Effective Date: November 1, 2023

Polytope Research LLC (the "Firm") respects our clients' and investors' ("you" or "your") right to privacy. All financial companies choose how they share personal information. This notice is provided by the Firm, its affiliates, and funds (the "Firm", "we", or "us"). Please read this notice carefully to understand our practices and contact ir@polytope-research.com if you have any questions.

The Personal Information We Collect and How We Collect It

We generally collect the following types of personal information about you:

  • Identifiers, such as name, contact details and address (including physical address, email address, and IP address), and other identification (including government identification information);
  • Customer records information, such as telephone number, signature, bank account or other financial information (including anti-money laundering information), and verification information (such as social security number, income, and assets);
  • Protected classification characteristics under California or federal law, such as date of birth, demographic information, citizenship, and birthplace;
  • Commercial Information, such as account information, risk tolerance, investment experience and history, information regarding a potential and/or actual investment in a fund (including ownership percentage, capital investment, income and losses, and source of funds used), statements of net worth, information about other transactions with us, our Affiliates, or other financial institutions with which we have relationships; and
  • Internet or electronic network activity information, such as information regarding your use of our website, cookie data, as well as information you provide to us when you correspond with us

We generally collect this information from the following sources:

  • Information we receive from you in subscription agreements, questionnaires, in-person meetings and in other forms; such as name, address, account information, social security number, the types and amounts of investments, statements of net worth, telephone number, and other contact information;
  • Information we receive from you, Affiliates and other companies; about your investments or transactions with us, our affiliates, or other financial institutions with which we have relationships; and
  • Information we receive from third parties such as demographic information and information collected (e.g., to comply with law and regulation).

We may have collected some or all of the categories of personal information from you in the last twelve (12) months and shared some or all of this personal information with Affiliates and third-party service providers as described below. When you are no longer an investor or client, we may continue sharing your information as described in this notice.

How and Why We Share Personal Information

This section lists reasons why financial companies may share their customers' personal information. With respect to each reason, we explain whether the Firm chooses to share for this reason and, if we do share, whether you can limit this sharing.

  • For everyday business purposes: The Firm shares personal information for everyday business purposes, such as to:
    • process your transactions;
    • provide financial products or services to you;
    • maintain your investment(s);
    • secure business services, including printing, mailing, and processing or analyzing data;
    • secure professional services, including accounting and legal services; or
    • respond to court orders and legal investigations.
  • For our marketing purposes: The Firm shares personal information for our marketing purposes so that we can offer products and services to you.
  • For use by Affiliates in providing products and services to you: The Firm shares personal information for our Affiliates' use in providing you with products and services that meet your financial services needs.
  • For the everyday business purposes of Affiliates: The Firm shares personal information, including information about your credit worthiness, with our Affiliates for their everyday business purposes.
  • For use by Affiliates to market to you: The Firm shares personal information with Affiliates so that they can market to you.
  • For use by Non-Affiliates to market to you: The Firm shares personal information with Non-Affiliates so that they can market to you.

Your Rights

U.S. federal law provides you with the right to limit or "opt-out" of our sharing personal information under certain circumstances. For example, you have the right to opt-out of our sharing certain: (i) personal information with Non-Affiliates for their marketing purposes; (ii) personal information (for example, information regarding your credit worthiness like a credit report) with our Affiliates; and (iii) receiving marketing of products and services from our Affiliates based on any personal information that we share with them. U.S. state laws and individual companies may give you additional rights to limit sharing.

Please contact ir@polytope-research.com to exercise your rights. Your decision to opt-out under federal law will remain in effect until you tell us otherwise, and you may change your opt-out status at any time.

In addition, if you reside in California, you may have certain rights provided by the California Consumer Privacy Act of 2018 ("CCPA") with regards to your personal information, including the right to request we:

  • Delete personal information that we retain, subject to certain exceptions;
  • Disclose or provide access certain information regarding our collection, use, disclosure and sale of your personal information in the past twelve months; and
  • Disclose or provide access certain information regarding our collection, use, disclosure and sale of your personal information in the past twelve months; and

Other U.S. state laws and individual companies may give you additional rights to limit sharing.

Please contact ir@polytope-research.com to exercise your rights under the CCPA. We verify requests under the CCPA as required by the law.

How We Protect Your Personal Information

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

Definitions

Affiliates: Entities related to the Firm by common ownership or control. They can be financial and non-financial companies.

Non-Affiliates: Entities not related to the Firm by common ownership or control. They can be financial and non-financial companies.




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