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Nezu Asia Capital Management Limited and all of its affiliates and related entities (hereinafter referred to as “Nezu Asia”) respect and aim to protect the privacy of every current, former and prospective client (hereinafter referred to as “Clients”), as far as practicably possible. This notice sets forth the policies of Nezu Asia with respect to collection, use and restricted sharing of non-public personal information as well as safeguards in place to protect such information. For purposes of this privacy policy, “Client” includes investors in funds managed or advised by Nezu Asia.

Financial companies choose how they share Clients’ personal information. Applicable law gives clients the right to limit some but not all sharing. Applicable law also requires Nezu Asia to disclose to Clients how their personal information is collected, shared, and protected. Clients should read this notice carefully to understand Nezu Asia’s privacy policy.

Personal information we collect
Clients may provide Nezu Asia with personal information, such as their name, address, telephone number, social security or other identification number(s), investment experience, transaction history, wire transfer instructions, assets and/or income information.

How we collect this information
Nezu Asia collects this information from Clients through various means. For example, Nezu Asia collects information whenever a Client accesses Nezu Asia’s website, gives Nezu Asia its contact information, enters into an investment advisory contract with Nezu Asia, buys securities (i.e., interests in a fund) from Nezu Asia, tells Nezu Asia where to send money, or makes a wire transfer. Nezu Asia also may collect Clients’ personal information from other sources, such as from its affiliates1 or other non-affiliated companies.

Clients may provide this information to Nezu Asia in a variety of ways, including (i) in the subscription agreement and related documents, (ii) in correspondence and conversations with Nezu Asia’s representatives; and (iii) in the course of receiving advisory services from Nezu Asia.

How we use this information
All financial companies need to share customers’ personal information to run their everyday business and Nezu Asia uses the personal information it collects from Clients for its everyday business purposes. These purposes may include for example:

  • To provide advisory services;
  • To open an account;
  • To process a transaction for a Client’s account;
  • To market products and services to Clients; and
  • To respond to court orders, regulatory authorities and legal investigations.

Disclosure to others
Nezu Asia does not disclose any of this personal information to anyone, except:

  1. necessary employees of Nezu Asia in furtherance of its business relationship with them and then only to those persons necessary to effect the transactions and provide authorized services;
  2. to persons assessing Nezu Asia’s compliance with industry standards (e.g., professional licensing authorities, compliance consultants, etc.);
  3. Nezu Asia’s professional advisors and service providers, including but not limited to, attorneys, accountants, auditors, brokers and administrators, as reasonably required;
  4. governmental and/or quasi-governmental departments and/or agencies, regulatory and/or statutory bodies, any court and/or officer of the court;
  5. as otherwise provided by applicable law; or
  6. as otherwise provided herein.

For example, Nezu Asia may provide a Client’s personal information to its affiliates and to firms that assist Nezu Asia in servicing Client accounts and have a need for such information, such as a broker or fund administrator. Nezu Asia may also disclose such information to service providers and financial institutions with whom it has joint marketing arrangements (i.e., a formal agreement between nonaffiliated financial companies that together market financial products or services to Clients, such as placement agents).

Nezu Asia uses reasonable best efforts to ensure that any persons or institutions to which it discloses non-public information will protect the confidentiality of that information and only use such information for the intended purposes for which it was disclosed.

These sharing practices are consistent with applicable privacy and related laws, and in general, Clients may not limit Nezu Asia’s use of personal information for these purposes under such laws. The applicable privacy laws only give Clients the right to limit the certain types of information sharing that Nezu Asia does not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with nonaffiliates for them to market to you).

How we protect your personal information
Nezu Asia seeks to carefully protect Clients’ private information in compliance with applicable law. To that end, Nezu Asia maintains physical, electronic and procedural safeguards to protect their non-public personal information. More information on the aforementioned safeguards is available upon request.

All Clients can seek access to, withdraw their consent for the use of, or make a request to correct their non-public personal information maintained by Nezu Asia. Nezu Asia reserves the right to refuse such a request under the applicable regulatory requirements and if such a request is ever refused, the relevant Clients will be informed of such refusal and the reason for the same.

If you have any questions, complaints or comments about Nezu Asia’s Privacy Policy, or would like to make a request related to the non-public personal information Nezu Asia maintains in its records, please feel free to contact Nezu Asia at dataprotectionofficer@nezuasia.com.

1 Our affiliates are companies related to us by common ownership or control and can include both financial and nonfinancial companies. Non-affiliates are companies not related to us by common ownership or control and can include both financial and nonfinancial companies.