Privacy Notice

What does the advisor, Versor Investments (formerly “ARP Investments”), do with personal information?

Why?

This privacy notice is directed to individuals/clients whose personal data Versor Investments, or its third party processors, handles in the course of carrying out commercial activities, including an investor in Versor Investments, a member, partner, trustee, shareholder, beneficial owner, officer, director, employee or other representative of any client of Versor Investments and any investor in Versor Investments, including any prospective client or investor. Such personal data may be provided to Versor Investments directly by a client such as an individual. Where a client is an entity, it may provide Versor Investments with personal data on individuals connected to the entity. This privacy notice will be relevant for those individuals, and the client should transmit this document to such individuals or otherwise advise them of its contents.

Versor Investments is responsible for ensuring use of personal data in compliance with applicable data protection law. This privacy notice sets out the basis on which any personal data will be processed by Versor Investments.

Purpose of Processing and Legal Basis for Processing

The client’s personal data may be processed by Versor Investments – or any of its affiliates, agents, delegates or sub-contractors – for the following purposes which are necessary for performance of client contracts:

  • Managing and administering clients’ holdings in Versor Investments, including assessing and processing subscription applications, communicating with clients about their holdings and account related activities on an on-going basis;
  • To update and maintain records and provide net asset value and other calculations (as applicable);
  • To manage and maintain client relationships for ongoing customer service;
  • To enforce or defend Versor Investments’ rights either directly through Versor Investments or through third-parties to whom it delegates such responsibilities;
  • To comply with any applicable legal, tax or regulatory obligations of Versor Investments, including those that derive from anti-money laundering and counter-terrorism legislation; and
  • To communicate with clients and prospective clients in order to provide information about Versor Investments and other products and services.

Client personal data may be processed by Versor Investments – or any of its affiliates, agents, delegates or sub-contractors – for the following purposes in order to enable Versor Investments to comply with its legal or regulatory obligations:

  • In order to carry out anti-money laundering checks and related actions including sharing client personal data with police, law enforcement, tax or regulatory authorities, or other government agencies where Versor Investmenrs has a legal obligation, including screening transactions, reporting suspicious activity and complying with production and court orders;
  • To report tax related information to tax authorities, including the automatic exchange of tax information;
  • To investigate and resolve complaints and manage contentious regulatory matters, investigations and litigation; and
  • To monitor electronic communications for investigation and fraud prevention purposes, crime detection, prevention and investigation.

In pursuance of our legitimate interests, or those of a third-party to whom client personal data is disclosed, including:

  • Complying with a legal, tax, accounting or regulatory obligation to which Versor Investments, or the third-party, is subject;
  • Assessing and processing requests clients make;
  • Sending updates, information and notices or otherwise corresponding with clients in connection with client holdings or interests in Versor Investments;
  • Investigating any complaints, or pursuing or defending any claims, proceedings or disputes;
  • Providing clients with, and informing clients about products and services;
  • Managing risk and operations;
  • Complying with audit requirements;
  • Ensuring internal compliance with policies and procedures;
  • Protecting Versor Investments against fraud, breach of confidence or theft of proprietary materials;
  • Seeking professional advice, including legal advice;
  • Where applicable, facilitating business asset transactions involving Versor Investments or related entities;
  • Monitoring communications to or from Versor Investments (where permitted by law); and
  • Protecting the security and integrity of Versor Investments’ information technology systems.

What?

Information that clients provide to Versor Investments: The nature of relationships with clients will determine the kind of personal data Versor Investments might ask for, though such information may include (by way of a non-exhaustive list):

  • Social security number
  • Basic personal data
  • Income
  • Assets
  • Risk tolerance
  • Wire transfer instructions
  • Transaction history

Information collected or generated about clients: Files may be produced as a record of client relationships and prospective client relationships, including contact history, and any personal data that clients provide during communications with Versor Investments.

Information obtained from other sources: This includes information from publicly available sources, information from the transfer agents or administrators or financial intermediaries, platforms, professional advisers, and information obtained from sanctions checking and background screening.

How?

All financial companies need to share clients’ personal information to run their everyday business. In the section below, reasons financial companies and Versor Investments choose to share clients’ personal information are listed. Versor Investments may share clients’ personal data with affiliates, agent, delegates and sub-contractors. In certain cir