Privacy Policy

WSD Capital Management, L.P. (the “Firm”) understands that your privacy is important to you. This Privacy Policy and any applicable agreement entered into by you and the Firm sets out the basis on which the Firm uses your personal information. If you are viewing this Privacy Policy on the Firm’s website located at www.wsdcapital.com (the “Website”), you accept that your use of the Website indicates your consent to the practices described in this Privacy Policy. This Privacy Policy, in conjunction with the Cookie Usage Information, describes how the Firm handles and protects your personal data in connection with the Website, in the Firm’s capacity as a data controller. Please see the Website’s Terms of Use for more information about the Website’s online terms and policies in general.

Whose Personal Information Is Collected?

The Firm collects and uses information about the following groups of individuals:

Clients, investors and beneficiaries (current, prospective and former) and any of their directors, officers, employees, partners, shareholders or agents;
Suppliers and service providers;
Professional advisers and consultants;
Individuals who contact the Firm by e-mail, phone or otherwise and any visitors to the Website;
Employees, contractors and other members of staff (current, prospective and former); and
Directors, officers and senior management of listed companies in which the Firm may invest.

Types of Personal Information

The Firm may collect and use personal information that is:

Directly provided by you;
Related to services provided to you by the Firm;
Received from your representatives or advisers;
Received from third parties, including administrators of products advised by the Firm;
Collected using cookies and other technologies when visiting the Website; or
Sourced from public sources.

When you visit the Website, your IP address is recorded, along with the data you requested, the server reply code on the request from your browser, what browser you used, the date you visited, and for how long. Please refer to the Firm’s Cookie Policy for more details regarding the Website’s use of cookies.

The Firm cannot attribute this data to any specific person as a general rule (unless you log in), and does not combine this data with data from any other sources.

The Firm collects personal data on certain areas of the Website when you register for or apply for jobs, register for newsletters and alerts, and/or sign up for conferences and events. The personal data collected varies across the Website and may include information that you provide, such as your name, mailing address, e-mail address, telephone number, fax number, and background information required to apply for a job.

Purposes for Collection of Personal Information

The Firm may use the information held about you to:

Provide you with information about the Firm’s products, services, research or events;
Assess your suitability for products or services;
Evaluate and improve the Firm’s services;
Process your subscription or investment in certain funds and accounts the Firm manages (collectively, the “WSD Funds”);
Fulfill any contract between you and the Firm;
Fulfill any legal, regulatory or self-regulatory requirement that applies to the Firm and/or any of its affiliates;
Protect the Firm’s property, services and legal rights;
Process your job application and assess your suitability for a vacancy with the Firm;
Process your requests to participate in conferences and events;
Personalize content that you view or receive on the Website;
Ensure that the Website is effectively presented for you and for your computer or device;
Analyze the Website’s performance and functioning;
Administer the Website;
Enforce the Website’s terms of use and the Firm’s agreements;
Support auditing, compliance, and corporate governance functions;
Comply with all applicable laws and corporate reporting obligations;
Respond to any inquiry or complaint raised by you;
Evaluate information about directors, officers and senior management of listed companies in which the Firm may invest, for research and investment purposes; and
Prevent fraud against the Firm, its subsidiaries, affiliates and/or business partners.

The Firm may combine any information that you provide with the information received from other sources. This combined information may be used for the purposes set out above. The Website does not collect personal data about your online activities over time and across third party websites or online services.

Third Parties

The Firm may share your personal information with any of its affiliates for the purposes set out above. In addition, the Firm may share your personal information with selected third parties, including:

Business partners, suppliers and sub-contractors for the performance of any contract the Firm enters into with them or you;
Marketing providers that assist with the delivery of information to you;
Analytics providers that assist in the improvement of the Website;
Administrators and directors of the WSD Funds in connection with your subscription or investment in such funds; and
Law enforcement authorities or other government entities based on a lawful disclosure request.

The Firm may also share your personal information with third parties in the following circumstances:

If the Firm sells or buys any business or assets, it may be necessary to share your personal information with the prospective seller or buyer;
If the Firm is acquired by a third party, the personal information held by the Firm will be one of the transferred assets; or
If there is a duty to share your personal information in order to fulfill any legal, regulatory or self-regulatory requirement that applies to the Firm and/or any of its affiliates, or if the Firm believes disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

Newsletters and Information Services

There are many points on the Website where the Firm offers newsletters or comparable information services. By registering for newsletters or alerts, you agree to receive the correspondence to which you have subscribed at the e-mail address that you provided at registration. Only the Firm or its agents will contact you using this e-mail address.

You may also unsubscribe from mailing lists or any registrations on the Website. To unsubscribe from mailing lists or any registrations, please click on the “Unsubscribe” link in the e-mail to opt-out of e-mail marketing communications.

The Security of Your Information

The Firm is committed to protecting information that you provide. While no data transmission over the Internet can be guaranteed to be 100 percent secure, the Firm takes reasonable and appropriate measures designed to protect the security of data transmitted to the Firm upon receipt. By default, the Website encrypts connections between client devices and the Firm’s servers to minimize the ability of any third party to “eavesdrop” on the data. In addition, where feasible, data is stored encrypted.

The Firm’s databases and system administration logs, are restricted to access by authorized and authenticated users. The Firm uses reasonable industry security standard safeguards (which may include physical, procedural and technical measures) to protect against the unauthorized disclosure of data. Despite these precautions however, the Firm cannot guarantee that unauthorized persons will not obtain access to your personal data.

Where the Firm Stores Your Personal Information

If you visit the Website from a country other than the United States, your communications will likely result in the transfer of your data across national borders. The Firm’s servers or offices may be located in countries other than the country from which you access the Website, also resulting in the transfer of your data across international borders. If you provide your data when visiting the Website from outside of the United States, you acknowledge and agree that this data may be transferred from your then current location to the Firm’s offices and servers and to those of its affiliates, agents, and service providers located in the United States and in other countries. The United States and such other countries may not have the same level of data protection as those that apply in the jurisdiction where you live.

For site visitors who reside in the European Economic Area, Switzerland or the United Kingdom, the Firm will only transfer your data (a) to jurisdictions with “adequate protection” as used in the General Data Protection Regulation governing transfer of personal data outside of the European Union (the “GDPR”), or (b) to recipients with appropriate safeguards in place, including where contractual arrangements exist which include Standard Contractual Clauses (as defined in the GDPR) without any additions, modifications, or omissions. By submitting your personal information to the Firm, you agree to this transfer, storing or processing.

Data Retention Policy

The Firm retains personal data, as necessary, for the duration of the relevant business relationship. The Firm may also retain personal data for longer than the duration of the business relationship should it need to retain it to protect itself against legal claims, use it for analysis or historical record-keeping, or comply with its information management policies and schedules. If you request that the Firm delete your personal data, the Firm will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Privacy Policy.

Your Rights

The Firm offers you certain choices in connection with the personal information the Firm collects from you. To update your preferences or submit a request, please contact the Firm via e-mail. To the extent provided by the law of your jurisdiction, you may request access to the personal information the Firm maintains about you or request that the Firm correct, amend, delete or block the information. Where provided by law, you may withdraw any consent you previously provided to the Firm or object at any time on legitimate grounds to the processing of your personal information, and the Firm will apply your preferences going forward.

You also have a right to lodge a complaint with a relevant supervisory authority once you have tried to resolve the issue with the Firm.

Your California Privacy Rights

Pursuant to California Civil Code Section 1798.83(c)(2), the Firm does not share your personal data with third parties for those third parties’ direct marketing use.

Children

The Website are not designed for or directed at children 13 years of age or younger, and the Firm does not intentionally collect or maintain personal data about anyone under this age.

Link to Third-Party Sites

The Firm may provide links to third-party websites or information as a service to its users. If you use these links, you will leave the Website. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by the Firm of the third party, the third-party website, or the information contained therein, and the Firm shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

Consent and Changes to Privacy Policy

By using the Website, you consent to the collection, use, and storage of your personal data by the Firm in the manner described in this Privacy Policy and elsewhere on the Website. The Firm reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. Such changes shall be effective immediately upon posting. The Firm suggests that you review this policy periodically for changes. You acknowledge that by accessing the Website after the Firm has posted changes to this Privacy Policy, you are agreeing to the terms of the Privacy Policy as modified.

Last modified on April 20, 2018.