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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 (“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’ 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 Information is collected, shared, and protected. Clients should read this notice carefully to understand Nezu Asia’s privacy policy.

Information we collect
Information provided by Clients to Nezu Asia may include:

  1. personal information, such as their name, address, telephone number, social security or other identification number(s)
  2. investment experience
  3. transaction history
  4. wire transfer instructions
  5. assets and/or income information
  6. political affiliations
  7. trade union membership
  8. criminal convictions

Some of this information may be publicly accessible.

How we collect this information
Nezu Asia collects 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 a fund managed or advised by Nezu Asia, tells Nezu Asia where to send money, or makes a wire transfer. Nezu Asia also may collect Clients’ Information from other sources, such as from its affiliates1 or other non-affiliated companies such as service providers.

Clients may provide 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
Nezu Asia will process and use Clients’ Information for the following purposes:

  1. To the extent necessary to provide advisory services;
  2. In the course of the operational support and development of our businesses, including to evaluate customer service, efficiency and cost, as well as risk management purposes;
  3. For internal administrative purposes; such as:
    a. To open an account;
    b. To process a transaction for a Client's account; or
    c. To market products and services directly to Clients;
  4. For ensuring cyber security (including preventing unauthorised access to networks and stopping damage to computers and systems);
  5. In relation to any litigation, disputes or contentious matter anywhere in the world that Nezu Asia is involved in and/or to assist with investigations, complaints, regulatory requests, litigation, arbitration, mediation or requests from individuals;
  6. In order to comply with legal and regulatory requests made to Nezu Asia (anywhere in the world);
  7. For reporting, (including without limitation transaction reporting), to and audits by national and international regulatory, enforcement or exchange bodies and complying with court orders associated with Nezu Asia; and
  8. For monitoring purposes.

Disclosure to others
Nezu Asia’s processing and use of a Client’s Information may include disclosure:

  1. to 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 processing such Information on Nezu Asia’s behalf;
  3. to Nezu Asia’s professional advisors and service providers, including but not limited to, attorneys, accountants, auditors, brokers and administrators, as reasonably required;
  4. to persons assessing Nezu Asia’s compliance with industry standards (e.g., professional licensing authorities, compliance consultants, etc.);
  5. to governmental and/or quasi-governmental departments and/or agencies, regulatory and/or statutory bodies, any court and/or officer of the court;
  6. to persons to whom we assign or novate our rights or obligations under an agreement with a Client;
  7. as otherwise provided by applicable law; or
  8. as otherwise provided herein.

For example, Nezu Asia may provide a Client’s Information to its affiliates or related companies 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 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).

These disclosures involve overseas storage and other overseas transfer, processing and use of Information, and disclosure to these third parties, including in or to countries or territories outside of the European Economic Area where the laws may provide different levels of data protection. Without limiting the foregoing, Information will be disclosed by Nezu Asia to its associated firms and vendors which conduct operational, technology and customer service functions in various jurisdictions which may include (but are not limited to) China, Hong Kong, India, Japan, Singapore, United Kingdom and the United States of America. Nezu Asia uses reasonable best efforts to ensure that any persons or institutions to which it discloses 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 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 and/or related companies certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any Information with non-affiliates for them to market to you).

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

Nezu Asia retains Clients’ Information in an identifiable form in accordance with its internal written information security policy, which establishes general standards and procedures regarding the retention, handling and disposition of Clients’ Information. Information is retained as long as necessary to meet legal, regulatory and business requirements. Retention periods will be extended if Nezu Asia is required to preserve Clients’ Information in connection with litigation, investigations and proceedings.

All Clients can seek access to, withdraw their consent for the use of, or make a request to correct or erase their Information maintained by Nezu Asia. All Clients also have the right to object to the processing of their Information, obtain restriction of the processing of such Information, and data portability. 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 wish to exercise any of your data protection rights or if you consider that we have processed your Information in violation of applicable law, please contact Nezu Asia atdataprotectionofficer@nezuasia.com. If you consider that Nezu Asia has processed your Information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with a supervisory authority.

If you have any questions, complaints or comments about Nezu Asia’s Privacy Policy, or would like to make a request related to the 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.