PRIVACY POLICY

This notice describes the Privacy Policy of Ceres Global Advisory Inc. (“CERES”) regarding how we handle and protect personal information that is received about our prospective, current, or former clients or fund investors. CERES collects personal information primarily to provide investment management services, communicate information about its products and services and process subscriptions in private investment vehicles that it may advise or sub-advice. Personal information, which may be obtained from discussions with you and documents you may deliver to CERES, may include your name, address, telephone number, social security number or tax identification number, assets, net worth, income, bank account in- formation and occupation (collectively, “Personal Information”).

CERES permits only authorized individuals, who have been advised as to the proper handling of investor information, and who need to access this information to perform services, to have access to this information. These authorized individuals are required to maintain and protect the confidentiality of Personal Information. CERES maintains physical, electronic and procedural safeguards to protect Personal Information.

In order to service your investments and process transactions for your investments, CERES may provide Personal Information to its affiliates and to non-affiliated third-party financial service providers that assist CERES in servicing your investments and have a need for such information, such as a broker-dealer, administrator, or registrar and transfer agent. In addition, CERES may share Personal Information with non-affiliated third-party non-financial service providers, in order to process or service transactions or products. Unaffiliated third-parties in this instance may include service providers such as word processors and printers. Any such contract entered into by CERES will include provisions designed to ensure that the third- party will uphold and maintain CERES’ privacy standards when handling Personal Information. CERES may also disclose Personal Information to regulatory authorities as required or permitted by applicable law. CERES does not otherwise provide information about you to outside firms, organizations or individuals except at your request or to our attorneys, accountants and auditors and as permitted by law. 

Except as described in this Privacy Notice, CERES will not use Personal Information for any other purpose unless CERES describes in advance how such Personal Information will be used and you are given an opportunity to decline approval of such use of your Personal Information.

CERES (“us”, “we”, or “our”) provides investment advisory services to individuals and Companies (the “Service”).

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.ceresglobaladvisory.com.

Definitions:

Service: Service is the advisory and portfolio management services provided by CERES to its clients, pursuant to an Investment Advisory Agreement or similar.

Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data: Usage Data is data collected by CERES from its clients.

Cookies: Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User): Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected Personal Data

In providing products and services to you, we collect nonpublic personal information that can be used to contact or identify you (“Personal Data”) from the following sources:

  • Information we receive from you on applications or other forms (e.g. investment/insurance applications, new account forms, and other forms and agreements).
  • Information about your transactions with us or others (e.g. broker/dealers, clearing firms, or other chosen investment sponsors).
  • Information we receive from consumer reporting agencies (e.g. credit bureaus), as well as other various materials we may use to put forth an appropriate recommendation, or to fill a service request. Personal identifiable information may include, but is not limited to:
    • Email address or First name and last name or Phone number or Address, State, Province, ZIP/Postal code, City.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Use of Data

CERES uses the collected data for various purposes:

  • To provide and maintain our Service.
  • To notify you about changes to our Service.
  • To provide customer support.
  • To gather analysis or valuable information so that we can improve our Service.
  • To monitor the usage of our Service.
  • To detect, prevent and address technical issues.
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), CERES legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

CERES may process your Personal Data because:

  • We need to perform a contract with you.
  • You have given us permission to do so.
  • The processing is in our legitimate interests and it’s not overridden by your rights.
  • To comply with the law.

Retention of Data

CERES will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws, including but not limited to the Investment Advisory Act of 1940), resolve disputes, and enforce our legal agreements and policies.

CERES will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

CERES will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data Disclosure for Law Enforcement

Under certain circumstances, CERES may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

CERES may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation.
  • To protect and defend the rights or property of CERES.
  • To prevent or investigate possible wrongdoing in connection with the Service.
  • To protect the personal safety of users of the Service or the public.
  • To protect against legal liability.

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. CERES aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data, we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • he right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where CERES relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Web-Site Links to Other Sites

Our website may contain links to other sites that are not operated by us. If you click on a third- party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email:
info@cerescapitaladvisory.com

By phone:
(305) 532-9229