WHAT DOES INDUS CAPITAL PARTNERS, LLC DO WITH YOUR PERSONAL INFORMATION?
Financial companies choose how they share your personal information. Federal law gives our clients the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.
We do not disclose nonpublic personal information about our clients or former clients to third parties other than as described below.
Personal information we collect. We collect personal information about you in connection with our providing advisory services to you. This information can include your:
• Social Security number;
• Assets;
• Account balances;
• Transaction history;
• Income; and
• Wire transfer instructions.
How we collect this information. We collect this information from you through various means. For example when you give us your contact information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates or other non-affiliated companies (our affiliates are companies related to us by common ownership or control and can include both financial and nonfinancial companies; while non-affiliates are companies not related to us by common ownership or control and can include both financial and nonfinancial companies).
How we use this information. All financial companies need to share customers’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example:
• To provide advisory services to you.
• To open an account for you.
• To process a transaction for your account.
• To market products and services to you.
• To respond to court orders and legal investigations.
Disclosure to others. We may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker or fund administrator. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between nonaffiliated financial companies that together market financial products or services to you, such as placement agents). We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information to carry out the purposes for which we disclose the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with nonaffiliates for them to market to you).
How we protect your personal information. To protect your personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include computer safeguards and secured files and buildings.
ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS
If you are a California resident, the California Consumer Protection Act (the “CCPA”) requires that we provide you with additional information regarding how we collect, use and share your Personal Information (as defined in the CCPA).
Categories of Information We Collect About You. We may collect and use the following 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: Identifiers (such as your name, address or social security number); Personal information categories listed in the California Customer Records Statute (such as your signature, physical characteristics or description or employment history); characteristics of protected classification under California or federal law (such as age, gender or citizenship); commercial information (such as records of personal property or purchasing or consuming histories); biometric information (such as fingerprints, retina scans or keystrokes); internet or other electronic network activity information (such as browsing history, search history or information on your interaction with a website); geolocation data (such as your physical location or movements); sensory data (such as audio, electronic or similar information); professional or employment-related information (such as current or past job history); non-public education information (such as grades, transcripts or student disciplinary records); inferences drawn from any of the foregoing to create a profile about a consumer.
How Your Personal Information is Collected. We may collect this information from you directly in person, by telephone, text or email and/or via our website. However, we may also collect information from publicly accessible sources (e.g., property records); directly from a third party, e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers; from a third party with your consent (e.g., your bank); from cookies on our website; and or via our IT systems, including door entry systems and reception logs and automated monitoring of our websites, Wi-Fi, internet browser and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
Why We Use Your Personal Information. We use your personal information for the following reasons: to fulfill or meet the reason you provided the information; to provide, support, personalize, and develop our products and services; to create, maintain, customize, and secure your account with us; to process your requests, purchases, transactions, and payments and prevent transactional fraud; to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses; for testing, research, analysis, and product development, including to develop and improve our products and services; to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; counting visits by unique visitors to gauge views; detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; debugging to identify and repair errors that impair existing intended functionality; short-term, transient use, provided the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction; performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider; undertaking internal research for technological development and demonstration; undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
Who We Share Your Information With: We share your information with our affiliates; service providers we use to help deliver our services to you, such as fund administrators, payment service providers, warehouses and delivery companies; other third parties we use to help us run our business, such as website hosts; third parties approved by you, including consultant, and third party payment providers; credit reporting agencies; our insurers and brokers; and our banks.
What Types of Information We May Share: in the past 12 months, we have shared the following types of information to parties identified above: identifiers, California Customer Records personal information, and commercial information. We have never sold any personal information.
Description of Your Rights: You have the right to know the categories of information that we collect about you; the sources from which the personal information is collected; our business or commercial purpose for collecting 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. We are not required to retain any personal information about you that was collected for a single one-time transaction 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 12-month period.
You have the right to request that we delete your personal information from our records and direct any service providers to delete your personal information from their records.
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.
These rights are subject to certain limitations and qualifications.
How to Exercise Your Rights: if you want to exercise any of your rights under the CCPA, please contact us at indusfunds@induscap.com. You will be required to provide us with enough information to identify you (e.g., your full name and address), proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility bill), a description of what right you want to exercise and the information to which your request relates. 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. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. You also have the right to appoint an authorized agent to exercise your rights on your behalf.
Additional Information. If you have any questions about the Privacy Notice, including the CCPA, please contact Laura Ferchak, Chief Compliance Officer, at induscompliance@induscap.com or 212-909-2888. For consumers with disabilities who need to access this Privacy Notice in an alternative format, please contact Laura Ferchak, Chief Compliance Officer, at induscompliance@induscap.com or 212-909-2888.
