Quanbot Technologies, LP
CALIFORNIA PRIVACY NOTICE
This CA Privacy Notice, effective January 30, 2020, (the “CA Notice”) supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California (“consumers” or “you”).
This CA Notice describes how Quantbot Technologies, LP (“Quantbot,” “we,” or “us”) collect, use, disclose, and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (CCPA).
Unless otherwise expressly stated, all terms in the CA Notice have the same meaning as defined in our Privacy Policy or as defined in the CCPA.
Personal Information Definition
When we use the term “personal information” in this CA Notice, we 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 individual. The term does not include publicly available information from government records; de-identified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you; or any other information excluded from the CCPA’s scope (e.g. certain types of health or medical information).
Collection and Use of Personal Information
We collect personal information in connection with our services for various purposes. For example, we use personal information to:
– Communicate with you.
– Inform marketing and advertising activities we undertake on behalf of the funds, if any.
– Optimize and improve our services.
– For other business, operational and commercial purposes.
Please review the following to learn more about the personal information we collect and the purposes for which we collect it: “Personal Information We Collect” and “How We Use Your Personal Information.” In the last 12 months, we have collected the following categories of personal information:
| Category of Personal Information We Collected | Collected? | Categories of Sources |
|---|---|---|
| Identifiers, such as your name, address, phone number, email address or other similar identifiers. | YES | – Directly from you – Automatically generated or collected during your use of services (e.g. by your browser or device) – Our affiliates and third parties, including third parties you direct to share information with us (e.g. social networks) |
| California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your name, address, phone number, bank account number or other payment account numbers. | YES | – Directly from you – Automatically generated or collected during your use of services (e.g. by your browser or device) – Our affiliates and third parties, including third parties you direct to share information with us (e.g. social networks) |
| Protected Classification Characteristics, such as age, gender or demographic group. | YES | – Directly from you |
| Commercial Information, such as your subscription/redemption history, record of transaction tendencies, and investment status or progress. | YES | – Directly from you – Automatically generated or collected during your use of services (e.g. by your browser or device) – Our affiliates and third parties, including third parties you direct to share information with us (e.g. social networks) |
| Communications, such as your correspondence history, inquiry history, and information regarding your interaction with Quantbot. | YES | – Automatically generated or collected during your use of services (e.g. by your browser or device) |
| Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address and GPS (e.g. latitude and/or longitude). | YES | – Automatically generated or collected during your use of services (e.g. by your browser or device) |
| Sensory Information, such as photographs or records of calls with our support teams, if any | YES | – Directly from you |
| Inferences, such as information generated from your use of our services reflecting your preferences | YES | – Automatically generated or collected during your use of services (e.g. by your browser or device) |
Sharing and Disclosure of Personal Information
We may share your personal information with the following categories of third parties:
– Service Providers
– Third-Party Businesses
– Affiliates
– Governmental and law enforcement officials
– Persons involved in an acquisition of our business or assets
Service Providers. We may share your personal information with Service Providers that perform services for us, such as a broker, but only for the purpose of and to the extent necessary to perform those services.
Affiliates. We may share your personal information with our parent, subsidiaries, affiliates and other related entities, and our advisors, including lawyers, consultants, accountants, auditors and others.
Marketing Communications. We may use your personal information to communicate with you about services offered by us.
Health, Safety, and Legal Requests. We may share your personal information for purposes of health, safety and other matters in the public interest. We may also share your personal information to cooperate with official investigations or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We may also use personal information to protect our rights and property and those of our agents, clients, and others including to enforce our agreements, policies, and terms of use.
Transfer or Sale of Our Business. If we, or our parent, subsidiaries, affiliates or other related entities, are involved in a business transaction, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving us or our parent, subsidiaries, affiliates or other related entities, we may share your personal information in connection with such transaction. We may also share your personal information to legal, financial, insurance, or other advisors in connection with such business transaction or management of all or part of our business or operations.
In the last 12 months, we may have disclosed for a business purpose all of the categories of personal information we collect, explained in the chart above. In the last 12 months, we have not sold any personal information we collect.
Protection of Your Personal Information
Security Measures: We take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, Personal Information.
No Liability for Breach: Because no security system is impenetrable, we cannot guarantee the security of your Personal Information. By using our services, you agree to assume all risk in connection with your Personal Information. We are not responsible for any loss of such Personal Information or the consequences thereof.
Breach Notification: If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you subject to applicable laws and regulations governing such notifications.
Retention: We will retain your Personal Information for as long as it is reasonably useful for commercial purposes. We will retain and use your Personal Information as necessary to comply with our legal obligations or data retention policies, resolve disputes and enforce our agreements.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights (collectively, the “California Privacy Rights”) in relation to the personal information about you that we have collected (subject to certain limitations at law):
| Right to Know | You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
● The specific pieces of personal information we have collected about you; |
| Right to Request | You have the right to request specific pieces of personal information that we hold. |
| Right to Delete | You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions. |
| Right to Opt-out | You have the right to direct us not to sell (as that term is defined by the CCPA) personal information we have collected about you to third parties now or in the future. |
| Right to Correct | You have the right to request that we correct inaccurate personal information that we have about you. |
| Right to Limit | You have the right to request that we limit the use and disclosure of sensitive Personal Information collected about you. |
| Right to Non-Discrimination | If you choose to exercise your rights, we will not charge you different fees or provide different quality of services unless those differences are related to your personal information. That is, if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner. |
If you opt out of the sale of your Personal Information, we may still share your Personal Information with third parties if those transfers are not sales, such as with our Affiliates or our Service Providers.
How to Exercise Your California Privacy Rights
Exercise Your Right to Know or Right to Delete
You may submit a request to exercise your California Privacy Rights by contacting the Quantbot compliance department. We will need to verify your identity before processing your request, which may require us to request additional personal information from you. We will only use personal information provided in connection with a California Privacy Rights request to review and comply with your request. You may also designate an authorized agent to make requests on your behalf. In order to be able to act, authorized agents must submit a request by contacting the Quantbot compliance department and provide sufficient evidence to demonstrate that the requestor is an authorized agent with written permission to act on your behalf.
In certain circumstances, we may decline a request to exercise the Right to Know or Right to Delete described above, particularly where we are unable to verify your identity. We may also ask for supplemental information as needed to establish your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Response Timing and Procedures
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.