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”) contains information about how the Company collects, uses, and shares Personal Information, as defined by the California Consumer Privacy Act (“CCPA”). Gresham regards protection of your privacy as an important responsibility. This privacy notice (the “Notice”) contains information about how Gresham the Company collects, uses, and shares Personal Information, as defined by the California Consumer Privacy Act (“CCPA”). This privacy notice should not be construed as establishing a contractual relationship.
1. Purpose and content
1.1 This Notice applies to our website. This Notice is for California residents only pursuant to the CCPA.
1.2 The CCPA defines Personal Information broadly to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
1.3 Please note that much of the Personal Information we collect about California residents is not covered by this Notice. The CCPA includes certain exemptions that may apply to our use or collection of your Personal Information and it is possible that not all Personal Information that we collect from you or about you is covered by the CCPA or this Notice. For example:
- Personal Information that is collected, processed or sold pursuant to the federal Gramm-Leach-Bliley Act and implementing regulations is not covered by this Notice; and
- Personal information that we collect about you in a business-to-business context, including when you are communicating with us as an employee of a business to whom we are providing a product or service, or receiving a product or service from, is not covered by this Notice.
2. Categories of Personal Information that we may collect, use, and share
2.1 We may collect, use, or share Personal Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or a member of your household. The categories of Personal Information we may collect, use, or share include, but are not limited to:
- Identifiers (e.g., name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
- Categories of Personal Information in California Civil Code Section 1798.80
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement);
- Geolocation data;
- Professional or employment-related information (e.g., job application or resume information, past and current job history, and job performance information);
- Inferences drawn from Personal Information (e.g., consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).
3. Sources from which we may collect your Personal Information
3.1 We may obtain your Personal Information:
- Directly from you when you contact us via the internet, in person, or subscribe to Gresham's mailing list;
- From third parties such as data aggregators, social media, or companies with which we may have business relationships;
- Using online tracking technologies (including cookies, email tracking, and similar technologies), which may be used, among other things, to provide you with advertisements tailored to your interests (also known as targeted or behavioral advertising);
4. How we use your Personal Information
4.1 We use your Personal Information for our business and commercial purposes, including:
- To present our website and its contents to you;
- To deliver the information, products or services you requested from us;
- To reach out to you about and market our products and services to you;
- To communicate with you;
- To help us improve our website and deliver a more personalized experience;
- To deliver interest-based, targeted or behavioral advertising to you;
- To carry out our obligations and enforce our rights;
- In any other way we describe when you provide the information, or otherwise at your direction or with your consent;
- As permitted by law or as we may notify you.
5. How we share your Personal Information
5.1 We do not currently sell your Personal Information. The CCPA defines the term “sale” very broadly. In the past twelve months, we may have disclosed the following categories of Personal Information to third parties that provide services to us, such as website advertising and analytics services. Such disclosures may be considered a sale for purposes of the CCPA:
- Categories of personal information described in Cal. Civ. Code 1798.80(e);
- Internet or other electronic network activity information;
- Geolocation data;
- Inferences drawn from Personal Information.
5.2 We share your Personal Information for business purposes and in the last twelve months we may have shared the categories of Personal Information listed in Section 2 for a business purpose. For example, we share Personal Information with our affiliates, with entities that provide marketing services to us, and with our business partners, service providers and vendors. We may share your Personal Information with third parties and endeavor to ensure that they use it only for those services requested and keep it confidential.
5.3 We may share any of the Personal Information described in this CCPA Notice with third parties as part of or in connection with a sale, merger, consolidation, change of control, transfer of assets or reorganization of all or part of our business.
5.4 We may additionally share Personal Information in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving the Gresham or the clients of Gresham, or as otherwise required by law.
6. Your rights under the CCPA
6.1 As a California resident, you have the right to know how we have collected, used, and shared your Personal Information in the last twelve months. Specifically, you have the right to request to know:
- The categories and specific pieces of your Personal Information we have collected about you in the twelve months prior to your request, the categories of sources from which we have collected it, the business or commercial purpose for its collection or sale and the categories of third parties with whom we have shared it;
- The categories of your Personal Information we share for a business purpose, the categories of the third parties with whom it is shared, and the purpose for sharing this information; and
- The categories of your Personal Information sold and the categories of third parties to whom it was sold.
6.2 In addition, you have the right to request that we delete your Personal Information.
6.3 You have a right to not be discriminated against for exercising these rights.
7. Requests to know or delete your Personal Information
7.1 You have the right to request that we disclose to you the categories and/or specific pieces of Personal Information that we have collected about you. When you make a request, we will first take steps to verify your identity. Once we have verified your identity, we will provide information from our records for the preceding twelve months. Please note, we may decline your request if we are unable to verify your identity.
7.2 You have the right to request that we delete your Personal Information. When you make a request, we will first take steps to verify your identity. Once we have verified your identity, we will delete your Personal Information from our records unless an exception to your deletion request applies or we are unable to verify your identity. We may deny your request to delete Personal Information in whole or in part if retaining the information is necessary for us or our service providers to:
- Complete a transaction for which the Personal Information was collected, provide a good or service requested by you, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract(s) with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
7.3 To submit a request to know or a request to delete as described above, please call 866-887-1975 or send an email to firstname.lastname@example.org.
7.4 To review and update the cookies collected, please visit .
8. Verifying and responding to your requests
8.1 We only respond to requests that you make which are “verifiable.” To verify your requests, we may require authentication of you or the authorized agent acting on your behalf that is reasonable in light of the nature of the personal information requested. We may need additional information from you to verify your request.
8.2 In order to verify your request, we may need to obtain additional information about you to match the information we already have about you. If you provide us with new personal information that we did not already have about you, we will use it solely for the purposes of verifying your request. We will let you know if we need more information from you to verify your request. Please reply to our requests promptly.
8.3 If we cannot verify your request, we will let you know.
9. 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 collect, use and share your Personal Information.