Privacy Policy – Panoptic Fund Administration

Panoptic Fund Administration Privacy Notice, Updated 8/15/2023

GENERAL PRIVACY NOTICE (“Notice”). It is Panoptic Fund Administration’s ( “we”, “us” or “our”) policy to maintain the confidentiality and security of personal information (“Personal Information”) that we collect, maintain and utilize in serving the needs of our clients (“Clients”, “you” or “your”). This Notice describes how we collect, hold, use and disclose Personal Information that you provide, is provided on your behalf, or is collected by us.

CATEGORY OF PERSONAL INFORMATION COLLECTED:
Identifiers: Names, Phone Numbers, Postal Addresses, Email Addresses, Passport Numbers, Drivers License Numbers, Tax Identification Numbers, Social Security Numbers
Business Purpose for Collection of Personal Information: Carrying out the tasks of administering funds: including conducting calculation value of assets, preparing balance sheets, preparing account statements, maintaining accurate records, compliance with laws and regulations, and supporting annual audits

INFORMATION WE COLLECT. We collect several types of Personal Information to enable us to provide you with exceptional service or to perform our designated tasks under an agreement with you, which may include (depending on whether you are an institution or an individual):We collect your Personal Information in various ways, including:

Information you provide to us in connection with your administrator activities, including information you provide as part of our due diligence inquiries or pursuant to other periodic correspondence, whether in writing, electronically, or orally;
Information from third parties obtained via client acceptance procedures;
Information obtained from your service providers that you authorize to interact with us on your behalf; and
Information obtained from publicly available sources.

INFORMATION WE SHARE. We do not sell your Personal Information and we do not generally disclose it to anyone except:

As necessary to carry out Panoptic’s management, administration and processing of, and reporting on, the activities and transactions of the investment fund or account in which you are invested, including, for example, but not necessarily limited to, Panoptic’s and/or the respective investment fund’s or account’s administrators, custodians, prime brokers, tax advisors, legal advisors, independent auditors, contractors and service providers;
Governmental agencies as required by law or regulation, including, but not limited to, the U.S. Securities and Exchange Commission and the U.S. Internal Revenue Service;
At your request (for example, by sending duplicate account statements to someone you designate); or
As otherwise permitted or required by

Employees are prohibited, either during or after termination of their employment, from disclosing Personal Information to any person or entity outside Panoptic, including family members, except under the circumstances described above. An employee is permitted to disclose Personal Information only to such other employees who need to have access to such information to deliver our services to the client or investor.

This list of possible disclosures is not intended to be exhaustive and there may be other legitimate purposes for holding, disclosing, or otherwise processing your Personal Information. Where the law so requires, you will be notified of any additional purposes and where required your consent will be sought.

RETENTION AND DISPOSAL OF INFORMATION. To meet our legal and regulatory obligations, we will hold your Personal Information while our services are ongoing and for a period of time after that for as long as needed to perform our services or otherwise engage with you and as long as required by applicable laws or regulations. For our clients, this would usually be for a minimum period of six (6) years from the date of last use, but such period may be extended if required in connection with ongoing complaints, litigation, or investigations or to comply with applicable legal/regulatory obligations.

SECURITY. We implement and maintain physical, electronic, and procedural safeguards and security measures that are reasonably designed to protect your Personal Information from unauthorized access, modification, or disclosure. For example, we implement:

Security measures for access to our business premises;
Security procedures within our offices; and
IT security measures and monitoring systems, including password protection, firewalls, and intrusion detection.

YOUR PERSONAL INFORMATION RIGHTS. Depending upon where you live, certain rights with respect to your Personal Information may be available to you, including the right to request access to your Personal Information, correct any mistakes in our records, erase or restrict records where they are no longer required, and object to use of Personal Information based on legitimate business interests.

We will respond to your request in writing, or orally if requested, as soon as practicable and in any event no later than one month after receipt of your request. In exceptional cases, we may extend this period by two months and we will tell you why. We may request proof of identification to verify your request. To exercise these rights please contact us pursuant to the instructions below.

CHANGES TO OUR PRIVACY NOTICE. We reserve the right to change our privacy notice in the future, but we will not disclose your Personal Information as required or permitted by law without giving you an opportunity to instruct us not to.

QUESTIONS OR COMPLAINTS. Our Managing Director oversees how we collect, hold, use, disclose, and protect your Personal Information. For questions about this notice, to exercise your rights regarding your Personal Information held by us, or to make an inquiry, please contact:

Jeff Lambert, Managing Director
11835 W. Olympic Blvd., Suite 640E
Los Angeles, CA 90064
Email: [email protected]
Tel: (310) 573-8520

PRIVACY NOTICE supplement FOR CALIFORNIA RESIDENTS

This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively known as “CPRA”). . This supplement is only relevant to you if you are a resident of California as determined in accordance with the CPRA. Information required to be disclosed to California residents under the CPRA regarding the collection of their personal information that is not set forth in this CPRA supplement is otherwise set forth above in the Privacy Notice.

Categories of Personal Information We Collect: We may have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:

Within the last twelve (12) months, we may have shared each of the categories of personal information collected with affiliates and third-party service providers as set forth in the general Privacy Notice above, and we collect personal information from the sources set forth in the general Privacy Notice above.

Purposes for Collecting Personal Information: We may collect or share the personal information we collect about you for one or more of the following business or commercial purposes:

Carrying out the tasks of administering funds including:
- Conducting calculation value of assets,
- Preparing balance sheets,
- Preparing account statements and maintaining accurate records
- Processing subscription and redemption requests and Transfer of interests
- Compliance with laws and regulations; and
- Supporting annual audits

We do not sell any of the personal information we collect about you to third parties.

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.

Disclosure/Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you over the last twelve (12) months. You may only make such requests twice per every 12 months. Such information includes:

The categories of personal information we collected about you;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting such personal information;
Categories of third parties with whom we share the personal information;
The specific pieces of personal information we have collected about you; and
Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.

Correction Rights: You have the right to correct any inaccurate information that we may have about you, subject to certain exceptions, including, but not limited to, whether we cannot identify you, whether the request is unfounded or excessive, or whether the information is exempt under the CPRA.

Sensitive Personal Information Limitation Rights: You have the right to limit how we may process any sensitive personal information we collect about you to ensure that is being used only as necessary to perform the services expected by you.

No Discrimination: We will not discriminate against you for exercising your rights under the CPRA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CPRA, or to access this notice in an alternative format, please submit a request using any of the methods set forth below.

Call us using the following phone number: 310-573-8520.

Email us at the following address: [email protected]

We will contact you to confirm receipt of your request under the CPRA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests); we may request your investor portal access credentials in order to verify your request. You may designate an authorized agent to make a request under the CPRA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. Please contact the Managing Director of Panoptic at the email address above with any questions or concerns about this Privacy Notice.