Privacy Policy
ANNUAL PRIVACY NOTICE
This U.S. Privacy Notice describes the policies of Contour Asset Management, LLC (“Contour”) with respect to the non-public personal information (“Information”) of its clients, prospective clients, and former clients (the “Clients”) and investors, prospective investors, and former investors (collectively, with the Clients, the “Investors”) in the funds (the “Funds”) to which Contour provides investment advisory services. These policies apply to individuals only.
Personal information collected
In the course of its investment advisory services, Contour receives and maintains nonpublic personal information about Investors including, but not limited to, the below listed types of Information. Contour has collected the following categories of personal information from Investors within the past twelve months:
- Information in correspondence, subscription documents and other forms which Investors complete and submit to Contour. This includes (but is not limited to):
- names,
- addresses,
- phone numbers,
- social security numbers or other relevant government issued identifiers,
- nationality, citizenships
- employment, and
- commercial and financial and source of wealth information.
- Information relating to the value of an Investor’s interests in the Funds.
- Information relating to an Investor’s transactions with Contour and its affiliates, with and through the Funds, including subscriptions and redemptions.
- Information about the bank and brokerage accounts of an Investor received from such Investor’s purchaser representative, financial advisor, investment consultant or other financial institution with whom the Funds have a relationship and/or whom the Investor may have authorized to provide such Information to the Funds.
Purpose for processing personal information
Contour may use or disclose the personal information it collects for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we will use that information to provide that service to you. We may also save your information to facilitate future communications and services.
- To identify and verify the Investor in the Funds
- To comply with state and federal law and regulation, which include but are not limited to, Anti-Money Laundering and Know Your Customer checks for financial fraud prevention
- To assist the Fund Administrator to administer and operate the Funds
- To assist the Contour in its reporting obligations to Investors
- To process your requests, transactions, and payments and prevent transactional fraud
Disclosure of personal information
We may disclose your personal information to a third party for a business or commercial purpose. When we disclose personal information for a business or commercial purpose, we make efforts to ensure the recipient will both keep that personal information confidential and not use it for any purpose except performing the contract.
For example, Contour may disclose Information about Investors as may be reasonably necessary or appropriate in connection with the management of client and investor accounts or as required by law or any applicable regulatory authority, such as to demonstrate compliance with state or federal laws or regulations, or as otherwise directed in writing by an Investor.
Personal information may be shared with the following recipients:
- Third party service providers to the Funds, including fund administrators, accountants, auditors, and primer brokers.
- Contour service providers such as attorneys, auditors, and other professionals.
- Unaffiliated third parties who perform marketing services on behalf of the Funds or with whom Contour has entered into joint marketing agreements for services or information about services that you have requested, including placement agents and brokers.
- Persons acting in a fiduciary or representative capacity on behalf of an individual investor, such as an IRA custodian, Financial Advisor, or Trustee of a grantor trust.
- Government, legal regulatory or other authorities under applicable laws.
In the preceding twelve months, Contour has disclosed the personal information it collects listed above for a business or commercial purpose. In the preceding twelve months, Contour has not sold personal information.
Storage and security of personal information
Contour restricts access to Information about you to those of our employees and agents and representatives, who need to know the Information to enable us to provide our services to our Investors.
Contour also maintains appropriate physical, electronic and procedural safeguards designed to protect Investor Information and to prevent unauthorized disclosure of such Information.
When it is necessary for Contour to share your personal Information with other parties, Contour requires (i) that such parties agree to protect the confidentiality of that Information and (ii) that such Information be used solely for the limited purpose for which Contour discloses the Information to them. Contour will advise these parties not to further share your Information with others except to fulfill that limited purpose.
Investors’ Privacy rights in relation to Personal Information
- You may send requests for correction to: Alpa Rana, Chief Financial Officer and Chief Compliance Officer, who can be contacted at Privacy@contourasset.com or at +1 646 553 2490.
- You may also request that we update or delete certain of your Information, subject to some conditions, by contacting us at Privacy@contourasset.com. We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any Information. Your right to delete your Information is subject to our records retention policies and applicable law.
- You may also limit use of your Information to prevent Contour from sharing Information with non-affiliates who may use it to market to you. Currently, Contour does not share Information with any non-affiliates for this purpose.
- You have the right to request access to the personal information we hold about you
- You have the right to data portability and to request the transmission of personal information about them to another organization
- You have the right to object to automated decision making technology that materially impacts you. Contour does utilize this technology.
- If Contour receives a request to delete your personal Information, Contour may be prevented from doing so if that personal Information is retained to meet legal or regulatory requirements.
- You cannot limit the Information Contour shares to respond to court orders and legal investigations. It may be necessary, under anti-money laundering and similar laws, to disclose Information about Investors in order for the Funds to accept subscriptions from them.
- If you exercise your privacy right, Contour will not discriminate against you.
Opt In and Opt Out
You may have the right to opt in to or opt out of certain of our uses and disclosures of your Information. For example, when you are asked to provide Information, you may have the opportunity to elect to, or not to receive messages from us by e-mail. You may tell us that you do not want to receive our promotional messages, or that you do not want us to share your Information with third parties for their marketing purposes by sending us your name, address, e-mail, and phone number to:
Alpa Rana, Chief Financial Officer and Chief Compliance Officer, can be contacted at Privacy@contourasset.com or at 646-553-2490.
Please indicate whether you are asking us to stop sharing your Information with third parties, or if you are writing to request that you no longer receive a particular media notification from us. Please understand that it may take us a few days to process any opt out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions, and communications with us. Also, to stop receiving promotional messages from third parties who already have your contact information, please contact them directly.
CCPA Specific Rights
Under the California Consumer Privacy Act (“CCPA”), California residents have specific rights regarding their personal information. If you are a California resident, this section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Contour disclose certain information to you about our collection and use of your personal information over the past twelve months. Once Contour receives and confirms your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Contour does not provide these access and data portability rights for business to business personal information.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We do not provide these deletion rights for B2B personal information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at +1 646 553 2496
- Emailing at Privacy@contourasset.com
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Amendments to Privacy policy
Contour will continue to follow privacy procedures relating to retention, handling, and dispositions of our records, including with respect to your Information. Contour reserves the right to modify this U.S. Privacy Policy at any time and without prior notice.
Questions?
If you have any questions in relation to this U.S. Privacy Policy, please contact:
Contour Asset Management LLC99 Park Avenue, Suite 1540
New York, NY 10016
Attention: Alpa Rana, Chief Financial Officer and Chief Compliance Officer
Phone: +1 646 553 2490.
Email: Privacy@contourasset.com
Contour takes its responsibility to protect the privacy and confidentiality of your Information very seriously. If Contour materially changes its privacy policies to permit it or its affiliates to share additional information Contour has about you or to permit disclosures to additional types of parties, you will be notified in advance, and, if required by law, you will be given the opportunity to consent to such disclosure, as appropriate, or opt out of such additional disclosure and to direct Contour not to share your Information with such parties.
Last Updated:
David Meyer, CFA
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Nikhil Berry,
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Todd Cohen, CFA
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Vanessa Hernandez,
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David Reison,
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Michael Tabaksblat,
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