SHUTTLE FUND PRIVACY POLICY

Last Updated: May 4, 2018

 

We at Shuttle Fund Advisor LLC, together with our subsidiaries and affiliates listed in Appendix A of this Privacy Policy (collectively, “Shuttle” or “We”) respect your concerns about privacy. This Privacy Policy describes the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures.

By using our or our affiliates’ websites (collectively, the “Sites”), you are accepting the practices set forth in this Privacy Policy. If you do not agree with this policy, then you must not access or use the Sites.

YOUR INFORMATION

1. Information we collect automatically

When you use the Sites, we automatically collect and store certain information about your computer or mobile device and your activities. This information includes:

Mobile Device ID. Your mobile device’s unique ID number (e.g., IMEI).

Geographic Location. Your mobile device’s geographic location and timezone when you first register for any of the Sites.

Device Information/Specifications. Technical information about your computer or mobile device (e.g., type of device, web browser or operating system, IP address and internet service provider) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information.

Length and Extent of Usage.  How long you used the Sites and which pages, services and features you used.

Information obtained through cookies. We use “cookies” to keep track of some types of information while you are visiting and using the Sites. “Cookies” are very small files placed on your computer, and they allow us to count the number of visitors to the Sites and distinguish repeat visitors from new visitors. They also allow us to save user preferences and track user trends. We rely on cookies for the proper operation of the Sites; therefore if your browser is set to reject all cookies, the Sites may not function properly. Users who refuse cookies assume all responsibility for any resulting loss of functionality with respect to the Sites.

Information obtained through web beacons. “Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize the Sites for our users and to collect a limited set of information about our visitors. We may also use web beacons in email communications in order to understand the behavior of our customers, such as whether an email has been opened or acted upon.

2. Information you provide to us

Information you provide directly to us. When you register with the Sites, you provide us with:

  • Personal and business contact information (such as name, postal and email address, and telephone number); and
  • other personal information you submit to us (such as name and email address) you provide to register for email alerts.

3. How we use the information

Pursuant to the terms of this Privacy Policy, we may use the information we collect from you for the following purposes:

  1. Provide and manage our products, services and the Sites;
  2. Manage your investments;
  3. Send you promotional materials, newsletters and other communications;
  4. Create and manage your account;
  5. Communicate with you about, and administer your participation in, special events, programs, promotions, offers, surveys and market research;
  6. respond to your inquiries;
  7. Manage your employment application, assess your qualifications and manage your employment with us;
  8. Verify your information;
  9. perform data analyses (including market and consumer research, demographic analyses and anonymization and aggregation of personal information);
  10. operate, evaluate and improve our business (including developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; and performing accounting, auditing and other internal functions);
  11. protect against, identify and prevent fraud and other unlawful activity; and
  12. comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms and Conditions of Use;
  13. for other purposes required or authorized by law, including other purposes for which you have provided your consent.

As a general matter, we use the personal information we obtain to comply with applicable legal requirements, carry out our contractual obligations and pursue our legitimate interests (such as managing the Sites and our client relationships). Where required by applicable law, we obtain consent to process personal information. We also may use the personal information we obtain in other ways for which we provide specific notice at the time of collection.

4. Sharing Your Information

We do not disclose personal information we obtain about you through the Sites, except as described in this Privacy Policy. We may share your personal information with our affiliates and subsidiaries. We also may share personal information with service providers who perform services on our behalf based on our instructions.  We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.

We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities based on a lawful disclosure request, or (iii) when we believe 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. We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).

In addition, we may share anonymous, aggregate information with third parties, such as service providers, for any purpose.

Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the Privacy Policies of the providers of the plug-ins and widgets, and Shuttle is not responsible for those providers’ information practices.

THIRD PARTY SITES

The Sites may contain links to other websites, apps and features for your convenience and information. The fact that we link to a third party websites, apps or features is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third parties. Third party websites, apps and features may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites, apps and features follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the Privacy Policies or statements of the other websites, apps and features that you use.

HOW WE RESPOND TO LEGAL REQUESTS OR PREVENT HARM

We may access, preserve and share your information without notice or consent from you in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; or to prevent death or imminent bodily harm. For example, we may provide information to third-party partners about the reliability of your account to prevent fraud and abuse on and off of the Sites. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. We also may retain information from accounts disabled for violations of our terms for at least a year to prevent repeat abuse or other violations of our terms.

CHILDREN’S PRIVACY

Our Website is a general audience site, and we do not knowingly collect personal information from children under the age of 13. Should we learn that a child under 13 has provided us with personal information, we will delete that information from our database.

SECURING YOUR PERSONAL INFORMATION

We endeavor to safeguard personal information to ensure that information is kept private. However, please be aware that unauthorized entry or use, hardware or software failure, the inherent insecurity of the Internet and other factors, may compromise the security of your personal information at any time. As such, we cannot guarantee the security of your personal information.

USING SHUTTLE SERVICES FROM OUTSIDE THE UNITED STATES

If you are visiting the Sites from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. By using our services, you understand and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time at our sole discretion. When we make such changes, we will revise the “last updated” date at the top of this Privacy Policy. We recommend that you check this website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

YOUR RIGHTS AND CHOICES

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, ask us to remove your information from our mailing lists or to submit a request regarding your personal information, please contact us as indicated in the How To Contact Us section of this Privacy Policy.

To the extent provided by the law of your jurisdiction, you may (1) request access to the personal information we maintain about you; (2) request that we correct, amend, erase or restrict the information; or (3) exercise your right to data portability, by contacting us as indicated below. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response. Where provided by law, you may withdraw any consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

HOW TO CONTACT US

If you have any questions about this Privacy Policy, please contact us by email at [email protected].

APPENDIX A

List of Shuttle’s affiliates:

Shuttle Fund, LP
[545 5th Avenue, New York, NY 10017]

Shuttle Fund
[Harbour Place 2nd Floor, 103 South Church Street, Grand Cayman, KY1-1106]