or other sources, such as the administrator of a fund (the “Administrator”), placement agents, 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 and information received from the investor’s advisers or from intermediaries. This might include information obtained for the purpose of a fund’s know-your-client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-person checks, sanctions checks, among other things).
Categories of Entities with Which Personal Information Is Shared
Over the last 12 months, we have shared each of the Personal Information categories listed above with other entities and affiliates for business or commercial purposes, and we will continue to do so. We typically do not share Personal Information with entities other than as described below.
Our affiliates for the management and administration of our business, including for the subscription of shares or interests in a fund or other related dealings.
The Administrator, professional advisers such as law firms and accountancy firms, and other service providers of a fund, the Administrator or King Street, including technology service providers, prime brokers, custodians, executing brokers and other counterparties. These persons may be permitted to further disclose the personal data to other parties.
Contractors and suppliers in connection with the processing of personal data for the purposes described in this Policy.
If we, an affiliate, or other entity noted in this Policy is required to do so in order to comply with any legal or regulatory obligation, establish, exercise or defend our legal rights, or to protect the rights, property, or safety of others.
With any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed our successor or transferee.
We Do Not Knowingly Collect the Personal Information of Minors
The Site is not directed to minors under the age of 18, nor do we sell information about minors. If we learn that we have erroneously collected personal information of a child under 18, we will take steps to delete such information from our files as soon as possible.
Your Rights in Relation to the Personal Information We Hold About You
Certain state laws may grant natural persons certain rights with respect to their Personal Information. We thus extend certain consumers these rights, including the rights, described below, to access or delete their Personal Information, although these rights may not apply to Personal Information about employees, applicants, and contractors; Personal Information processed exclusively in the business-to-business context (e.g., information about an individual acting in his or her capacity as a representative of an entity); or information covered by the U.S. Gramm-Leach-Bliley Act of 1999, which we cover in a separate notice. If we will not be fulfilling a rights request you submit, because, for example, relevant exceptions apply, we will provide you with an explanation.
Right to Request Disclosure of Information We Collect and Share About You
You can submit a request to us for the following Personal Information we have collected:
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 purposes for which we collected the Personal Information.
The categories of third parties with which we shared the Personal Information.
The specific pieces of Personal Information we collected.
You can also submit a request to us for the categories of Personal Information that we have disclosed for a business purpose.
Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.
Right to Request the Deletion of Personal Information We Have Collected From You
Upon request, we will delete the Personal Information we have collected about you, except for situations where specific information 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. We may also retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.
Our Approach to Processing Requests
If you would like to make a request to access or delete your personal information, you may email us at InvestorReports@kingstreet.com. We will acknowledge receipt of your request within 10 days of receipt of your request and aim to provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
When you make a request to access or delete your personal information, we will take steps to verify your identity. These steps may include asking you for personal information, such as your name, address, or other information 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.
We are committed to honoring your rights. If you exercise any of the rights explained in this Policy, we will continue to treat you fairly.
We aim to protect Personal Information by implementing and maintaining reasonable security, such as by using reasonable organizational, technological and physical safeguards appropriate to the sensitivity of the Personal Information we hold. We take measures, which are at least as strict as the law requires, to safeguard your Personal Information, but we cannot guarantee its absolute security.
Retention of Personal Information
How long we hold your personal data for will vary. The retention period will be determined by the following criteria:
the purpose for which we are using your personal data – we will need to keep the data for as long as is necessary for that purpose; and
legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.
Please note that the Site may contain links to third-party websites. Please be aware that we are not responsible for the privacy practices of other websites. This Site 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.
“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. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
If you have any questions, comments or concerns about our privacy practices, or if you would like to request changes to any of your Personal Information, please contact us at: InvestorReports@kingstreet.com.
Where we handle personal information that is protected by the EU General Data Protection Regulation (mostly where your personal data is being handled by King Street entities based in the EU), you can find further details of how King Street may use that information, as well as individuals’ rights in relation to that information, here.