Privacy Policy

Introduction

Cambridge Associates, LLC and its affiliates (collectively referred to as “Cambridge Associates” herein) provide discretionary and non-discretionary portfolio management investment services, independent research and performance monitoring to non-profit institutions, family offices, corporate and public pension funds, public authorities and sovereign wealth funds.  Cambridge Associates and its employees place a high priority on protecting sensitive personal and financial information.  We do not disclose clients’ confidential information, or that of former clients, except as permitted by you or required by law.

What type of personal data do we collect and where do we get it from?

We may collect nonpublic personal information about you from your discussions with us, from legal documents, from information you supply about your investments or portfolio, from your incoming wire transfers or invoice payments, and from applications and other forms completed by you or provided to us by your authorized representatives and other fiduciaries.  We may also collect personal data from email correspondence, telephone calls, paper communications, social media, our own websites and online platforms, visiting our offices, enquiring about or buying products or services from us, providing products or services to us and trade events such as conferences or exhibitions.  This information may include contact details, biographical data, income, transaction history, assets, risk tolerance, wire transfer instructions, banking details, and tax, identification, social security, and account numbers, as well as information on your investment assets.  For those visiting our websites, online platforms or engaging us through social media, we may collect information relating to IP addresses, social media handles and usernames.

How do we collect personal information?

We may collect and process information that you provide during your correspondence with us. This could include, but is not limited to, any of the following ways:

How do we use personal information?

Unless expressly agreed otherwise, we may disclose the information described above to custodians, fund administrators, investment managers, venture capital and private equity fund managers, and other nonaffiliated companies or individuals, such as legal, audit, and tax advisors, in the manner and to the extent permitted by you or as required by law.  We may also disclose the information described above to other nonaffiliated service providers, such as providers of reporting data, data storage and fund monitoring services for our everyday business purposes in supporting our provision of services.  We may also share your personal data with marketing agencies who help us promote ourselves or deliver our services, as well as printer/email service providers or other suppliers who help us to send our newsletters and communications.  We require third parties to respect the security of your data and to treat it in accordance with the law. We will share your personal information with third parties where required by law.

Our affiliates may also use nonpublic personal information about you to determine eligibility for services and to make marketing solicitations.  This information is only provided with the understanding that it will be maintained in confidence.  To opt out of affiliate use of your personal information for eligibility or marketing solicitation, please send such request to the Chief Compliance Officer (details below).

International Transfer of Data

Cambridge Associates may send your data outside the jurisdiction from which it originated or was collected.  Where personal data is transferred or accessed outside of a specific jurisdiction, we require that appropriate safeguards are in place to comply with any applicable data protection regulations.

Your choices in relation to personal information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.   You also have rights and choices which you can exercise with respect to the data we hold on you.  You have the right to:

Retention and destruction of personal information

We take reasonable steps to ensure the accuracy of the information we hold about you. We will not use your personal information unless it is (to our knowledge) accurate and up to date.  We typically will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.  When the purposes for which we have collected the data for have ended we will retain and securely destroy your personal information in accordance with our policy, applicable laws and regulations.

Security

Unfortunately, the transmission of data over the internet is not completely secure.  Although we will use our reasonable commercial efforts to protect your personal information, we cannot guarantee its security.  Once we have received your data we will use strict security measures to try to protect it against loss, misuse, unauthorized alterations or interception when transferred electronically.  All clients who access performance data and other investment information from our website receive unique login and password identifiers.  The firm maintains physical, electronic and procedural safeguards including the use of encryption technologies to protect your confidential information.

Changes

We may change the terms of this Privacy Policy from time to time.  You may find a current version of this policy posted on our website at www.cambridgeassociates.com.

Contact Information

For further details about our privacy policy, please contact:

Sean F. Hanna
Chief Compliance Officer and Senior Counsel
125 High Street
Oliver Street Tower
Boston, MA 02110

Tel.  +1 (617) 457 7518
Fax  +1 (617) 457 7501

email:  privacy@cambridgeassociates.com

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