The California Consumer Privacy Act (CCPA) imposes certain obligations on the Atalaya Capital Management LP, together with its subsidiaries and affiliated companies (together, “Atalaya,” “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about our privacy practices surrounding how and why we collect, use, disclose and share personal information and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Notice at Collection and Use of Personal Information
Information We Collect
Depending on how you interact with us, we may collect certain categories of personal information from or about a California Resident, including:
- identifiers and similar information such as, name, address, date of birth, email address, social security number, driver’s license number, passport number, online identifiers or other similar identifiers;
- additional information subject to Cal. Civ. Code § 1798.80(e), such as your education, credit card number, state identification card number, signature, bank account, or other financial information;
- characteristics of protected classifications under certain federal or state laws, including, gender, national origin, or marital status;
- commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth;
- audio (e.g., voicemail), electronic, visual or similar information;
- internet or other electronic network activity information, including interactions with our website or use of certain online tools;
- professional or employment-related information, including occupation, compensation, employer, and title; and
- inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds.
How We Use Collected Information
We may use your personal information for our business or commercial purposes, such as but not limited to:
- performing services on behalf of a fund, including maintaining or servicing accounts, providing investor relations services, processing subscriptions, and withdrawals; verifying information, processing payments or providing similar services;
- performing our contractual obligations to a California Resident as a subscriber to a fund, including providing updates on a fund’s performance, providing tax reporting and other operational matters;
- detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks; and
- enabling or effecting commercial transactions, including, using bank account details to remit funds and process distributions.
Our Collection, Use, Disclosure, and Sharing of Personal Information
Information We Have Collected
In the preceding 12 months, and depending on how you interact with us, we may have collected the categories of personal information listed above in the “Information We Collect” here.
Sources of Personal Information
We may collect personal information about you directly from you and/or your intermediaries through sources such as:
- account applications, subscription agreements, and other forms or related documentation;
- written, electronic, or verbal correspondence with us or our service providers;
- investor transactions;
- an investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or
- from information captured on applicable websites.
In addition, we may collect personal information from different sources, such as:
- our affiliates, our service providers, or our affiliates’ service providers;
- public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or
- from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.
Purposes for Collecting Personal Information
We may collect your personal information for the business or commercial purposes described above in the “How We Use Collected Information” here.
Our Disclosure and Sharing of Personal Information
We do not sell your personal information. In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as described in the following chart:
|Category of Personal Information||Category of Third Party|
In addition, in the preceding 12 months, we may have disclosed for a business purpose all of the categories of personal information identified in “Information We Collect” above, to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law.
We may also share your personal information with our service providers such as our administrator, IT providers, email providers or CRM provider, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by, the CCPA. We also may disclose personal information about you or your accounts to a third party at your request or direction or with your consent.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); and (v) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting the personal information; (d) the categories of third parties to which we disclosed personal information about you for a business purpose; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.
How to Submit a Request under the CCPA
You may submit a Request to Know, as described above, through the following telephone number 212-201-1910 or email email@example.com. You may submit a Request to Delete, as described above, through the same two methods.
We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your authorized agent. When you submit a Request to Know or Request to Delete, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
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