The Collection and Use of Personal Information
The following list describes the limited categories of Personal Information we may collect in your interactions with the Site or have collected about you in the past 12 months. As described above, we collect these categories of Personal Information from you directly, automatically from your interactions with us, or from third party sources. We collect this Personal Information for the business and commercial purposes of providing our services to you or otherwise for the management and administration of our website and business, to evaluate your job application or for purposes of your employment, communicating with you about our products and services, for fraud detection and prevention and other security purposes, to comply with legal requirements, enforce our policies or contracts, or otherwise to protect our rights and interests.
- Identifiers, such as name, email address, address, phone number, facsimile number, IP address, social security number or other similar identifiers.
- Characteristics of protected classes and demographic information, such as age, sex, and marital status. Note that we do not collect this information from job applicants.
- Commercial and financial information, such as records of personal property, products or services purchased, obtained, or considered, information on investments, assets, net worth, tax status, holdings, account balances, transaction history, bank account details, wire transfer instructions.
- Site activity information, including information regarding an individual’s interaction with the Site.
- Audio, electronic, visual, thermal, or olfactory information, such as copies of drivers’ license, passport or other photograph identification, or information from security cameras in certain of our facilities that deploy them.
- Professional or employment-related information Education information
- Inferences drawn from any of the information identified above, to create a profile reflecting an investor’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Information Collected and Stored Automatically
The Site automatically collects some technical information from you when you visit the Site in order to give you the best possible experience. The Site uses web measurement technology (e.g., HubSpot and Google Analytics) to automatically track how visitors interact with the Site, including where they came from, what they did on the Site and whether they completed any pre-determined tasks while on the Site. Aggregate data is used to help improve our user interface and diversify our content offerings to meet the needs of our customers, track operational problems, prevent fraud, and improve the effectiveness, security, and integrity of the Site. This information is retained in accordance with the NHP record retention policy. For each page that you visit, we collect and store information about your interactions with our Site, including the following technical information:
- Date and time of access
- URL address of the Site webpage visited
- Internet domain and IP address from which our website was accessed
- Type of browser and operating system used to access the Site (if provided by the browser)
- URL address of the referring page (if provided by the browser)
- Completion or success status of the request for a webpage or other on-line item
- File size of the webpage visited
This information is used to help us make the Site more useful for you. With this data we learn about the number of visitors to our Site and the types of technology our visitors use. In the password protected portion of the Site, NHP maintains the right to track and store all actions which are performed during each visit; this is subject but not limited to products that were viewed and documents accessed; other than our third party service providers that support our site processes, we do not share this data with anyone outside of NHP unless necessary for law enforcement purposes or to otherwise comply with applicable law or to protect our rights and property and enforce our terms.
Information That You Provide Voluntarily
Cookies and other Tracking Technologies
One primary purpose for using cookies is to save you time on the Site. A cookie’s purpose is to communicate to the web server that you have come back to a certain page. One example would be if you register with the Site, a cookie will assist NHP in recalling your specific information on future visits. This simplifies the process of recording your personal information or preferences. When you return to the Site, the information you previously provided can be retrieved, so you can easily use the NHP features you personalized.
You have the ability to accept or decline cookies. Most modern web browsers accept cookies automatically, but you can usually modify your browser’s settings to decline cookies if you choose. If you elect to decline cookies, you may not be able to fully experience the interactive features of the Site.
NHP may utilize third party services to enhance distribution of data and information through links from the Site. A persistent cookie, which may be saved to your hard drive and accessed upon re-visiting a website that originated the cookie, may be set by such a third-party provider when you click on the provider’s link in order to access NHP data.
Sharing of Information
NHP does not sell your Personal Information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share Personal Information with certain third parties without notice to you, including those set forth below. For each of the Personal Information categories listed above, we may share this information with other entities and affiliates for business or commercial purposes.
Agents, Consultants and Related Third Parties:
We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function. We require such third parties to maintain the confidentiality of such information and use such information only as necessary to provide us with designated services. We may also share information with our affiliates that assist us in the management and administration of our business.
We may aggregate your Personal Information with Personal Information of other users of the Site and disclose such information in a non-personally identifiable manner to advertisers and other third parties for marketing and promotional purposes. In these situations, we will not disclose to these entities any information that could be used to identify you or your clients personally.
We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) at the request of governmental authorities or other third parties conducting an investigation, (c) to detect and protect against fraud, or any technical or security vulnerabilities, (d) to respond to an emergency, (e) act in urgent circumstances to protect the personal safety of users of the Site or the public, (f) protect against legal liability, or (g) otherwise to protect the rights, property, safety, or security of our business, third parties, visitors to our websites, or the public.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.
NHP may also use online survey instruments to obtain feedback on your experience with the Site. If you decline any survey, you will still have access to the same information and resources of the Site as those who do take any survey. Any survey reports are available only to the Site’s managers and other staff who require this information to perform their duties. NHP retains the data from any survey results in accordance with its record retention policy.
Social Media and Third-Party Websites
NHP uses some social media tools and websites to interact with customers and resource partners. Social media websites are used to publicize NHP programs and services and engage with members of the public. NHP does not use third party websites to solicit and collect personal information from individuals. Any personal information collected by a third-party website will not be transmitted to NHP unless required for law enforcement purposes or as otherwise permitted by law. The NHP privacy and other web policies do not apply to these third-party sites and we encourage you to read the policies of the third-party site when deciding whether to use it.
Site Security and Safeguarding of Information
NHP maintains reasonable administrative, technical, and physical policies, procedures and safeguards designed to assist us in protecting the Personal Information we collect against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. These measures include computer safeguards, secured files and buildings, and employee background checks. For Site security purposes and to ensure that this service remains available to all users, this computer system employs commercial software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. The NHP computer system is protected by firewall and anti-virus software and employs encryption technology for data storage. NHP networks also employ automated network and server monitoring. All major components of the application and hardware architecture have been designed for automatic or semi-automatic rollover in the event of a failure. We take commercially reasonable steps to protect Personal Information and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free.
Other Terms and Conditions
Questions or comments regarding the Site, including any reports of non-functioning links, please contact us.
New Hyde Park Alternative Funds, LLC and New Hyde Park Asset Management LLC – General Data Protection Regulation (GDPR) Privacy Notice
New Hyde Park Alternative Funds, LLC and New Hyde Park Asset Management LLC (“NHP”) and their affiliated entities provide certain financial and technology services to eligible registered investment advisory firms, broker-dealers, qualifying investors, and select institutional investors, family offices, and banks and trusts located in the United States. NHP and its affiliated entities may provide financial and technology services to similarly situated investment advisory firms, qualifying investors, and select institutional investors and/or family offices located in the United Kingdom (UK) and the European Union. This privacy notice applies to data subjects, as defined by GDPR.
What Data Might We Collect? NHP collects the following data:
- Personal Identification Information: This may include First Name, Last Name, Email Address, Telephone Number.
- Professional Information: This may include employment information, job history, and other due diligence information required by way of law, regulation or best practice standards.
- Geolocation Data: Your IP Address.
- Cookie Data/Internet Activity: This pertains to information concerning interactions with the NHP public facing website.
When Might We Collect Data?
- When a data subject located in UK or EU accesses or views the NHP public facing website
How Will We Use Your Data?
- To evaluate an application for employment.
- To monitor traffic and activity on the NHP public facing website.
How Will We Share Personal Information?
- NHP will not sell your personal information to third parties.
- NHP will not generally share your personal information without your agreement.
Data Protection Rights NHP is required to make sure you are fully aware of your data protection rights. If you are a data subject in the UK or EU and you provide personal information to NHP, you are entitled to the following:
- The Right to Access: You have the right to request NHP for copies of your personal data. Please note that NHP may charge a fee for this service.
- The Right to Rectification: You have the right to request that NHP correct any information you believe is inaccurate. You also have the right to request that NHP complete information you believe to be incomplete.
- The Right to Erasure: You have the right to request that NHP erase your personal data, subject to certain conditions, statutory limits, and prerequisites.
- The Right to Restrict Processing: You have the right to request that NHP restrict the processing of your personal data, which means that NHP suspends the processing of your personal information for a certain period. This may happen when the accuracy of your personal information is contested but NHP requires time to verify the accuracy/inaccuracy, or if your personal data has been unlawfully processed and you request restriction of processing instead of deletion.
- The Right to Data Portability: You have the right to request that NHP transfer the data that we have collected to another organization, or directly to you, under certain conditions.
To exercise your rights, please contact us at 630-566-4502 or contact email@example.com. To the extent permitted by law, we will need to verify your identity, or the identity of your agent, and ensure the authenticity if your request.
Data Processing If you are a data subject located in the UK or EU and you provide personal information directly, NHP will process your information in accordance with the following requirements:
- Consent: Processing will be based on your consent (e.g., you voluntarily contact us).
- Legitimate Interests: Processing is necessary for NHP’s legitimate interests (e.g., monitoring the use of the NHP public facing website).
- Contract Undertaking: Processing is necessary for the performance of a contract to which you are a party.
- Legal Compliance: Processing is required to comply with a legal or statutory obligation.
If you are a data subject in the UK or EU, please know that you are entitled to file a complaint with your data protection authority. For the data protection authority in the UK, please visit https://ico.org.uk/ and navigate to the “Make a Compliant” icon. For data protection authorities located in the EU, please visit https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en.