Hedonova LLC (the "Investment Manager") is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by the investment manager is controlled by the Investment Manager, and the Investment Manager is the data controller of your personal information. When your details are provided to the Investment Manager as a consequence of your investment (or potential investment) in a private investment fund sponsored by Hedonova LLC (each, a "Fund"), then the Investment Manager, acting as a data controller, may itself (or through third parties acting in its capacity as the Fund's agent or administrator) process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (as distinguished from the entity itself) (the foregoing collectively, "Your Personal Information"). When processing Your Personal Information, the Agent or Administrator may also act as a data controller.
The Investment Manager collects Your Personal Information from the following sources, as applicable:
Your Personal Information may be processed by the Investment Manager and/or the Administrator (or any of their affiliates, agents, employees, delegates, or subcontractors) for the following purposes, as applicable:
The Investment Manager and the Administrator have legal authority to collect and use Your Personal Information because:
The Investment Manager and the Administrator will retain Your Personal Information for the purposes described in the preceding paragraphs for as long as necessary for the purposes described above. In particular, and without limitation to the foregoing, the Investment Manager and the Administrator are obligated by applicable legal systems to retain Your Personal Information for a certain period of time.
You have the right to:
To make any requests of the above requests, please contact the Investment Manager at firstname.lastname@example.org. The Investment Manager will respond to requests relating to your rights outlined above within one month of receipt, or within two months if the request is more complex.
You can tell the Investment Manager to stop collecting, using, and retaining Your Personal Information at any time by emailing the Investment Manager at email@example.com. You should note that notwithstanding your withdrawal of consent, the Investment Manager and the Administrator may be legally required to retain some or all of Your Personal Information. When the Investment Manager or the Administrator requires Your Personal Information in order to comply with AML or other legal requirements, failure to provide this information will result in your inability to be accepted as an investor in the Fund and/or mandatory redemption from the Fund if you are already an Investor.
The Investment Manager maintains appropriate technical and organizational measures to address potential risks, including physical, electronic, and procedural safeguards that comply with the GDPR to protect customer information, including:
The Investment Manager restricts access to Investors' personal and account information to employees who need to know that information to fulfill their job responsibilities. The Investment Manager will destroy, erase, or render unreadable any nonpublic data, computer files, and documents containing Your Personal Information prior to disposal.
If you would like to make a complaint about the way the Investment Manager has collected, used, or retained Your Personal Information, please contact us at firstname.lastname@example.org.
If you believe that the processing of Your Personal Information by the the Investment Manager or its service providers infringes the GDPR, you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.
Updated May 2021