Client Privacy Notice of Hall Capital Partners LLC.
Your privacy is very important to us. This Privacy Notice explains how we collect, use, share, protect and otherwise process personal information provided to Hall Capital Partners LLC and the private funds it manages (“Hall Capital” or “we”) by current, prospective, and former clients, investors in private funds managed by us and other individuals we serve (each, a “client” or “you”).
Personal Information We Collect And How We Collect And Use It.
We collect and use personal information from or about our clients and their representatives and beneficial owners for the purpose of providing our financial and advisory services.
The specific information we collect for each client depends on the scope of our relationship with that client. We collect personal information (i) provided directly to us by you or another person on your behalf, including through conversations and electronic communications, (ii) from account and similar applications and documentation that you complete with our assistance, (iii) through specific transactions, investments, and monitoring of accounts on your behalf, and (iv) from third parties, such as administrators of our private funds, publicly-accessible sources, and consumer reporting agencies.
We process your information only (i) when we have your consent, (ii) when we need to information for the purposes of performing our contractual relationship with you (or to take steps at your request prior to entering into a contractual relationship), (iii) when the processing is necessary for our legitimate interests and not overridden by your fundamental rights and freedoms (such as to respond to your inquiries, to monitor and improve our services or offer new services to you, or to execute your investment strategy), or (iv) when necessary to comply with applicable legal or regulatory requirements.
How We Disclose Personal Information.
Hall Capital does not disclose or sell personal information about clients with unaffiliated third parties, except as described below and permitted by law. We do not disclose personal information about any of our clients to unaffiliated third parties for their telemarketing, direct mail or other marketing purposes.
We may disclose personal information to third parties (i) to process, administer or enforce transactions as necessary to execute an investment strategy or to service customer accounts, including disclosures to investment managers and investment funds, transfer agents, brokerage firms, your lawyers and accountants, and other service providers, (ii) for our legitimate business purposes, including disclosures to our lawyers, accountants, auditors, and other third parties that offer products and services to Hall Capital (such as data storage, customer relationship management, and third-party administrative services), (iii) when requested by you, (iv) if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control, and (v) to detect or report suspected illegal activity, fraud or other wrongdoing, including pursuant to regulations designed to detect or prevent money laundering, and (vi) in connection with actual or threatened lawsuits, in each case subject to applicable law. In addition, applicable law may require us and third parties that perform services on our behalf to comply with a legal process (such as a court order, subpoena or search warrant) or in connection with a government or regulatory request or investigation. Nothing in this Privacy Notice prevents reporting possible violations of law to any governmental authority or other disclosures protected under the whistleblower provisions of applicable law.
How We Protect And Retain Information.
We maintain physical, electronic and procedural safeguards to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. We restrict access to each client’s personal information to those employees who have a business reason to know that information, and all of our employees are subject to strict obligations of confidentiality. We have implemented appropriate safeguards intended to ensure that our third-party service providers protect personal information that they process on our behalf. Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure.
We retain personal information as necessary for our legitimate business purposes. The criteria used to determine our retention periods include the length of time we provide services to you (e.g., for as long as you have an account with us), whether there is a legal obligation to which we are subject (i.e., certain laws require us to keep records of your transactions for a certain period of time), and whether retention is advisable considering our legal position (e.g., for statutes of limitations, litigation or regulatory investigations). From time to time, we may review the purpose for which personal information has been collected and decide to delete or anonymize it.
Your Choices About Your Information.
If you are a natural person and you would like to review, correct, delete or restrict our use of personal information about you that you previously provided to us or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (in each case, when these rights are provided to you by law), please contact us using the contact information below. In your request, please make clear the personal information to which your request relates and the actions you would like us to take. For your protection, we will verify your identity before responding to your request, and will process your request in compliance with applicable law. Please note that we may not allow you to review or delete certain data for legal, security or other reasons.
Your European Union And Cayman Islands Privacy Rights.
If you are located in the European Union or are an investor in a Cayman Islands investment fund, you have the right to lodge a complaint with a data protection authority about how we process your personal information. Hall Capital is the “data controller” of your personal information. As a data controller, Hall Capital is subject to requirements under applicable data protection law and regulation, including the General Data Protection Regulation ((EU) 2016/679), the UK Data Protection Act 2018, and the Data Protection Law, 2017 of the Cayman Islands, and any other applicable legislation in force from time to time that regulates the processing of personal information.
We may transfer, with appropriate safeguards, your personal information to our offices in the US and other jurisdictions where the privacy and data protection laws may not be as protective as those in your jurisdiction or the Cayman Islands. Please contact us using the contact information below to learn more about our safeguards for transfers of your personal information.
Changes To This Privacy Notice.
Hall Capital may change this Privacy Notice when permitted by applicable law. We will take appropriate measures to inform you of such changes, such as clearly and conspicuously posting a notice about changes, sending you an email (when possible), or obtaining your consent if required by applicable law.
If you have any questions about our privacy practices, please feel free to contact us at Compliance@hallcapital.com.