In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Cove Creek Partners will obtain personal information about you.

This policy describes the types of personal information we collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy.

Cove Creek Partners’ Sources of Information

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Cove Creek Partners during the course of your relationship with us. We will also collect information about you from your custodian, broker, or your agents, or representatives. Cove Creek Partners collects information about you from your usage of the Cove Creek Partners website.

The Information Cove Creek Partners Collects

If you deal with Cove Creek Partners in your individual capacity (e.g. as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include:

• Your name, address, and other contact details;
• our age, occupation, and marital status;
• Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;
• A head and shoulders photograph from, as applicable, your passport, national identity card, or driver’s license, as required by laws and regulations addressing due diligence and related matters; and
• A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

 

If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:

• Your name and contact details;
• Your role/position/title and area of responsibility; and
• Certain identifying information (e.g. passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.

 

Cove Creek Partners’ Use of Your Personal Information

We may use your personal information to:

Administer, operate, facilitate and manage your relationship and/or account with Cove Creek Partners. This may include sharing such information internationally as well as disclosing it to third parties, as described in Disclosures of Your Personal Information below;

Contact you or, if applicable, your designated representative(s) by mail, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;

Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by Cove Creek Partners; and

Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with Cove Creek Partners ends, we will continue to treat your personal information, to the extent we retain it, as described in this policy.

Disclosures of Your Personal Information

Cove Creek Partners will not sell your personal information.

Cove Creek Partners does not disclose your personal information to third parties, except as described in this policy. Third-party disclosures may include sharing such information with nonaffiliated companies that perform support services for your account, that facilitate your transactions such as a custodian and brokers, or that provide services to Cove Creek Partners including legal, regulatory, audit, technology, or other services. We may also disclose your personal information to fulfill your instructions, to protect our rights and interests, and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities.

How We Protect Your Privacy

Cove Creek Partners is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized employees or agents and, as described above in Disclosures of Your Personal Information. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification, and unauthorized access or disclosure. Some of the primary features of our safeguards are:

• The use of specialized technology such as firewalls;
• Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
• Implementing controls to identify, authenticate and authorize access to various systems or sites;
• Protecting information during transmission through various means including, where appropriate and practical, encryption; and
• Providing Cove Creek Partners personnel with relevant training and updating our security practices in light of new risks and developments in technology.