Privacy Policy
Riposte Capital LLC ("Riposte") recognizes the importance of protecting your privacy and is committed to protecting your personal data. This privacy policy is provided to you by Riposte on behalf of its investment funds, and sets forth Riposte's policies with respect to the collection, sharing and protection of non-public personal information you provide to Riposte. These policies apply to individuals and individual retirement accounts only and may be changed at any time, without providing you direct notice.
This privacy policy explains how investment funds managed or operated by Riposte that are organized in the Cayman Islands (each a "Cayman Islands Fund") collect, use, share, and otherwise process personal data under the Cayman Islands Data Protection Law (as amended, the "Cayman DPL"). For the purposes of the Cayman DPL, the relevant Cayman Islands Fund is a Data Controller, and for the purposes of this privacy policy, the terms "we", "us", "our" includes the Cayman Islands Funds as the context requires.
This privacy policy is also being provided in accordance with the requirements of data privacy laws, including the EU General Data Protection Regulation 2016/679 (‘EU GDPR’), as well as the UK’s retained version of the EU GDPR (‘UK GDPR’) (collectively, ‘GDPR’). Natural persons from the European Economic Area (‘EEA’) and the UK should refer to the section on your rights under GDPR in this Privacy Notice.
GDPR requires Riposte to inform you of the legal basis on which we maintain your personal data. Typically, Riposte will reach out to you personally to confirm this; however, as a general rule the following is applicable.
- Clients – Information is maintained on the basis of contractual obligation, legitimate interest and/or legal obligation (where relevant);
- Service providers – Information is maintained on the basis of contractual obligation and/or legal obligation (where relevant); and
- Database/marketing contacts – Information is maintained on the basis of legitimate interest.
We collect personal information, such as your address, social security number, assets, transaction and/or income information, for example, when you (i) provide it to us or the Fund's Administrator in the Subscription Agreement and related documents; (ii) provide it to us in correspondence and conversations with Riposte's representatives; or (iii) make transactions with Riposte, such as when you purchase securities from us, tell us where to send money or make a wire transfer. We may also collect your personal information from other sources, such as affiliates. To the extent you provide personal information to service providers to our Funds, we attempt to verify that such service providers maintain their own privacy policies consistent with Riposte's privacy policy.
We may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) solely for our ordinary business purposes, such as to process your transactions, maintain your account(s), respond to court orders and legal investigations or to host this website. Thus, it may be necessary, under anti-money laundering and similar laws, to disclose information about our investors to affiliates and/or non-affiliates in order to accept subscriptions from them. We will also release information about you if you direct us to do so. We do not share your information with non-affiliates for them to market to you. We may disclose your information for our own marketing purposes, such as to offer our products and services to you. We may also disclose information about your transactions and experiences with us to our affiliates for their ordinary business purposes. You do not have the option to limit these types of sharing.