Notice of Privacy Policy

Financial institutions like Rotella Capital Management, Inc. dba Qdeck (“Rotella Qdeck”) are required to provide their clients with a notice of privacy policies and practices. We believe that protecting the privacy of your nonpublic personal information is of the utmost importance, and we are committed to maintaining the privacy of your nonpublic personal information in our possession. It is important for you to understand what information Rotella Qdeck collects about you and how we will use, protect and disclose this information once it is collected, as well as how you can opt-out of some of our uses and disclosures of your information. Therefore, we are providing you with the following notice about the information we collect, how we use that information and how we protect that information.

This Privacy Policy applies to you if you are an individual who is a client of ours; you represent (as an employee, agent, director officer, partner or owner (an “authorized representative”)) a client of ours and your information has been provided to us; you are an individual who is a potential client or the authorized representative of a potential client; you visit any website or application operated by us; you contact us by any means; or you represent a supplier, service provider, adviser or consultant of ours.

This Privacy Policy and any applicable agreement entered into between you and Rotella Qdeck sets forth the basis on which we use your personal information. This notice discloses information required under the privacy laws that apply to us, including the General Data Protection Regulation and other applicable European and US privacy laws. We are a data controller of your personal information.

Information We Collect

1. We collect information we receive from you from managed account or other service agreements and forms. This information may include personal details such as name, title, addresses, telephone numbers, email addresses, date of birth, gender, citizenship, signature, photographs and details about your employment. This information may also include financial details such as your investment experience, income, assets, bank accounts, tax residency and tax id. We may also collect information provided by you and/or an authorized representative via email, telephone or at a meeting. Information may also be obtained from public sources such as websites or regulatory filings.

2. We collect information about your transactions with our firm. This may include account activity, transactions and balances.

3. We collect information from our website and applications we operate using cookies and other technologies.

How We Use This Information

Information is collected from you in the ordinary course of business in order to offer or provide services, process transactions, and to fulfill contractual and legal obligations. We may use this information (i) to communicate with you and/or an authorized representative; (ii) to provide services to and process transactions for you; (iii) to conduct business development activities, including providing information about our services; (iv) to comply with legal and regulatory requirements, including the prevention of money laundering and “know your customer” procedures, as well as any other obligations that apply to our business; (v) to evaluate suitability for our services; (vi) to perform due diligence and ongoing monitoring of service providers and counterparties; (vii) to fulfill contractual obligations; (vii) to maintain our website and applications; (ix) to engage with any party regarding complaints, litigation, and regulatory or government investigations in connection with Rotella Qdeck, its clients or its services; and (x) for other legitimate business purposes.

We may use your personal information to communicate with you about our services. Where required by applicable law, we obtain consent to process personal information and communicate with you for marketing purposes and to provide information about your investments. Where you have provided consent to receive these communications, you also have the right to unsubscribe by clicking on the link to unsubscribe on any of these communications or by emailing us at unsubscribe@rotellacapital.com.

How We Store and Retain Your Information

Your personal information is stored securely and access to it is limited in accordance with our Information Systems Security Policy (“ISSP”) and its procedures. We maintain electronic and physical safeguards, including limited access controls, to protect your personal information. All Rotella Qdeck employees are subject to the requirements of our compliance policies and procedures, as well as the specific safeguards set forth in our ISSP. We will take reasonable steps to protect your personal information against loss, theft and misappropriation, as well as from unauthorized access, copying or modification. In addition, if personal information is processed outside your country of residence, we have established safeguards to protect that information in accordance with applicable law.

The length of time we hold your personal information will vary. We retain your personal information for a minimum of five years from the date the relevant business relationship has ended. To the extent permitted by applicable law, we will retain personal information as long as it is needed for the business purpose for which it was provided, or we have another lawful basis to retain the information.

Information Transfer and Disclosure

To service your account and process your transactions, we may provide your information to firms that assist us in servicing your account and require such information. We require these service providers to protect the confidentiality of your information and use it only for the purpose of providing these services. If these services are provided outside the UK/European Economic Area (“EEA”), we will ensure safeguards are in place to protect your information, as required by applicable law.

By submitting your personal information to us, you consent to the transfer of your personal information to Rotella Qdeck and other recipients described in this notice that are located outside of the EEA. These countries may not be subject to the same standards of protection as required in the EEA. In such a case, we ensure that transfers of personal information outside the EEA are subject to approved standard data protection provisions. You may withdraw your consent to the transfer of data; however, the withdrawal of consent will not affect the lawful nature of information processing based on consent provided before withdrawal.

We do not disclose any personal information about customers or former customers to any third party except for the purposes described above in connection with the processing and servicing of customer accounts or as otherwise permitted or required by law.

Your Data Protection Rights

We want you to be certain that you are aware of all your data protection rights under applicable EU privacy laws. You have the right to request (i) the details of your personal information that we hold and request a copy of that information; (ii) we correct any personal information that is inaccurate or incomplete; (iii) we erase your personal information, although in certain circumstances we may be legally entitled to retain it; (iv) we restrict our use of your personal information, although in certain circumstances we may be legal entitled to continue to use it; (v) we do not use your personal information to market to you; (vi) we transfer your personal information to a third party.

If you exercise your rights of erasure or restriction, or refuse to provide certain personal information, it may limit our ability to provide services to you.

Changes to this Privacy Policy

We keep our Privacy Policy under regular review. This notice and the policies described may be updated periodically without notice to you to address changes in our privacy practices or in applicable law, rules or regulations. We will place any updates on this web page.

Contact Us

If you have questions or comments about our Privacy Policy or practices, please contact us by email or mail using the contact information below. You may also make a complaint in accordance with applicable privacy laws to a supervisory authority in your country of residence.

Email: privacypolicy@rotellacapital.com

Address: 800 Bellevue Way NE, Suite 200, Bellevue, WA 98004 USA

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