PRIVACY POLICY | Pluribus Labs

This notice is being sent to you by and on behalf of Pluribus Labs LLC and its affiliated management entities and funds (“Pluribus”, “we”, or “our”) in connection with your use of our website.

Pluribus is committed to handling your information responsibly and consistent with privacy rights. This Privacy Notice describes how we collect, use and share the personal data that we gather.

How We Collect and Use Personal Data

We generally collect all or most of the following categories of personal data:

Contact information: name, address, email, telephone number
Identification information: signature, date of birth, social security number, taxpayer identification number, driver’s license, passport, other government identification and numbers
Background information: information revealed in know-your-customer (KYC) and anti-money laundering (AML) due diligence, investor accreditation and consents
Financial information: assets, income, net worth, amounts and types of investments, capital account balances, capital commitments, capital contributions, account data, other investment participation information, funds transfer information, beneficiaries, positions, percentages of fund, share or option numbers and values, vesting information, investment history, transaction information, tax information
Cookies: Our website uses “cookies”, which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of our website. The data identifies you as a unique user and facilitates your ongoing access to and use of our website. Cookies also help us diagnose problems with our server and the website. If you don't want us to use cookies when you use our website, you can adjust your internet browser settings not to accept cookies. Your web browser's help function should tell you how to do this. Alternatively, to find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit the website: http://www.allaboutcookies.org. Our website will also explain how you can delete cookies which are already stored on your device. However, without these identifier files you may not have access to many features that may make your browsing of our website smoother, and some of our services may not function properly. Our website does not respond to “Do Not Track” signals.

We collect this personal data from:

forms you complete, such as subscription agreements, investor questionnaires, applications or other forms;
your correspondences (written, telephonic, voicemails or electronic);
your transactions with us or others;
third party service providers (e.g., background screening, investor placement, or public databases) who perform services on our behalf or verify or supplement our information; and
our website, including registration information and any information captured via cookies.

We collect this personal data for the purposes of and pursuant to the legal bases of contract performance, legal compliance, and legitimate interests. These include:

Complying with legal or regulatory obligations, such as our obligations regarding KYC and AML, as well as for tax purposes.
Performing a contract with you or to take steps at your request before entering into a contract.
Other legitimate business interests, such as:
- For our everyday business purposes — such as to process your transactions, maintain or service your account(s), communicate with you, pay funds, manage records, respond to court orders and legal investigations, and administer and provide services to you, including onboarding, marketing, research and due diligence.
- For our marketing purposes — to offer our services to you, to improve and customize our services for you and to understand how our services are used.
- For our risk mitigation purposes — to protect against fraud and security risks, including through background screening.

In some cases, we rely on your consent for processing your personal data, but only in those cases where we specifically ask for your consent.

E-Mail Communications and Marketing

Occasionally, we may send you e-mail communications with information that may be useful to you, including information about our products and services. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional e-mails from us. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing or market research communications from us, or would like to stop processing your personal information in any other way, you can contact us as described below to let us know what types of communications you wish to stop receiving.

How We Share and Disclose Personal Data

We may share your personal data with:

any successor to us, all or part of our business or our affiliates or to all or part of any of our private investments fund(s) for their ordinary business purposes and uses that are consistent with this Privacy Notice (but not for their marketing purposes);
legal or government regulatory authorities as required in connection with legal or regulatory matters, including in connection with background screens, claims, disputes or litigation, or if we determine disclosure is necessary to enforce our legal rights or contractual commitments;
service providers who, on our behalf or for your benefit, provide services to Pluribus;
employees and service providers who have a reasonable need to know the information in connection with the conduct of Pluribus’ business as an investment advisor; and
third parties to which you request or authorize us to disclose your personal data.

If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties, you may opt out of those disclosures, that is, you may direct us not to make those disclosures (other than disclosures permitted by law). If you wish to opt out of disclosures to nonaffiliated third parties, you may contact us at info@pluribuslabs.com. If you do not send such a request before you terminate your relationship with us, we may continue to share your information with third parties in accordance with this policy.

We do not sell your personal data.

Safeguards

We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your personal data in our possession or under our control from unauthorized access and use. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Unfortunately, no data transmission or storage system can always be guaranteed to be secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

We retain personal data pursuant to our records retention program, for as long as is necessary for the purposes set out in this Privacy Notice, unless a longer period is required or permitted under applicable law or is needed to resolve disputes or protect our legal rights. We maintain personal data of our former investors and apply the same policies that apply to current investors.

Children’s Personal Information

Our website is not directed to children under the age of thirteen, and we do not knowingly collect personal information from children under the age of thirteen. If we discover that we inadvertently collected information from a child under the age of thirteen, we will promptly delete it.

Updates to the Privacy Notice

Pluribus may change this Privacy Notice from time to time, and at Pluribus’ sole discretion. Upon any material change to this policy, Pluribus will provide a notice to investors to inform them what kinds of personal data the firm collects and the circumstances in which that information may be disclosed to third parties.

Additional Region-Specific Disclosures

If you live in the European Economic Area (“EEA”), or other jurisdictions, including Andorra, Argentina, Australia, Canada, Cayman, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, Uruguay, and certain other jurisdictions, or invest in Pluribus’ Cayman Islands funds, the following additional disclosures apply to any personal data that we process subject to relevant data protection legislation, including the EU’s General Data Protection Regulation.

International Data Transfers

Your personal data may be transferred to, stored, and processed in a country other than the one in which it was collected. We may transfer your personal data outside the EEA, including to the United States, and when we do so, we rely on appropriate or suitable safeguards recognized under data protection laws, including:

using Standard Contractual Clauses when transferring personal data from a country in the EEA to a country outside the EEA, including the United States;
obtaining your consent to transfer personal data outside the EEA after first informing you about the possible risks of such a transfer;
when the transfer is necessary for the performance of a contract between you and Pluribus, or if the transfer is necessary for the performance of a contract between Pluribus and a third party, and the contract was entered into in your interest; and
when the transfer is necessary to establish, exercise or defend legal claims or to protect your vital interests.

Data Subject Rights

If you live in one of the jurisdictions listed above, or invest in Pluribus' Cayman Islands funds, you may have certain data subject rights. These rights vary, but they may include the right to:

request access to and rectify or erase your personal data that we hold, restrict or object to certain processing of your data by us, or request transfer of appropriate data to a third party where this is technically feasible;
request whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and of the possible consequences of failure to provide such personal data; and
the information on the recipients or categories of recipients with whom we share your personal data, which we have provided.

You can exercise these rights by contacting us at info@pluribuslabs.com. We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all rights available to us at law in this regard.

Additionally, in the circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. If you decline to provide or consent to our use of the data and we are relying on consent as the legal basis for its processing, there are circumstances in which we will not be able to provide you with services or take action on your behalf.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so in law. If you wish to withdraw any consent given for processing, please contact us at info@pluribuslabs.com.

In the event that you have a complaint that is not resolved by us to your satisfaction, you may refer the matter to your local data protection authority in the EEA.

California-Specific Disclosures

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year.
If you are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, the following additional disclosures apply to any personal data that we process subject to the California Consumer Privacy Act of 2018 (the “CCPA”).
California residents have a right to:
- request disclosure of your personal data that we hold from the past 12-month period, including your specific information as listed under How We Collect and Use Personal Data and How We Share and Disclose Personal Data
- request deletion of your personal data that we hold from the past 12-month period, provided that the data is not required by Pluribus to complete a transaction or enable internal uses within the context of our ongoing business relationship with you, to provide security, prevent fraud, and repair errors, or to comply with applicable laws or regulations
California residents can exercise these rights by contacting us at 415-767-1118 or at info@pluribuslabs.com. We will review your requests and respond accordingly within the time required by law. The rights described herein are not absolute and we reserve all rights available to us at law in this regard. You will not have to pay a fee for the disclosure of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for disclosure is manifestly unfounded or excessive. We will not provide disclosure of your personal data more than twice in any 12-month period.
Individuals who submit requests for access or erasure of personal information will be required to verify their identity by answering certain questions. We will not disclose or delete any information until such individual’s identity is verified.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.
Agents who make requests on behalf of individuals will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.

We will not discriminate on the basis that you have exercised any of your rights under the CCPA. Pluribus takes very seriously any inquiries we receive about our privacy practices and our compliance with the CCPA, and we will ensure that all inquiries are handled in accordance with the CCPA’s requirements. Where CCPA requests are submitted to us, we will only use the information supplied to us to verify the request and any subsequent issues.

Cross Border Transfers of Data

The data that we collect from you may be transferred to, and stored in, a country (a “non-equivalent country”) not considered to have adequate data protection laws pursuant to data protection laws that apply to Pluribus or to a Pluribus fund in which you are invested. Personal data may also be processed by staff operating in a non-equivalent country who work for us or for one of our service providers. Such staff may be engaged in, among other things, the forming and operating our private investment funds for our investors and the provision of administration and support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice and applicable data protection laws.

Further Information

The examples contained within this notice are illustrations only and are not intended to be exclusive. This notice is intended to comply with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and the Data Protection Law, 2017 of the Cayman Islands. You may have additional rights under other foreign or domestic laws that may apply to you.

If you have any questions, comments, requests or concerns about this Privacy Notice or other privacy-related matters, please contact

Pluribus Labs LLC
One Embarcadero Center, Suite 2110
San Francisco, CA 94111
+1 (415) 767-1118

info@pluribuslabs.com