GDPR Privacy Notice

This section of our notice applies to visitors to our website who are located within the European Economic Area ("EEA") or the United Kingdom.  Please scroll down to read the parts of our privacy notice which are relevant to other jurisdictions.

INTRODUCTION

Respect for Your Privacy:

The privacy of your personal information is important to us at SPF Investment Management, L.P., and we are committed to protecting its privacy. Furthermore, the privacy of your personal information may be protected by various government laws or regulations. 

At the same time, in order to provide you with services you may request, it is necessary for us to possess some personal information of yours. Similarly, without some of that information, we cannot inform you about the services we have available or that you may request (though if you are currently receiving information or marketing communications from us, you may opt-out of receiving further communications at any time).

This privacy statement explains our personal information policies and practices. It includes, but is not limited to, explanations of the types of personal information we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, your rights regarding your personal information, and the way to contact us to exercise those rights.

The GDPR and Your Personal Data Rights:

The European Union’s General Data Protection Regulation (GDPR) is a sweeping piece of legislation that grants EU residents increased control over their personal data. 
The GDPR allows consumers to access their personal data and find out details of how that data is processed, to rectify inaccurate personal data, to have their data erased (when certain conditions are met), to restrict processing of their data, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to ensure that personal data is secured. 

This privacy notice provides the details you need to understand your rights under the GDPR, and to exercise those rights. It provides you with the contact information you need to take action regarding the privacy of your data.
 
DATA PRIVACY INFORMATION

Defining Personally Identifiable Information:

Various laws and regulations (including the GDPR) use different terms and definitions for information about individuals that is personal and should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories.

At SPF Investment Management, L.P., we have chosen to adopt the broader approach to what information must be protected and kept as private as possible. In this notice, “Personally Identifiable Information” (PII) refers to data that could be used, alone or in combination with other data, to identify you as an individual. It can include name, physical address, email address, IP address, date of birth, social security number, passwords, credit card or other financial or payment information, and more.

Security of Personal Information: 

We are committed to protecting your PII from unauthorized access and use. To help protect your personal information, we implement and maintain appropriate technical, physical, and administrative safeguards. Access to your personal information is restricted solely to those employees who need to know that information to provide our services to you. Our employees receive training to maintain the confidentiality, privacy, and security of your personal information. 

Data Storage and Retention:

Your personal information will be retained only for as long as the information is needed to fulfill the purposes for which it was collected and processed. We reserve the right to retain and use your personal information for as long as necessary to comply with our legal obligations and business requirements and/or to resolve ongoing disputes and enforce our agreements. 
 
Types of Collected PII:

SPF Investment Management, L.P. collects some of your personally identifiable information. This section describes the categories of PII that are collected, as well as the categories of sources for obtaining that PII, and the purpose for collecting it.

PII Categories: 

Depending on your relationship with us, the PII we collect from you may consist of any of the following categories: 

•	If you are employed by us or are applying to be employed by us, your contact information, date of birth, place of birth, social security number or other government-issued identification number, passport details, educational details, professional references, credit history, employment history, information related to your employment benefits, personal securities trading related information, information related to your employment, information required to pay you, and anything else you may share with us which we collect (including Criminal History, if any and if permitted by law) (HR Related Data).

•	If you (or a corporate entity you are associated with) carry out financial transactions with us or perform services for us, information about those transactions or services, your financial details and other related information (Financial Data)

•	If you (or a corporate entity you are associated with) invest with us or are identified as a prospect to invest with us, your contact information, information about your investments and their performance, information about the corporate entities you are associated with, and information that we collect from you as part of our onboarding process (Investor Data)

•	Information that may be provided to us based on your interactions with our custodian or administrator service providers (Custodian/Administrator Data)

•	Information that may be provided to us based on your interactions with our distributors (Distributor Data)

•	Information about investments that is necessary for us to collect in order to carry out our accounting functions (Accounting Information)

•	Information we collect about you if your personal information is included in documentation (i) held by a prospective investment counterparty which we are reviewing for the purposes of assessing a potential investment or (ii) provided to us by a counterparty or their agent in connection with an investment, such as your name and details of your transactions with the relevant counterparty (Investment Data)

Sources for PII:

The categories of sources of the PII we collect about you are: 

•	Direct (information you provide to us)

•	Indirect (information provided by third parties such as our service providers, prospective investment counterparties (or their agents) or investment counterparties (or their agents))

Purpose for Collecting Your PII:

Depending on your relationship with us, we collect your PII for a variety of purposes including, as applicable: 

Purpose/ Categories of Data/ Legal Basis
•	Managing job applications and employment/ HR Related Data, Financial Data/ Performance of a contract with you or, in specific circumstances, compliance with our legal obligations
•	Facilitating transactions related to your investments in investment funds managed by us/ Financial Data, Investor Data/ Performance of a contract with you
•	Contacting you or your designated representative by phone, email, fax, or mail/ Investor Data, Custodian or Administrator Data/ Performance of a contract with you or, depending on the nature of the communication, our legitimate interest in managing our relationship effectively
•	Performing obligations under agreements between ourselves and you/ HR Related Data, Financial Data, Investor Data, Custodian or Administrator Data, Distributor Data, Investment Data/ Performance of a contract with you
•	Sharing information about our services/ Investor Data/ Our legitimate interest in promoting our business
•	Providing you or your representative with marketing communications/ Investor Data/ Our legitimate interest in promoting our business
•	Fulfilling our legal and regulatory obligations including compliance with applicable anti-money-laundering and know-your-customer laws, sanctions monitoring, tax law compliance and compliance with laws and regulations applicable to investment advisers and investment fund marketing and distribution/ HR Related Data, Financial Data, Investor Data, Custodian or Administrator Data, Distributor Data, Investment Data/ Compliance with our legal obligations 
We may also further process your personal data where necessary in connection with actual or prospective legal claims or legal proceedings, or to take legal advice.

Our Website and Your PII: 

Visiting and navigating our website will likely involve some form of usage of your PII. This section details the methods and permissions involved. 

Consent to Use Your PII:

While we do not generally rely on your consent (under the GDPR) as a lawful basis for processing, please note that we might also be required under applicable privacy laws and regulations to record and maintain certain PII from you (e.g., recording telephone calls or monitoring email and other network traffic) on the basis of consent.

Without some of this information we cannot provide you with the services you may request. If you are currently receiving information or marketing communications from us, however, you may opt-out of receiving further communications at any time.

If we do rely on consent, you may withdraw such consent at any time by contacting us via the details at the end of this GDPR privacy notice.

Use of Cookies:
Some of the PII we collect is obtained through the use of third-party automated collection tools on our website(s), such as cookies or web beacons that capture information sent from your web browser to our website. Information that is collected includes your IP address, the website address that you were at before landing at our website, and information such as the pages you clicked through while at our website. This information is collected to improve your experience. 

When you first visit our website, you are asked if you agree to our use of cookies. You may agree and opt-in, or refuse and opt-out. If you opt-out, please note that your experience using the site may not be optimal. 
 
Sharing Your PII:

Your PII may be combined with information we receive from other sources, or it may be provided to other organizations we work with. This section details that sharing of your PII.

Receiving PII from Third Parties:

We may receive information about you from other sources and combine that information with the PII we collect directly from you. Additionally, to promote protection of your identity, we also may collect identity information which we use to help prevent and detect fraud.

Sharing PII with Third Parties:

We may share your PII with our affiliates, business partners, and other third parties. We may do so for the purposes of operating our business, delivering and improving the financial services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business.

We also share personal information for a variety of additional purposes including, but not limited to: 

•	Within SPF Investment Management, L.P. and our affiliates and subsidiaries for data processing or storage purposes

•	With business partners and suppliers to provide services and help facilitate transactions

•	In response to a request from law enforcement, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements

•	For any purposes other than which the PII was collected (and other than for the exceptions listed here) only after we have provided you notice and received your consent to share the information for that purpose

Transfer of PII from the EU (or EEA, Switzerland) to the US and/or Other Countries:

Your personal information may be transferred, processed and/or stored in a country other than the one in which your personal information is collected. When transferring your personal information to the US or other countries, we have implemented the necessary safeguards as required by the GDPR by way of entering into the standard contractual clauses approved by the European Commission for that purpose. We have also implemented procedures to ensure that appropriate safeguards are in place to protect the personal information regardless of where it is being transferred to. 

PII From Minors:

We do not offer financial services and products to minors and do not intend to collect personal information from persons under the age of 18. We follow all local legal requirements with respect to the collection and processing of a minor’s personal information.
 
Your Data Subject Rights:

The GDPR and other national privacy laws provide data subjects with certain rights regarding their personal data. 

If you are an individual who resides in the EU and whose personal data is collected and processed by SPF Investment Management, L.P., you have the right to (subject to certain objections): 

•	Request access to your data
•	Rectify your data 
•	Take your data (in a readable, “portable” format) to another service provider
•	Erase your personal data 
•	Restrict or object to the processing of your personal data
•	Lodge a complaint with a Member State Supervisory Authority
•	Withdraw previously given consent to collect and process personal data (which will not impact personal data processed before the withdrawal)

Contacting Us to Exercise Your PII Rights:

You may contact us in order to exercise any of your rights set forth in this privacy notice at the details listed below.

Questions, Concerns or Complaints:

If you have any questions, concerns or complaints regarding the information in this privacy statement and/or our privacy practices, please contact:

Christopher Marvin, General Counsel and Chief Compliance Officer
SPF Investment Management, L.P.
220 Fifth Avenue, 13th Floor
New York, NY 10001
United States
E-mail: spf@spfim.com 
Phone: +1 (212) 457-8730

Changes to this Privacy Statement:

From time to time we may update this privacy statement. If revisions are made to the privacy statement, we will update the statement with a new revision date. 


CCPA Privacy Notice

INTRODUCTION

Respect for Your Privacy:
The privacy of your personal information is important to us at SPF Investment Management, L.P., and we are committed to protecting its privacy. Furthermore, the privacy of your personal information may be protected by various government laws or regulations. 
At the same time, in order to provide you with services you may request, it is necessary for us to possess some personal information of yours. Similarly, without some of that information, we cannot inform you about the services we have available or that you may request (though if you are currently receiving information or marketing communications from us, you may opt-out of receiving further communications at any time).
This privacy statement explains our personal information policies and practices. It includes, but is not limited to, explanations of the types of personal information we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, your rights regarding your personal information, and the way to contact us to exercise those rights.

The CCPA and Your Personal Data Rights:
The California Consumer Privacy Act (CCPA) is a sweeping piece of legislation that grants California residents increased control over their personal data. 
The CCPA allows consumers to find out what personal information of theirs has been gathered, to request that businesses delete their data, to opt out of having their information sold, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to ensure that their vendors comply as well. 
This privacy notice provides the details you need to understand your rights under the CCPA, and to exercise those rights. It provides you with the contact information you need to take action regarding the privacy of your data.
 
DATA PRIVACY INFORMATION

Defining Personally Identifiable Information:
Various laws and regulations (including the CCPA) use different terms and definitions for information about individuals that is personal and should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories.
At SPF Investment Management, L.P., we have chosen to adopt the broader approach to what information must be protected and kept as private as possible. In this notice, “Personally Identifiable Information” (PII) refers to data that could be used, alone or in combination with other data, to identify you as an individual. It can include name, physical address, email address, IP address, date of birth, social security number, passwords, credit card or other financial or payment information, and more.

Types of Collected PII:
SPF Investment Management, L.P. collects some of your personally identifiable information. This section describes the categories of PII that are collected, as well as the categories of sources for obtaining that PII, and the purpose for collecting it.

PII Categories:
Depending on your relationship with us, the PII we collect from you may consist of any of the following categories: 
•	HR Related Data (including Criminal History, if any)
•	Financial Data
•	Investor Data
•	Custodian/Administrator Data
•	Distributor Data
•	Prospects Data
•	Accounting Information
•	Investment Data

Sources for PII:
The categories of sources of the PII we collect about you are: 
•	Direct (information you provide to us)
•	Indirect (information provided by third parties)

Purpose for Collecting Your PII:
Depending on your relationship with us, we collect your PII for a variety of purposes including, as applicable: 
•	Managing job applications and employment
•	Facilitating transactions related to your investment in investment funds managed by us
•	Contacting you or your designated representative by phone, email, fax, or mail 
•	Performing obligations under agreements between ourselves and you
•	Sharing information about our services
•	Providing you or your representative with marketing communications
•	Fulfilling our legal and regulatory obligations

Our Website and Your PII: 
Visiting and navigating our website will likely involve some form of usage of your PII. This section details the methods and permissions involved. 

Consent to Use Your PII:
By visiting our website or completing any of our online forms, you consent to our storing and using your PII for the reasons provided in this notice. You also consent to our using it to reply to your request as well as to contact you in the future, whether or not at your request, to provide you with additional information.
Note that we might also be required to comply with all applicable privacy laws and regulations to record and maintain certain PII from you by (e.g., recording telephone calls or monitoring email and other network traffic).
Without some of this information we cannot provide you with the services you may request. If you are currently receiving information or marketing communications from us, however, you may opt-out of receiving further communications at any time.

Use of Cookies:
Some of the PII we collect is obtained through the use of third-party automated collection tools on our website, such as cookies or web beacons that capture information sent from your web browser to our website. Information that is collected includes your IP address, the website address that you were at before landing at our website, and information such as the pages you clicked through while at our website. This information is collected to improve your experience. 
When you first visit our website, you are asked if you agree to our use of cookies. You may agree and opt-in, or refuse and opt-out. If you opt-out, please note that your experience using the site may not be optimal.  

Sharing Your PII:
Your PII may be combined with information we receive from other sources, or it may be provided to other organizations we work with. This section details that sharing of your PII.

Receiving PII from Third Parties:
We may receive information about you from other sources and combine that information with the PII we collect directly from you. Additionally, to promote protection of your identity, we also may collect credit or identity information which we use to help prevent and detect fraud.

Sharing PII with Third Parties:
We may share your PII with our affiliates, business partners, and other third parties. We may do so for the purposes of operating our business, delivering and improving the financial services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business.
We also share personal information for a variety of additional purposes including, but not limited to: 
-	Within SPF Investment Management, L.P. and our affiliates and subsidiaries for data processing or storage purposes
-	With business partners and suppliers to provide services and help facilitate transactions 
-	In response to a request from law enforcement, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements
-	For any purposes other than which the PII was collected (and other than for the exceptions listed here) only after we have provided you notice and received your consent to share the information for that purpose

PII From Minors:
We do not offer financial services and products to minors and do not intend to collect personal information from persons under the age of 18. We follow all local legal requirements with respect to the collection and processing of a minor’s personal information.

Your PII Rights:
The CCPA provides you with certain rights in regard to what we do with your personally identifiable information. This section details those rights, how to exercise them, and what SPF Investment Management, L.P. will do in response.

Disclosure:
You have the right to request that we disclose to you, free of charge, the categories and specifics of the PII we collect about you (and/or, if applicable, disclose about you to a third party for business purposes). We require a verifiable request from you to ensure that it is, in fact, you who is requesting such a PII disclosure. Once we verify the request, we will provide that information to you. 
Your request for disclosure can apply to any such PII mentioned in the previous paragraph for as much as twelve months preceding your request. Be advised that we are not required to disclose such information about the PII we collect about you more than twice in a twelve-month period.
Following our verification of your request, we will disclose to you, unless otherwise restricted by law or regulation, the following PII we collect about you:
1.	The categories of personal information we have collected about you
2.	The categories of sources from which the personal information is collected
3.	The business or commercial purpose for collecting or selling that personal information
4.	The categories of third parties with whom we share personal information
5.	The specific pieces of personal information we have collected about you

Deletion of PII:
You have the right to request that we delete the PII we have collected from you. Following our verification of your request, we will comply with your request and delete any or all of your PII in our possession that we collected from you and/or any or all such PII in the possession of our service providers, unless otherwise restricted by law or regulation.

Contacting Us to Exercise Your PII Rights:
You may contact us in order to exercise any of your rights set forth in this privacy notice by calling this toll-free number (1-866-467-8688) and entering Service Code 248, by sending us an e-mail at spf@spfim.com or by visiting our website (www.spfim.com).

This privacy statement was last revised and posted on January 06, 2023.