HazelTree Fund Services, Inc. and its subsidiaries ("Hazeltree") is committed to protecting personal data and respecting your privacy. This privacy statement describes how we collect, use, share, protect, and otherwise process personal information about you. This statement applies to personal information that you provide to us:
Notice to Hazeltree Clients In case we collect personal information, Hazeltree acts as a “data processor” (as defined in the European General Data Protection Regulation (GDPR)) on behalf of its clients and this privacy policy does not apply.
We may collect and process the following information (personal data) about you:
Information that you give us:
Information that our website and other systems collect about you:
Other information: We may also collect some information from other sources. For example:
We may use your information for the following purposes:
We may from time to time be required to review information about you held in our systems for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. To the extent permitted by applicable law, these reviews will be conducted in a reasonable and proportionate way, and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties as set out below.
Your emails and other communications may also be accessed occasionally by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left our organization).
We will only process your personal information as necessary to pursue the purposes described above.
In exceptional circumstances, we may also be required by law to disclose or otherwise process your personal information.
We may disclose personal information about you, where reasonably necessary and appropriate for the various legitimate purposes set out above:
These disclosures may involve transferring your personal information overseas. If you are dealing with us within the European Economic Area (or the UK, after it has left the European Economic Area), you should be aware that this may include transfers to countries outside the European Economic Area / UK, which do not have similarly strict data privacy laws and which may therefore afford a lower standard of personal data protection. In those cases, where we transfer personal data to other legal entities within Hazeltree or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission.
We are committed to protecting your personal information submitted to us. We maintain an information security program including internal policies addressing the acceptable use and access to confidential business information and personal information which may be contained within Hazeltree’s information systems. We maintain physical, electronic and procedural safeguards reasonably designed to guard personal information from loss, misuse or unauthorized access, disclosure, alteration or destruction of the information that has been provided to us through our on-line services.
We will retain your data in accordance with our Data Retention Policy, which provide for a period of at least 7 years or longer as required by applicable law or our internal data protection policies.
We will delete the information that we hold about you when we no longer need it.
Note that we may retain some limited information about you even when we know that you have left the organization that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organization.
Rights of access, correction, restriction and deletion You have a right of access to the personal information that we hold about you under European data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted as well as that any further data processing is restricted.
Right to object You can object to our use of your personal information for direct marketing purposes at any time and you have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please contact us as set out below.
Complaints You can also lodge a complaint about our processing of your personal information with the body regulating data protection in your country.
Under the California Consumer Privacy Act and its implementing regulations (CCPA), you (if you are a California resident) may have certain privacy rights in connection with your Personal Information (as such term is described in the CCPA). Some of those rights and disclosure requirements are already outlined in the various Sections above. In addition, we collect the personal information categories outlined below, which we may disclose to other legal entities within Hazeltree, third party service providers who host our website or other information technology systems or otherwise hold or process your information on our behalf, under substantially similar conditions of confidentiality and security, and business partners, suppliers and sub-contractors for our operational business purposes:
We do not share or sell your personal information with third parties for such third parties’ direct marketing practices; nor do we sell personal information (as contemplated by the CCPA) about you that you have provided to us or that we may have collected.
If you are a California resident, you have the following rights as set forth in the CCPA:
a) Right to Know. You have the right to request that we disclose to you the following information covering the 12 months preceding your request.
b) Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you.
c) Right to Be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
We welcome questions, comments and requests regarding this privacy policy and our processing of personal information. Please send them to 150 West 30th Street, 11th Floor, New York, NY 10001 or email us at privacy@hazeltree.com.
To make a request for the disclosures or deletion described under Section 8, please email us at privacy@hazeltree.com.
We will respond to your request consistent with applicable data protection laws. Depending upon the type of business relationship that you have with us, we may need to notify you that additional information is necessary to authenticate your identity for your data security or that we will refer your inquiry to the financial services entity that holds the primary relationship with you.
For requests to delete your personal information as permitted under applicable data protection laws, we will work with you to accomplish your requests unless otherwise exempted under applicable data protection laws, such as compliance with applicable law or regulatory inquiry.
We track user activity on our website by setting cookies on your browsers. These cookies are set in order to remember preferences when you return to our site, such as form field values. By continuing to browse the site, you are agreeing to our use of cookies.
Our website uses three types of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Further information about cookies and their purpose can be found by visiting: http://www.allaboutcookies.org/
We use the following first-party cookies:
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Session cookie
Visitor cookie
Blocking cookies
Duration of cookies
Do the cookies expire?
The cookie duration is set to 10 years.
Do the cookies store any personal information (encrypted or otherwise)?
No. Cookies are simply a numeric identifier that allow us to recognize repeat users and have no meaning outside the marketing automation system.
How can someone stop being tracked?
Cookies are set on users’ browsers. If cookies are disabled (generally or selectively), or if a browser extension is enabled, cookies may not be set properly and prospect activity may not be tracked.
How can I reject and delete Cookies?
Most web browsers automatically accept cookies. However, you do not have to accept cookies and you can, should you choose to at any time, reject or block the use of cookies and delete all cookies currently stored on your computer or mobile device. You can find out how to do this for your particular browser by clicking “help” on your browser's menu, or by visiting: www.allaboutcookies.org.
Any changes we make to this privacy policy in the future will be posted to our website and also available if you contact contact us. Please check back frequently to see any changes.
Last Updated: June, 2023