Privacy Policy

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Introduction

Gulfstream Investment Partners Limited and its affiliates (collectively referred to as “Gulfstream,” “we,” “us,” or “our”) offer a range of investment management and advisory services to qualified investors. These include discretionary and non-discretionary portfolio management, investment research, and performance monitoring. We prioritize the protection of sensitive personal and financial information. We do not disclose confidential information about our clients or former clients except as authorized by you, as required by law, or as described in this Privacy Notice.

This Privacy Notice outlines the types of personal information we collect, the purposes for which we use and share that information, and your options regarding our data practices. Residents of California can click here for more information about their privacy rights. Additionally, residents of the European Union and the United Kingdom can find relevant information regarding their rights below. Transfers of personal data of EU residents to third countries are governed by Standard Contractual Clauses, as applicable.

What Personal Information We Collect and How We Collect It

We may collect personal information about you from various sources, including discussions and correspondence with us, legal documents, information you provide regarding your investments or portfolio, incoming wire transfers, invoice payments, and applications or forms completed on our website or online platforms. We may also obtain personal information from your authorized representatives, fiduciaries, email communications, phone conversations, paper correspondence, social media interactions, our websites and online platforms, and during events such as conferences and exhibitions.

The personal information we collect may include, but is not limited to, contact information, biographical data, income, transaction history, risk tolerance, wire transfer instructions, banking information, identification and tax numbers, as well as details about your investment assets. When you interact with our websites or online platforms, we may collect information about your IP address, social media usernames, and other identifying details. Our websites may also use cookies and similar tracking technologies to gather data about your usage patterns, including visitor counts, popular pages, browser types, geographical data, and navigation trends. For more details on our cookie usage, please refer to our Cookies Policy. Recipients of personal data may include employees and third-party service providers who are contractually obligated to maintain security and privacy measures equivalent to those of Gulfstream.

How We Use Personal Information

We may use your personal information for the following purposes:

• To provide our portfolio management, investment research, and performance monitoring services.
• To respond to your inquiries, comments, feedback, or questions.
• To send you administrative information, including updates about our services and changes to our terms, conditions, and policies.
• To analyze your interactions with our website.
• To improve and secure the content and functionality of our website.
• To assess and enhance the effectiveness of our marketing communications.
• To innovate new products and services.
• To prevent fraud, criminal activities, and misuse of our services while ensuring the security of our IT systems and networks.
• To comply with legal obligations and processes.
• To protect our rights, privacy, safety, or property, as well as those of our affiliates, you, or other parties.

Legal Basis for Processing Personal Data

We may lawfully process your personal data based on the following grounds:

• Consent: Processing for which you have provided explicit consent.
• Contractual Necessity: Processing essential for the execution of a contract to which you are a party or to take steps at your request before entering into a contract.
• Legal Obligations: Processing necessary for compliance with legal or regulatory obligations.
• Legitimate Interests: Processing necessary for our legitimate interests, provided that such processing does not override your rights or interests, such as in marketing activities with minimal privacy impact.

Sharing and Disclosure of Personal Information

Unless otherwise agreed, we may share the personal information described above with custodians, fund administrators, investment managers, legal advisors, audit firms, tax advisors, and other non-affiliated entities, in accordance with your consent or as mandated by law. We may also disclose this information to service providers that assist us in our business operations. We require third parties to adhere to adequate security standards and comply with applicable data protection regulations.

International Transfer of Personal Information

Gulfstream may transfer your personal information outside the jurisdiction in which it was collected. When such transfers occur, we ensure that appropriate safeguards are implemented to comply with applicable data protection laws.

Your Choices Regarding Personal Information

It is essential that the personal information we hold about you is accurate and up to date. Please inform us of any changes to your personal information during our professional relationship. Depending on your location, you may have specific rights regarding your personal data. California residents should review the Additional Information for California Residents section below for relevant rights.

Retention and Destruction of Personal Information

We take reasonable measures to ensure that the information we hold about you is accurate. We will retain your personal information only as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, accounting, or reporting obligations. When your data is no longer required, we will securely destroy it following our policies and applicable laws. We may anonymize your personal information for further use without additional notice.

Links to Other Websites

Our website may contain links to third-party websites not operated by us, including social media services. Information you provide to these sites is governed by their respective privacy policies and not by this Privacy Notice. We do not endorse or review these sites; please refer to their privacy practices directly.

Tracking Technologies and Do Not Track Signals

We and our service providers may use cookies and tracking technologies on our website to collect data about your browsing behavior over time and across different sites. Our website does not currently respond to "Do Not Track" signals, but we will update this Privacy Notice if we change our practices. Please see our Cookies Policy for more details.

Security

Data transmission over the internet is not entirely secure. While we implement reasonable measures to protect your personal information from loss, misuse, or unauthorized access, we cannot guarantee its absolute security. Clients accessing performance data on our website will receive unique login credentials, and it is your responsibility to safeguard this information.

Rights Related to Personal Data

Residents of the EU, UK, and Switzerland have specific rights under the GDPR and the Swiss Federal Data Protection Act regarding their personal information. These rights include:

• The right to access your personal information.
• The right to object to processing that may cause you distress.
• The right to prevent processing for direct marketing.
• The right to request restrictions on processing.
• The right to have your information rectified or deleted.
• The right to seek compensation for damages from data breaches.
• The right to transfer your personal data to another entity.
• The right to withdraw consent for data processing.
• The right to know about safeguards for personal data transferred outside the EU.
• The right to lodge a complaint with a data protection authority.

Additional Information for California Residents

Under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), this section informs California residents of (1) the personal information we collect and how we disclose it, and (2) the rights available to them regarding their personal information.

Personal Information Collection and Disclosure

In the past year, we have collected categories of personal information, as detailed in the "What Personal Information We Collect" section above, including:

• Identification Information: Your name, email, phone number, address, social security number, and online account details.
• Online Activity Information: Device identifiers, IP addresses, browser types, actions taken on our website, and referring pages.
• Commercial and Financial Information: Transaction history, banking details, account numbers, income, and risk profiles.

We collect this information from you, your authorized representatives, service providers, and other means described above.

California Consumer Privacy Act (CCPA) and CPRA Rights

California residents have specific rights regarding their personal information, including:

• The right to request deletion of personal information collected.
• The right to disclose information about our collection and use over the past year.
• The right to opt out of the sale of personal information (we do not sell personal information).
• The right to correct inaccurate personal information.
• The right to limit the use of sensitive personal information.
• The right to not be discriminated against for exercising privacy rights.

California residents can exercise these rights by contacting us at info@gs-investmentpartners.com

Additional Privacy Rights

Our privacy practices comply with various applicable privacy laws, including:

• United States: CCPA, CPRA, HIPAA, GLBA.
• European Union, UK, and Switzerland: GDPR, UK GDPR, Swiss Federal Data Protection Act.
• Canada: PIPEDA.
• Australia: Privacy Act 1988.
• Singapore: PDPA.

This list is not exhaustive, and the applicability of these laws may vary based on your location. We are committed to respecting all applicable laws that protect your privacy rights.

Identity Verification

To safeguard your personal information against unauthorized access or deletion, we may require you to verify your identity when making a request to access or remove your personal information. If you do not hold an account with us, or if we suspect fraudulent or malicious behavior, we may request additional information to confirm your identity. If we cannot authenticate your identity, we will be unable to grant your request to access or delete your personal information.

Requests via Authorized Agents

You may submit a request for information or to delete your personal details through an authorized representative. In such cases, we may ask for written consent from you, granting the agent permission to act on your behalf. You may also need to verify your identity independently and confirm that you have authorized the agent to submit the request.

Policy Updates

We reserve the right to amend this Privacy Notice periodically. The most current version will be available on our website. We recommend reviewing this notice regularly to stay informed about our practices regarding your personal information.

Contact Us

For any inquiries or further information about our privacy practices, please reach out to us at: info@gs-investmentpartners.com