Experience

Inner Circle Sports Privacy Notice

March 2016

Your Privacy Is Important To Inner Circle Sports

In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Inner Circle Sports (ICS) may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This Policy describes the types of personal information we may 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. As used throughout this policy, the term “ICS” refers to Inner Circle Sports, LLC.

The Sources of Information

The personal information we collect about you comes primarily from forms and materials you submit to ICS during the course of your relationship with us. We may also collect information about your transactions and experiences with ICS relating to the services you require, ICS may obtain additional information about you.

The Information We Have About You

If you deal with ICS in an individual capacity (e.g., as a private client), or as a settler/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 may collect about you would include:

• Your name, address and other contact details;
• Your 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;
• 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 may 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.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Our Use of Your Personal Information

We may use your personal information to:

• Administer, operate, facilitate and manage your relationship and/or involvement with ICS. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or involvement with ICS;
• Provide you with information, recommendations or advice concerning services offered by ICS; and
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with ICS ends, ICS will continue to treat your personal information, to the extent we retain it, as described in this Policy.

Disclosures of Your Personal Information to Third Parties

ICS does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services that may facilitate your transactions with ICS, including those that provide professional, legal, or accounting advice to ICS. Non-affiliated companies that assist ICS in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that ICS dictates.

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.

You should know that ICS will not sell your personal information.

Information Security: How We Protect Your Privacy

ICS is committed to implementing the highest standards of information security to protect the privacy and confidentiality of your personal information. We limit access to your personal information to authorized ICS employees or agents and, as described above in Disclosures of Your Personal information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.

Other Privacy Policies or Statements; Changes to Policy

This Policy provides a general statement of the ways in which ICS protects your personal information. You may, however, in connection with specific products or services offered by ICS, be provided with privacy policies or statements that supplement this Policy. This Policy may be changed from time to time to reflect changes in our practices concerning the collections and use of personal information. This version of the Policy is effective December 1, 2011.

Additional Information

If you require further information regarding our privacy policies and practices, please contact: