Privacy Policy

Last Updated May 22, 2018

I. Privacy Policy

This is the privacy policy (“Policy”) of Managed Funds Association (“Eminence”), an organization incorporated in the United States, on behalf of itself, its affiliates and subsidiaries. Eminence represents the global alternative investment industry and its investors by advocating for sound industry practices and public policies that foster efficient, transparent, and fair capital markets. Eminence, based in Washington, DC, is an advocacy, education, and communications organization established to enable hedge fund and managed futures firms in the alternative investment industry to participate in public policy discourse, share best practices and learn from peers, and communicate the industry’s contributions to the global economy.

II. What This Policy Covers

This Policy explains our practices regarding the collection and use of personal information from members, sponsors, event attendees, industry contacts, and other stakeholders (such as academics, investors, and policymakers), as well as information collected from users of Eminence’s mobile application services, and registered users or other visitors to Eminence’s websites (together, “Website”): mfastaging.wpengine.com, and www.hedgefundamentals.org.

This Policy provides information on:

• Personal Information Collected;
• Use and Disclosure of Collected Information;
• Information Security;
• Communications;
• Website Visitor Consent;
• Changes to the Policy; and
• Your Rights and How to Contact Us.

This policy does not apply to the practices of third party companies that Eminence does not own or control, to third party websites (even if linked to the Website), or to individuals that Eminence does not employ or manage. The Website may contain links to other sites. Eminence is not responsible for the data practices or privacy policies of these third party sites.

III. Personal Information Collected

Personal Information: We may collect your personal information to service your Eminence membership, in furtherance of Eminence’s mission statement provided above or for other legitimate business interests. We may collect your personal information, which includes contact information (i.e., name, address, telephone number, email), through your membership subscription, from an alternative assets industry subscription database, from a referral, or as provided voluntarily to us, such as when you register for, or sponsor, an Eminence event, request our newsletter, submit a Press Inquiry or Contact Us form, provide payment for dues or conferences, or provide personal information through our Website. The personal information we process is generally limited to contact information to communicate with or respond to requests from members and non-members, and payment information to process dues, fees, or donations. Eminence may request for additional personal information from members to submit on their behalves for government security clearance purposes for Eminence member meetings with policymakers.

Our Website may also provide you certain interactive features to allow you to post content to other members, or to share information publicly. Please do not disclose sensitive personal information, including non-public financial information, about yourself or any investors or other clients of your organization.

Website Information and Tracking Technologies: We, and/or our third party service providers, may collect information from your use of our Website or online services, including technical information about your interaction with our Website. This may include the time and date of your visit, your IP address, referral URLs (or the website you came from when you visit our Website), operating systems and browser types, and other information gathered through the use of cookies or other similar technologies. We may use these technologies in the collection of information you provide us or when your web browser accesses information on this Website to store your Website preferences, to help us to improve or optimize our Website, to understand Website traffic, and to offer you a more personalized experience. You can configure your browser to disable, block or alert you when a site is attempting to send a cookie. Because an industry-standard Do-Not-Track protocol is not yet established, the choices we offer will continue to operate as described in this Privacy Policy independent of any Do-Not-Track signals.

Children’s Privacy: This Website is not intended for children. We do not knowingly collect personal information from children under the age of 13, and in the event that we learn that a child under the age of 13 has provided information on our Website, we will delete that information as soon as possible.

IV. Use And Disclosure Of Collected Information

Third Party Service Providers, Agents, Contractors, or Partners: We do not share personal information with unaffiliated third parties for those third parties’ own purposes. We may, however, share personal information with our third party service providers, agents, contractors, or partners in connection with services that these individuals or entities perform for, or with, Eminence. This includes services such as sending email messages, managing data, hosting our databases, providing data processing services, or providing online consulting services. These service providers, agents, contractors, or partners are restricted from using this data in any way other than to provide services for Eminence.

With Other Members or Eminence Event Attendees: We may provide interactive features on our Website or through Eminence’s mobile application services to permit members or Eminence event attendees to communicate with each other for business, networking or educational purposes. We do not pre-approve or monitor disclosures between members or event attendees directly or through interactive Website or mobile application features. Please note that these interactions and disclosures are not governed by this Policy.

As Required by Law or for the Protection of Others: We retain the right to disclose collected information pursuant to a request from law enforcement or pursuant to other legal or regulatory process, or as otherwise required by law, or, in our sole discretion, to protect our rights, property or interests, including to enforce this Policy or our Website Terms of Use. We may also disclose your identity to any third party who claims that any content posted or uploaded by you to our Website constitutes a violation of their intellectual property, privacy or other rights.

Business Transfers: Your personal information may be disclosed to third parties in the event of a bankruptcy, transfer of assets, reorganization or other restructuring of Eminence.

V. Information Security And Data Retention

Eminence endeavors to protect personal information in its possession, and uses technical and organizational security measures and safeguards to help protect your information. However, Eminence cannot guarantee the security of personal information. Your account information is protected by a password for your privacy and security. You should help to prevent unauthorized access to your account by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.

We retain personal information of members for purposes of providing membership services. Any sensitive personal information that Eminence collects from members for government security clearances for meetings with policymakers is destroyed immediately upon the meeting for which such information was collected. We retain personal information of non-members in order to better service these individuals who may attend Eminence events, share common interests, become Eminence members, or for other similar legitimate business interests. We will expunge personal information of non-members after ten years with no recorded activity, outreach or communication with Eminence, absent a reason to obtain such information to comply with applicable law or for the legitimate interests of Eminence.

VI. Communications

For Eminence members, we may use your information to communicate with you to provide membership services, including notifications about relevant industry news and Eminence activities (such as meetings, calls, and events). For non-members, we may send you Eminence or industry news and information, notifications of Eminence events, or other information that you may sign up for on our homepage..

VII. Website Visitor Content

When you use our Website or provide personal information to Eminence through the Website, that information is provided to the Eminence in the United States. Please do not use our Website or mobile services if you do not agree to the transfer and processing of your personal information by Eminence in the United States.

VIII. Changes To The Privacy Policy

We may update this Policy from time to time and will place any updates on our Website with a “last updated” date at the top of the Policy. We will inform you of any material changes to the Policy.

IX. Your Rights And How To Contact Us

You may have certain rights under applicable law, including the right to access or for Eminence to update, rectify or delete the information we have on you, as well as the right to object or restrict our data processing activities, or to stop receiving communications. If you have any comments, questions, concerns or complaints about how we are processing your information, please contact us at the email below. If we are unable to address your concerns, you also have the right to challenge our data processing decisions with a supervisory authority.