During our ordinary business activities, WWC may process various categories of Personal Data including but not limited to:
We may collect this personal data in various ways, including:
We will process Personal Data including as outlined below:
For Business Purposes
We may collect and share Personal Data with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates (“Marketing Purposes”) unless and until you notify us that you do not wish to be contacted for Marketing Purposes. You may opt out of WWC’s direct marketing at any time. If you are a new investor, we will begin sharing your Personal Data with our affiliates for Marketing Purposes 30 days from the date of your initial investment in or commitment to a fund. When you are no longer our investor, we may continue to share your Personal Data with our affiliates for Marketing Purposes, unless you elect to unsubscribe from any such communications.
Personal Data held by us will be kept confidential in accordance with Data Protection Laws and applicable WWC policies and procedures. We will use commercially reasonable efforts to ensure that Personal Data is kept secure and safe from any loss or unauthorized disclosure or use.
Our Site uses Google Analytics to collect information regarding visitor behavior and visitor demographics on our website. Google Analytics uses text files placed on your computer (“Cookies”), to help our website analyze how users use the Site. The information generated by the cookie about your use (including your shortened IP address) will be transmitted to and stored by Google on a server which will regularly be located in the United States. On our behalf, Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity and providing us with other services relating to website activity and internet usage. The IP address transmitted from your browser as part of Google Analytics will not be put together with other Google data. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.
The below additional information applies only to Data Subjects who are residents of the state California in the United States where we process Personal Data under the California Consumer Privacy Act.
In accordance with the CCPA you may have the right to:
If you would like to exercise any of these rights, please contact us via email at: email@example.com. We will process such requests in accordance with Data Protection Laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
In respect of the collection, holding, storage, use, and processing of your Personal Data:
Because of the international nature of a fund management business, Personal Data may be transferred to countries outside the EEA, the UK or the Cayman Islands, and to jurisdictions where we conduct business or have a service provider, including the United States and other countries that may not have the same level of data protection as that afforded by Data Protection Laws in the EEA, the UK or the Cayman Islands. When doing so we will comply with the applicable requirements under GDPR and/or DPL and take appropriate safeguards to ensure the security and integrity of your Personal Data, in particular by entering into data transfer agreements as required under GDPR which are in the form of EU Standard Contractual Clauses.
Under the GDPR, and DPL more generally, subject to certain legal conditions, you may request access to, rectification, erasure or restriction of processing of your Personal Data. You may also object to processing or, under the GDPR, request data portability. Additionally, you may have the right to request a copy of the Personal Data that we hold about you. If your request is unfounded or excessive, we may charge an administrative fee.
PLEASE NOTE THAT IN ACCORDANCE WITH ARTICLE 21 (2) OF THE GDPR YOU MAY HAVE THE RIGHT TO OBJECT TO THE USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES.
If you have given us your consent for the processing of your Personal Data, you can withdraw the consent at any time with future effect, i.e., the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. Where consent is withdrawn, we may only further process your Personal Data where there is another legal basis for such processing.
For any of the above requests, we may require additional proof of identity to verify your identity and to protect your Personal Data against unauthorized access. We will carefully consider your request and may discuss with you how it can best be fulfilled.
If you have any concerns about how your Personal Data is handled by us or wish to raise a complaint on how we have handled your Personal Data, you may contact us to have the matter investigated. You may also submit a complaint to the competent data protection supervisory authority in your country. For example, if you are from the UK, you may contact the Information Commissioners Office via their website (www.ico.gov.uk).
Questions or complaints may be directed to:
White Wolf Capital
Attn: Chief Compliance Officer