J E MOODY & COMPANY LLC
When J E Moody & Company LLC requests specific information from or regarding a client, it is so we might observe the relevant laws and regulations and best serve the specific client, and all information gathered in such a manner will be made available only to those members of the Company as may positively effect an investment to the benefit of the client. Specific information may include but is not limited to personal background information (e.g. nationality, residency), personal identification numbers (e.g. passport number), tax identification numbers, income level, investment experience and holdings and other information relevant to or required for assessing the appropriateness of an investment and to comply with regulations. All information gathered will be treated with utmost confidentiality, as long as the client is involved with the Company and thereafter. In order to guard our clients' nonpublic personal information, we maintain physical, electronic, and procedural safeguards that comply with regulatory standards
Only such information regarding individual clients as is required by regulatory authorities for the efficient and lawful management of client funds will be revealed. J E Moody & Company LLC does not share information regarding its clients with any other entity or group, except as may be required by law, for example to comply with a subpoena or request from a regulatory authority, or as is necessary for a non-affiliated third party service provider to assist us. Service providers include, but are not limited to, administrators, brokers, accountants, banks, legal counsel, directors, and tax preparers. These parties are not permitted to use client information for any purpose other than the provision of these services, and are obligated to keep such information confidential.
This notice sets forth the privacy practices of the Company with respect to the personal data of business contacts, including investors, of the Company (each, a "Client").
Data That May Be Collected
Company may collect certain personal data with respect to Clients, for example, contact information (such as name, postal and email address, and telephone number); date of birth; information about your transactions with Company, Company funds or Company affiliates; information about your assets, net worth, source of funds or credit history; signatures; copies of identification documents; bank account details; and other personal information you provide to Company, such as through emails, subscription documents or agreements and other onboarding documents (that may include Social Security numbers, tax ID numbers or other government-issued identification numbers, to the extent permitted by applicable law), and other forms and documents you provide or that are provided by others on your behalf.
Use of Personal Data
Company will use Clients' personal data in the course of business where it is in the Company's legitimate interests to contact Clients, and to: respond to Clients' requests; send information about Company and its affiliates that may be of interest to Clients; provide or manage Company services; create, manage and administer accounts you hold with Company or with a related investment product or fund; send Clients promotional and advertising materials, newsletters and other communications; tax reporting; verify your identity and conduct identity and background checks for anti-money laundering purposes where you or your related organization are applying for Company products or services; manage career opportunities, including for recruitment purposes (such as processing job applications and conducting background checks in accordance with applicable law), employee onboarding and other human resources purposes; perform data analyses (such as market and customer research); develop, manage and improve Company business, products and services; determine and manage the effectiveness of Company communications; perform accounting, auditing, billing and reconciliation activities and other internal functions; protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities; conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and Company policies and terms; and for other purposes required or authorized by law, including other purposes for which you have provided your consent.
The provision of personal data by Clients may be necessary in order for Company to provide that Client with the requested services and communicate with Clients where in Company's legitimate interests.
As a general matter, Company uses the personal information it obtains to comply with applicable legal requirements, carry out Company contractual obligations and pursue Company legitimate interests (such as managing Company Client relationships). Where required by applicable law, Company obtains consent to process personal information. Company also may use the personal information obtained in other ways for which Company provides specific notice at the time of collection.
Please note that you have a right to object to processing of your personal data where that processing is carried out for Company legitimate interest or for direct marketing.
Data Subject Rights
Under applicable EU data privacy laws, as a Client you may have a right to: (i) request access to and rectification or erasure of your personal data; (ii) obtain restriction of processing or to object to processing of your personal data; and (iii) the right to ask for a copy of your personal data to be provided to you, or to a third party, in a digital form. If you wish to exercise any of these rights you should contact firstname.lastname@example.org. You also have the right to lodge a complaint about the processing of your personal data with your local data protection authority.
Security and Retention
Company will take reasonable steps to protect Clients' personal data against loss or theft, as well as from unauthorized access, disclosure, duplication, use or modification, regardless of the format in which it is held. To the extent permitted by applicable law, Company retains personal information it obtains about you as long as: (i) it is needed for the purposes for which Company obtained it, in accordance with the provisions of this notice; or (ii) Company has another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data.
Disclosure to Certain Third Parties
Company does not sell or otherwise share personal information about you, except as described in this notice. Company shares the information with service providers who perform services on its behalf based on its instructions and record your information in one or more databases maintained by third parties in connection with the collection of data and communications and for legal or regulatory purposes, as described in this notice. Company does not authorize these service providers to use or disclose the information except as necessary to perform services on its behalf or comply with legal requirements. Examples of these service providers include fund administrators and entities that perform anti-money laundering testing services. In addition, Company may share your personal information with your authorized representatives.
Company also may disclose information about you (1) if Company is required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government entities based on a lawful disclosure request; (3) to establish, exercise or defend Company's legal rights; (4) when Company believes disclosure is necessary or appropriate to prevent harm or financial loss; (5) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (6) otherwise with your consent. Company reserves the right to transfer personal information it has about you in the event of a potential or actual sale or transfer of all or a portion of Company's business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution or liquidation).
Transfer of Personal Data Outside the EEA
Company may disclose Client personal data to other recipients located in countries outside of the EEA, including affiliates located in the United States, which may not have data privacy laws equivalent to those in the EEA. By submitting your personal data to Company, each Client consents to the transfer of their personal data to Company and the other recipients described in this notice that are located in countries outside of the EEA. Clients may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
This notice and the policies described in this notice may be updated periodically and without prior notice to you to reflect changes in Company's privacy practices or in applicable law, rules or regulations.