The personal data we collect
Investors, Service Providers and Business Contacts
We collect personal data from current and prospective investors, service providers and business contacts, such as your name, residential address, place of business, email address, place of birth, date of birth, telephone number, copies of photo identification (e.g., passports, driver’s license, etc.), utility bills, social security or other tax identification number, account details and numbers, specimen signature, criminal history, assets, employment and education history, source of wealth, transactions, investment activity and/or income information. Much of this personal data is collected when you: (i) provide it to us in a subscription agreement and related documents; (ii) provide it to us in correspondence and conversations with Hitchwood representatives; or (iii) otherwise transact with us, such as when you invest in one of our advised funds, tell us where to send money or make a wire transfer. We may also collect your personal data from other sources, such as credit bureaus, investor databases, clearinghouses, data brokers, fraud databases, social media platforms, research vendors, other websites, our affiliates or other companies and other publicly available sources such as company websites. We may combine the personal data we receive from these other sources with the personal data that we collect from you. If you are a corporate or institutional investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal data regarding individuals connected to you for any reason in relation to your investment with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.
We may also collect your personal data when you email us. For example, at times, visitors to our website may choose to email individuals at Hitchwood using links available on our website. In such instances, your email address, address, phone number and other contact information contained in your email, as well as any other information you choose to provide in that email may be collected as part of the process of sending the email to us in order to enable us to reply to those emails.
How we use your personal data
We and our service providers use your personal data for various purposes depending on the type of information we have collected from you and about you, in order to:
How we share your personal data
We may share or disclose your personal data in the following ways:
Affiliates and Subsidiaries. We may share your personal data with our affiliates and subsidiaries, including, but not limited to, affiliated management entities and general partners to deliver our services, ensure a consistent level of service, enhance our products, services and your customer experience, and for our affiliates’ everyday business purposes.
With Your Consent. We may share or disclose your personal data if you direct us to do so.
Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information, including personal data, may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address and other personal data) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
Aggregate/Anonymous Information. From time to time, we may share aggregate and/or anonymous information about you. The sharing of such data is unrestricted.
Legal bases for use of your personal data
You are responsible for the use and security of your password
The password-protected areas of our website are established for investors and their representatives only. If you wish to access the password-protected areas of our website, you will need to apply for a password. If you apply for a password to access password-restricted areas on our website, you must provide us with your name, mailing address, email address, phone number, investor affiliation and other relevant information, in addition to the information you have provided to us as an investor (if applicable).
You are responsible for all actions taken with your username and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your username or password to access or use any part of our website. If your password has been compromised for any reason, you should contact us immediately for a new password.
You can review and change the information that you submit to us, such as your User ID, email address, contact information, other personal data and user preferences, by emailing firstname.lastname@example.org. You must promptly update your personal data if it changes or is inaccurate.
On your request, we will deactivate your password and remove your contact information and financial information from our active databases. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy.
How long we keep personal data
Our services and websites are not intended for persons under the age of 18 and persons under the age of 18 are not eligible to use our website or our services. If we become aware that we have collected personal data from a person under the age of 18, we will take reasonable steps to delete such information as soon as possible and will not sell that information to third parties.
Hitchwood Capital Management LP, located at 640 Fifth Avenue, 22nd Floor, New York, NY 10019 is the data controller for your personal data. If you are an investor in Hitchwood Capital Fund Ltd., Hitchwood Capital Master Fund LP or Hitchwood Capital Partners LP, the respective fund in which you are invested will also act as a data controller for your personal data. Each of the funds can also be reached care of Hitchwood Capital Management LP at 640 Fifth Avenue, 22nd Floor, New York, NY 10019.
Processing of personal data in and outside the United States and the Cayman Islands
Data subject rights and your choices
If you are located in the European Economic Area (“EEA”) or in the United Kingdom (“UK”), permanently reside in the state of California or are a domiciliary of California residing in another jurisdiction for a temporary or transitory purpose, you have certain legal rights with respect to your personal data as described below:
If you are located in the EEA or in the UK, you have certain additional legal rights with respect to your personal data as described below:
The DPL provides for broadly analogous rights.
As we do not process personal data on a large scale, we are not required to designate a data protection officer. However, should you have any queries or wish to discuss your data protection rights with us, please contact Hitchwood’s Chief Compliance Officer at (212) 373-1213 or email@example.com. For consumers with disabilities who need to access this policy in an alternative format, please contact Hitchwood’s Chief Compliance Officer using the above information.