Privacy Policy

At Genesis Assets LLC we respect your privacy and are committed to keeping your personal data secure. This notice (the “Privacy Notice”) explains how we use the personal data that Genesis Assets LLC collects or is provided to Genesis Assets LLC.
 

“Genesis Assets”, “we” or “us” means Genesis Assets LLC with its registered office at Hunkins Waterfront Plaza, Suite 556, Main Street, Charlestown, Nevis, or any of its subsidiaries, affiliates, and other companies in the Genesis Assets group (the “Genesis Assets Group”) or any fund sponsored by a member of the Genesis Assets Group (a “Genesis Assets Fund”) together (“Genesis Assets”).
 

This Privacy Notice is directed to individuals whose personal data we or our third-party processors handle in the course of carrying on our commercial activities, including a client of Genesis Assets or an investor in any Genesis Assets Fund, or a member, partner, trustee, shareholder, beneficial owner, officer, director, employee, or other representatives of any client of Genesis Assets or of any investor in any Genesis Assets Fund, including any prospective client or investor (“you”).
 

The name of the specific Genesis Assets entity which processes your personal data will depend on which of our services you use. We’ll let you know which entity you have a relationship with when you invest with us.
 

More information about the companies making up Genesis Assets is provided on our website and you can find out more at www.genesisassets.ca.
 

Genesis Assets LLC is appointed as Nevis representatives in relation to data protection issues for those Genesis Assets Group companies that are located outside of Nevis. Where you would like to contact a Genesis Assets Group organization located outside of Nevis, you may contact the representative in the manner detailed in the “Contacting Us” section below instead of, or in addition to, directly contacting the Genesis Assets Group organization located outside of Nevis.
 

ABOUT THIS PRIVACY NOTICE This Privacy Notice governs the handling of personal data by Genesis Assets in the course of carrying out our investment management and related activities.
 

Genesis Assets is responsible for ensuring that we use your personal data in compliance with applicable data protection law. This Privacy Notice sets out the basis on which any personal data about you will be processed by us.
 

PERSONAL DATA THAT WE COLLECT AND PROCESS ABOUT YOU Information that you provide to Genesis Assets. This includes information about you that you provide to us. The nature of our relationship with you will determine the kind of personal data we might ask for, though such information may include (by way of a non-exhaustive list):
 

• Basic personal data such as name, address, employment/position in the company, company name, company email address, business phone number, business address; and
   

• Sensitive personal data such as information we handle about your nationality, place of birth, health-related information, disability status, or details of political affiliations.
   

Information that we collect or generate about you. This includes:
 

• Files that we may produce as a record of our relationship with our clients and prospective clients, including contact history;
   

• Any personal data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service, and in order to comply with our legal and regulatory requirements; and
   

• Details about your use of Genesis Assets websites which may include internet browser history, IP addresses, and access to application forms.
   

Information that we obtain from other sources. This includes:
 

• Information from publicly available sources (including third-party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers, and records such as Companies House and the FCA Register; and other publicly accessible sources);
   

• Information obtained from the transfer agents or administrators of Genesis Assets Funds distributors or financial intermediaries, platforms, professional advisers including consultants, lawyers and tax advisers, product providers, event organizers, and other agents and/or representatives; and
   

• Information obtained from sanctions checking and background screening providers.
   

USES OF YOUR PERSONAL DATA Your personal data may be stored and processed by us in the following ways and for the following purposes:
 

• To manage your relationship and/or account with Genesis Assets;
   

• To assess clients’ and prospective clients’ applications or contracts for Genesis Assets products and services;
   

• To keep our records up to date;
   

• For ongoing review and improvement of the information provided on Genesis Assets websites to ensure they are user-friendly and to prevent any potential disruptions or cyber-attacks;
   

• To monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
   

• To communicate with clients and prospective clients in order to provide services or information about Genesis Assets and other Genesis Assets products and services;
   

• To effectively manage and strengthen client and prospective client relationships, understand the client and prospective client needs and interests and learn more about our clients and prospective clients in order to develop, improve and manage the products and services we can offer;
   

• For the management and administration of Genesis Assets' business; or
   

• In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.
   

We may use your personal data in these ways for a variety of reasons. These include:
 

• We are performing our contractual obligations;
   

• We have obtained your consent;
   

• We have legal and regulatory obligations that we have to discharge;
   

• We may need to in order to establish, exercise, or defend our legal rights or for the purpose of legal proceedings; or
   

• The use of your personal data as described is necessary for our legitimate business interests, such as:
   

• Allowing us to effectively and efficiently manage and administer the operation of our business;
   

• Maintaining compliance with internal policies and procedures; and
   

• Enabling quick and easy access to information on Genesis Assets products.
   

DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES We may share your personal data within the Genesis Assets Group for the purposes described above.

We may also share your personal data outside of the Genesis Assets Group as further described below:
 

• With our business partners who will be subject to appropriate data protection obligations;
   

• With representatives, agents, custodians, intermediaries, and/or other third-party product providers appointed by the client or prospective client (such as accountants and professional advisors);
   

• With third-party agents and contractors for the purposes of them providing services both to us (for example, Genesis Assets' accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies) and to clients or prospective clients. These third parties will be subject to appropriate data protection obligations; and
   

• To the extent required by law or regulation, for example, if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend our legal rights.
   

INTERNATIONAL TRANSFERS OF PERSONAL DATA Genesis Assets is a global business and as a result, we or our third-party processors collect and transfer personal data globally and may transfer your personal data to locations outside of your country. Your personal data may also be processed by individuals operating outside your country who work for Genesis Assets or for one of our vendors.
 

Where Genesis Assets transfers your personal data to another country it is required to do so in a manner consistent with legal requirements. In relation to data being transferred outside of the Nevis Economic Area, for example, this may be done in one of the following ways:

• The country to which we send your personal data might be approved by the Nevis Commission as offering an adequate level of protection for personal data;
   

• The recipient might have signed up to a contract based on “model contractual clauses” approved by the Nevis Commission, obliging it to protect your personal data;
   

• Where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
   

• In other circumstances, the law may permit us to otherwise transfer your personal data outside of Nevis.
   

You can obtain more details of the protection given to your personal data when we transfer it outside Nevis (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in the “Contacting Us” section below.
 

SECURITY OF PERSONAL DATA Genesis Assets has extensive controls in place to maintain the security of personal data. As a condition of employment, Genesis Assets employees are required to follow all applicable laws and regulations, including in relation to data protection law. The unauthorized use or disclosure of confidential client information by a Genesis Assets employee is prohibited and may result in disciplinary measures.
 

RETENTION OF PERSONAL DATA How long we hold your personal data will vary. The retention period will be determined by the following:
 

• The purpose for which we are using your personal data – we will need to keep the data for as long as is necessary for that purpose; and
   

• Legal obligations – laws or regulations may set a minimum period for which we have to keep your personal data.