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Privacy Notice for Individuals Located in Brazil

Gresham Investment Management LLC regards the protection of your privacy as an important responsibility. In this document, "we", "us" and "our" refers to Gresham Investment Management LLC ("Gresham"), a fund or account managed or advised by Gresham (the "Fund") and its or their affiliates and/or delegates.

This privacy notice (the “Notice”) outlines the information we may collect about you and describes the basis on which we process your Personal Information, as defined by the Brazilian Data Protection Regulation (“LGPD”). This Notice also gives information regarding the basis on which we process your Personal Information and your privacy rights under the LGPD.

This Notice is addressed to any natural person who is located in Brazil who is any of the following: an investor or prospective investor in any fund or account managed or advised by Gresham (each, a “Gresham Fund”), a member, distributor, sales representative, business affiliate, or other representative of any client or prospective client of Gresham, a business contact working with service providers and vendors, or an individual on a Gresham mailing list (“you”) whose Personal Information Gresham collects, controls and processes in the conduct of its business. This privacy notice should not be construed as establishing a contractual relationship.

1. Collection of Personal Information

Our primary goal in collecting Personal Information from you is to effectively conduct business with our business partners and when applicable provide services and features to our clients, investors and potential clients and investors. You may make a data request by emailing investorrelations@greshamllc.com

2. Types of Personal Information held and its use

2.1 Client services and administration

Gresham may, in the conduct of our business, obtain Personal Information about you that may include, subject to the type of business or service relationship we have with you, without limitation:

  • Contact information (e.g., your full name, business and/or home mailing address, telephone number, business and/or personal email address, job title);
  • Identification information (e.g., date of birth, social security number, tax or other identification numbers and documents);
  • Financial Information (e.g., documents and information about your income, account transactions and holdings with us);

In the course of our business, we may collect Personal Information about you from sources including, but not limited to:

  • Information we receive from you, your application, subscription or other forms or material completed or supplied by an actual or prospective client of Gresham or a third party;
  • Other written, electronic, or verbal correspondence which relate to the business activities by or on behalf of an actual or prospective client of Gresham;
  • Information we receive from you when subscribing to a Gresham mailing list or obtaining a login for Gresham’s website;
  • Information we receive from security footage recorded for safety and security purposes when visiting Gresham premises; and

We process your Personal Information to fulfill our contractual obligations, our statutory obligations and/or the legitimate interests of Gresham and for other purposes for which Gresham has a lawful basis under the LGPD, including:

  • To administer and deliver to you the products and/or services you have requested;
  • For purposes of reporting to, or communicating with, actual or prospective clients of Gresham or third parties or the appointment or engagement of Gresham consistent with our obligations to such Gresham clients;
  • To retain records of our business transactions and communications;
  • For compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing or other “Know your Client” requirements, as well as to verify the status and/or eligibility of an actual or prospective client of Gresham for services offered by Gresham and for compliance with tax reporting requirements;
  • Due diligence or monitoring activities or in response to “Know Your Client” requirements of counterparties;
  • In connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving Gresham or Gresham’s clients;
  • To enable us to respond to certain requests by you such as access requests, scheduling of meetings or similar requirements; and
  • For other legitimate business interests.

We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Personal Information should be kept may also be governed by specific business-sector requirements and agreed practices. Personal Information may be held in addition to these periods depending on individual business needs.

2.2 Marketing

Gresham collects certain information that you provide to us when electing to receive regular reporting from Gresham or otherwise by joining one of Gresham’s mailing lists, which may include your name, email address and other contact details. Some of your Personal Information collected, in accordance with this Notice, may be used by us and third-party service providers to contact you by email, fax, telephone and/or post for sending information or promotional material pertaining to Gresham’s products and services.

In addition, we may process your Personal Information in order to communicate with you for marketing purposes. In this event, we may provide additional information that we believe may be of interest, including about services, news updates, research or market commentary, conferences, or events offered by or in conjunction with Gresham.

We give you the opportunity to opt-out of receiving marketing communications and may in certain circumstances need to obtain your consent before sending such communications to you.

So that we can better understand our users' needs, we track responses to our emails. To do this, we may use small image files that are placed within the body of our email messages. If used, these files enable us to tell if a message has been opened and to track click-throughs on links within the message.

3. Third Parties

We may pass your Personal Information on to third-party service providers contracted to us in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service that they provide you on our behalf.

4. Disclosures

Gresham may share your Personal Information with Gresham entities including with Gresham Funds for any of the purposes set forth above. In any such business purposes set out above, Gresham may share your Personal Information with third parties, including:

  • Service providers e.g., attorneys, auditors, accountants, tax advisers, administrators, custodians, depositaries, distribution managers and brokerage firms, event organizers or other agent, adviser or service provider to Gresham, or the Gresham Funds;
  • Other counterparties e.g., administrators or any of their respective agents or representatives; and
  • Regulatory authorities (including tax authorities), courts and bodies as required by law or requested for internal investigations and reporting.

We may transfer, sell or assign any of the information described in this Notice to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganization of our business.

5. Transfers outside Brazil

Where your Personal Information is processed by third parties outside Brazil, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law.

6. Confidentiality and security of your Personal Information

We are committed to keeping the data you provide us secure and will take reasonable precautions to protect your Personal Information from loss, misuse, or alteration. Once we have received your information, we will use procedures and security features to try to prevent unauthorized access. We have implemented information security policies, rules, and technical measures to protect the Personal Information that we have under our control from:

  • Unauthorized access;
  • Improper use or disclosure;
  • Unauthorized modification; and
  • Unlawful destruction or accidental loss.

7. How to access, update and erase your Personal Information

At your request, we can confirm what information we hold about you and how it is processed. If we do hold Personal Information about you, you can request the following information:

  • Identity and the contact details of the person or organization that has determined how and why to process your data. The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of us or a third party, information about those interests.
  • The categories of Personal Information collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed.
  • If we intend to transfer the Personal Information to a third country or international organization, information about how we ensure this is done securely.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the Personal Information and the possible consequences of failing to provide such data.
  • The source of Personal Information if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

Where appropriate in accordance with the LGPD, you may:

  • Request confirmation of the existence of processing;
  • Access your Personal Information;
  • Request correction of incomplete, inaccurate, or outdated information;
  • Request anonymization, blocking or elimination of unnecessary or excessive information, or of information processed in breach of the provisions of the LGPD;
  • Request deletion of Personal Information processed with your consent, except in the cases provided for in the LGPD and in this Notice;
  • Request information on the recipient(s) or categories of recipients that the data is/will be disclosed to;
  • Where consent is necessary or required, obtain information on the possibility of not giving consent and on the consequences of refusal; and
  • Withdraw your consent, where the consent is the legal basis used to process your Personal Information.

Upon request, we will provide you with a readable copy of the Personal Information which we keep about you. We require proof of your identity before providing you with this copy.

We will allow you to challenge the date that we hold about you and, where appropriate in accordance with applicable laws and policies, you may request to have your Personal Information:

  • Erased;
  • Rectified or amended; and/or
  • Completed.

If you would like to make a data request, please contact investorrelations@greshamllc.com.

Changes to this Notice

We will occasionally update this Notice to reflect new legislation or industry practice, changes to Gresham’s business and/or client feedback. We encourage you to review this Notice periodically to be informed of how we are protecting your Personal Information.