Introduction

Your privacy is very important to us. This policy (this “Privacy Policy”) is provided by Atom Investors LP (“Atom”, “we” or “us”), and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to current, prospective and former investors in separate managed accounts that are managed by Atom. This Privacy Policy applies to both use of the Atom website.

References to “you” or an “investor” in this Privacy Policy mean any investor who is an individual, or any individual connected with an investor who is a legal person, as applicable.

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Who to Contact About This Privacy Policy

This Privacy Policy is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”). Atom is considered to be a data controller in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that the Investment Manager determines the purposes and the means of the processing of your personal information.

 

Please contact our Chief Compliance Officer at compliance@atomlp.com with any questions about this Privacy Policy or requests to exercise your rights with regards to the personal data we hold.

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You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.

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We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf.

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Please note that certain third-party service providers work under a range of professional and legal obligations that require them to process personal data (e.g., anti-money laundering legislation). In order to meet the requirements of such obligations, they, from time to time, would not be acting on our instructions but instead in accordance with their own respective professional or legal obligations and therefore as data controllers in their own right with respect to such processing. For more specific information or requests in relation to the processing of personal data by a service provider, you may also contact the relevant service provider by visiting their websites.

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The Types of Personal Data We May Hold

The categories of personal data we may collect include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches. If you are utilizing Atom services on behalf of another individual or entity, you are not required to disclose personal data of your underlying client. Any personal data of an underlying client should be transmitted to Atom in an anonymized manner.

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How We Collect Personal Data

We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; or (ii) information that we obtain in relation to any transactions between you and us.

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We also may receive your personal information from third parties or other sources, such as our affiliates, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

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How We May Use Personal Information

We may process your personal data for the purposes of administering the relationship between you and us (including communications and reporting), marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities, or law enforcement agencies).

 

We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal information. Such grounds include, for example, circumstances where:

1. processing is necessary to perform our obligations under any contractual arrangement between you and Atom;

2. we are required to comply with a legal or regulatory obligation applicable to us; or

3. we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal information, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose.

 

What Are The Consequences Of Failing To Provide Personal Information

Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in your investment being rejected. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

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How We May Share Personal Data

We may disclose information about you to our affiliates, service providers, or other third parties to accept your subscription, administer and maintain your account(s), or otherwise perform our contractual obligations. We may also need to share your personal information with regulatory, tax or law enforcement authorities to comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. We will also release information about you if you direct us to do so.

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It may also be necessary, under anti-money laundering and similar laws, to disclose information about you to facilitate the establishment of trading relationships for the separate managed account with executing brokers or other trading counterparties.

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We may also disclose information about you, or your transactions and experiences with us, to our affiliates or service providers for our everyday business purposes, such as administration of our business, record-keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, and compliance with applicable legal and regulatory requirements.

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Retention Periods and Security Measures

We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to the applicable Data Protection Laws. Personal data will be retained for the duration of your investment and for a minimum of five years after a withdrawal of your investment. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

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To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with applicable Data Protection Laws. These measures include computer safeguards and secured files and buildings.

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We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws.

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Additional Information under the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)

For purposes of U.S. federal law, this Privacy Policy applies to current and former investors who are individuals or Individual Retirement Accounts. We are providing this additional information under U.S. federal law.

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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) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary or appropriate, under anti-money laundering and similar laws, to disclose information about our investors in order to accept investments from them. We will also release information about you if you direct us to do so.

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We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at compliance@atomlp.com. If you are a new investor, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Policy. When you are no longer our investor, we may continue to share your information with our affiliates for such purposes.

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Cookies and Pixels

Cookies are small pieces of data that are stored on your computer, mobile phone or any other device used to access the internet. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies.

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We use these technologies to customize Atom and improve your experience with the site. Cookies store information, such as whether you viewed the site from your mobile device. We may store some personal information in a cookie and/or pixel, such as the site that you visited immediately prior to visiting Atom and relevant financial information that allows us to enhance your user experience and for marketing purposes. Additionally, we may use a cookie and/or pixel to track visitors across various websites or devices to better customize our marketing and advertising campaigns. We also offer certain tools from third-party service providers that may use cookies and/or pixels.

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Cookies, pixels, and similar technologies are not required for site functionality. You are not required to accept any cookies or pixels to use this site.

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Analytics Services

We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings and to understand more about the demographics of our users. You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy. You can also view Google’s currently available opt-out options.

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Children

Our service is not directed towards anyone under the age of 18. Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate their account.

 

California privacy rights

California consumers have the following additional rights under the CCPA with respect to their Personal Information. Please understand, however, that these rights are not absolute, and we may decline requests as permitted under applicable law.

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• Right to Request Access. You may submit a request that Atom disclose the categories of personal information we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of third parties with whom we share your personal information, and the specific pieces of personal information we have collected about you in the past 12 month. 

• Right to Request Deletion. You may submit a request that Atom delete the personal information about you that we have collected from you. 

• Right Not to Receive Discriminatory Treatment. You have the right to exercise the privacy rights conferred by the CCPA without discriminatory treatment.

 

Please understand that we are not obligated to provide you with access to your personal information more than twice in a 12-month period. 

 

Information For Persons Subject To UK Data Protection Laws

If you are located in the EEA or the UK, we adhere to relevant UK data protection laws, and provide individuals with the following additional information. For purposes of this section, “personal data” has the meaning provided in the General Data Protection Regulation (EU) 2016/679 as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“GDPR”). 

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Lawful bases for processing​

We process personal data subject to GDPR on one or more of the following legal bases:

• Legal Obligation: to conduct anti-fraud and identity verification and authentication checks and to fulfill our retention obligations; 

• Contractual Obligation: to satisfy our obligations to you, including to provide you with our services and customer support services, and to optimize and enhance Atom;

• Legitimate Interest: to monitor the usage of Atom, conduct automated and manual security checks of our service, to protect our rights; and

• Consent: to market Atom and our services to you. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before consent is withdrawn.

 

European privacy rights

European Residents have the following rights under GDPR, subject to certain exceptions provided under the law, with respect to their personal data:

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• Rights to Access and Rectification. You may submit a request that Atom disclose the personal data that we process about you and correct any inaccurate personal data.

• Right to Erasure. You may submit a request that Atom delete the personal data that we have about you. 

• Right to Restriction of Processing and Right to Object. You have the right to restrict or object to our processing of your personal data under certain circumstances.

• Right to Data Portability. You have the right to receive the personal data you have provided to us in an electronic format and to transmit that Personal Information to another data controller.

 

How You Accept This Policy

By using and continuing to use the Atom website or platform or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy and it supersedes any earlier version. Our Terms of Use take precedence over any conflicting privacy policy provision.

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Changes to the Policy

We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this privacy policy to determine if there have been any changes since you have last reviewed the Atom privacy policy and to stay informed about how we are protecting the personally identifiable information we collect.