PRIVACY POLICY

VSS Fund Management LLC (“VSS”) treats the privacy of its website users seriously and takes appropriate security measures to safeguard your privacy. Visitors to this site may visit some areas of the site without specifically revealing who they are or otherwise providing personal information.

This policy explains how VSS collects and uses any personal information – any information that relates to you and that identifies or can be used to identify you – (e.g., your name, email, address, or other digital identifiers relating to you, such as IP addresses, cookies or web server logs) you share with us, including how we collect, process, protect and share personal information. We reserve the right to change this privacy policy at any time.

VSS relies on various legal bases under applicable data protection legislation to process your personal information, including our legitimate interests (e.g., to operate our investment programs), contractual necessity (e.g., to enable us to provide our services to you), and as required by applicable law.

If we require your personal information due to a legal requirement or obligation, or in order for us to perform a contract with you, we will make you aware of this at the time we collect your personal information (unless we are restricted from doing so under applicable law), and the possible consequences of you failing to provide this personal information (e.g., we may require you to verify your identity for the purposes of anti-money laundering regulations).

Information you provide to us

You may provide us with personal information via email, postal mail and telephone when you decide to interact with us. This includes contact information, including name, email address and telephone number. We will only collect and process personal information about you where we have lawful basis to do so. We do not knowingly collect or solicit personal information from anyone under the age of 16.

Why we use your personal information

We will use the personal information you provide us for the following purposes, and pursuant to the corresponding legal basis:

   Purpose

  • To provide you with services you have requested
  • To respond to requests for information submitted by you
  • To keep a record of your relationship with us
  • To verify your identity

    Legal Basis

  • Contractual necessity
  • Legitimate interest
  • Contractual necessity and legitimate interest

Additionally, we will use your personal information to provide you with information and updates on VSS’s active funds and prospective funds, if you have provided your consent to us doing so or based on our legitimate interest where we have an existing relationship with you and we wish to contact you about funds in which you may be interested.

Who we share your personal information with

We will share your personal information with third parties as required by law or regulation. In addition, we will share personal information with regulatory bodies having competent jurisdiction over us, as well as with the tax authorities, auditors and tax advisers, where necessary or as required by law. We will also share your personal information with affiliates.

We will also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment or other disposition of all or a portion of our business, assets or shares.

How we keep your personal information secure

We will share your personal information with third parties as required by law or regulation. In addition, we will share personal information with regulatory bodies having competent jurisdiction over us, as well as with the tax authorities, auditors and tax advisers, where necessary or as required by law. We will also share your personal information with affiliates.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this privacy policy, unless a longer retention period is required under applicable law. We will not keep more information than we need for such purposes. How long we retain your personal information depends on the purpose(s) for which it is processed by VSS. For further information regarding how long we will keep your personal information, please contact us using the details outlined at the “How to contact us” section of this privacy policy.

Acceptance

Use of this site signifies that you have read, comprehend and accept all provisions of this Privacy Policy. VSS reserves the right at its discretion to add, modify, change or withdraw portions of its Privacy Policy without notice. VSS recommends reviewing the Privacy Policy on a regular basis for changes.

Your rights

You have the right to access the personal information we hold about you, and there are several ways you can control the way in which and what information we store and process about you. We have explained these individual rights and controls below. To exercise these rights and controls, please contact us at VSSPortalAdmin@vss.com.

Access: You have the right to ask for a copy of the personal information that VSS holds about you.

Correction: If there are any inaccuracies in the information we hold about you, please contact us and we will correct them.

Deletion: If you think that we shouldn’t be holding or processing your personal information any longer, you may request it be deleted. Please note this may not always be possible due to legal obligations.

Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you are verifying the accuracy of it; (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you are verifying whether our legitimate grounds to process your personal information override your own rights.

Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; and/or (iii) where processing is based on legitimate interests.

Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.

How to contact us

For any questions regarding VSS’s processing of your personal information please contact VSSPortalAdmin@vss.com.