Privacy policy Pharo is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Pharo Management, Inc (the “Investment Manager”) and Pharo Management (UK) LLP and Pharo Management (HK) Limited (each, an “Investment Advisor”, collectively, the “Investment Advisors”, and together with the Investment Manager, “Pharo Management”) are committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by Pharo Management is jointly controlled by the Investment Manager and the Investment Advisors and each of the Investment Manager and Investment Advisors is the data controller of your personal information. Where your details are provided to Pharo Management as a consequence of your investment in Pharo Macro Fund, Ltd., Pharo Trading Fund, Ltd., Pharo Gaia Fund, Ltd., or Pharo Africa Fund, Ltd. (each, a “Fund”; collectively, the “Funds”), then the Investment Manager and Investment Advisors, acting as data controllers, may themselves (or through a third party such as Citco Fund Services (Curacao) B.V. (the “Administrator”) acting in its capacity as the Fund’s administrator) process your personal information or that of your directors, officers, employees and/or beneficial owners. If you have your usual place of residence in the European Economic Area (EEA) or United Kingdom (UK), the EEA and UK Privacy Policy shall apply. If you have your usual place of residence in the United States (US), the US Privacy Policy shall apply. 1. EEA AND UK PRIVACY POLICY This policy (the “EU Privacy Policy”) explains the manner in which Pharo Management collects, utilizes and maintains non-public personal information relating to Applicants or investors (“Investors”) based in the EU or the European Economic Area (“EEA”) or UK, as required under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and Data Protection Act 2018. COLLECTION OF INVESTOR INFORMATION Pharo Management collects personal information relating to Investors in the Fund, such as Investors’ names, contact details and financial information, from the following sources: Subscription forms, investor questionnaires, account forms, and other information provided by the Investor in writing, in person, by telephone, electronically or by any other means. This information includes but is not limited to name, address, nationality, employment information, and financial and investment qualifications; Transactions within the Fund, including account balances, subscription amounts, redemptions and fees; Other interactions with Pharo Management (for example, discussions with our staff); and Verification services and consumer reporting agencies, including an Investor’s creditworthiness or credit history. (Pharo Management generally does not use these services.). WHY WE USE INVESTORS’ PERSONAL INFORMATION Your personal data may be processed by Pharo Management or the Administrator (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes: to facilitate the opening of your account with the Fund and the management and administration of your shareholdings in the Fund on an on-going basis (the “Services”) which are necessary for the performance of the Fund’s obligations to you, including without limitation the processing of redemptions, transfers and additional subscription requests and the payment of distributions, if any; in order to carry out anti-money laundering checks and related actions which Pharo Management, the Fund or Administrator considers appropriate to meet any legal obligations imposed on them relating to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with the Pharo Management’s, the Fund’s and the Administrator's anti-money laundering procedures; to comply with their legal obligations and, in particular, to report tax-related information to tax authorities; to monitor and record calls and electronic communications for (i) processing and verifying instructions, (ii) investigation and fraud prevention purposes, (iii) crime detection, prevention, investigation and prosecution, and (iv) enforcing or defending Pharo Management, the Fund, Administrator or their affiliates, themselves or through third parties to whom they delegate such responsibilities or rights in order to comply with any legal obligation imposed on them, or where the processing is in the public interest; to disclose information to other third parties such as service providers of Pharo Management, the Fund or Administrator, auditors, regulatory authorities and technology providers in order to comply with any legal obligation imposed on Pharo Management, the Fund or Administrator or in order to pursue the legitimate interests of Pharo Management, the Fund and the Administrator; to monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of Pharo Management, the Fund and the Administration to improve their delivery of services; to update and maintain records and fee calculations; to retain AML and other records of individuals to assist with the subsequent screening of them by the Administrator; to pursue the Fund’s legitimate interests, namely its direct marketing to selected professional investors; and which are necessary to comply with Pharo Management’s, the Fund’s or the Administrator’s legal obligations and/or which are necessary for Pharo Management’s, the Fund’s or the Administrator's legitimate interests indicated above and/or the processing is in the public interest. DISCLOSURE OF NONPUBLIC PERSONAL INFORMATION Pharo Management may share non-public personal information relating to Investors or potential Investors with affiliates, as permitted by law. Pharo Management does not disclose nonpublic personal information about Investors or potential Investors to non-affiliated third parties, except as permitted by law (for example, Pharo Management may share personal information with service providers, the Administrator and their affiliates, and other third party service providers in order to process the data for the above mentioned purposes). Such service providers are contractually restricted from using Investor information in any manner other than as mentioned above. Pharo Management may share nonpublic personal information, without an Investor’s consent, with affiliated and non-affiliated parties in the following situations, among others: To respond to a court order, judicial process or regulatory inquiry; In connection with a proposed or actual sale, merger, or transfer of all or a portion of its business; To protect or defend against fraud, unauthorized transactions (such as money laundering), lawsuits, claims or other liabilities; To service providers of the Fund in connection with the administration and operations of the Fund, which may include brokers, attorneys, accountants, auditors, administrators or other professionals; To assist Pharo Management in offering Pharo affiliated products and services to Investors; and To process or complete transactions requested by an Investor. COUNTRIES HAVING ACCESS TO INVESTORS’ PERSONAL INFORMATION Pharo Management’s servers which are used for storing and processing Investor information including personal data are located in countries which have an adequate level of protection or with which we have signed agreements incorporating the Standard Contract Clauses. Pharo Management also has a number of personnel and service providers who will have access to your personal information and which are located in other countries which have an adequate level of protection or with which we have signed agreements incorporating the Standard Contract Clauses. The disclosure of personal information to the third parties described above may involve the transfer of data to Hong Kong, the USA, Curacao, the Cayman Islands and other jurisdictions outside the EEA. Such countries may not have the same data protection laws as your jurisdiction. Pharo Management has authorized the Administrator as the Fund’s agent to put in place Standard Contractual Clauses with relevant parties to whom personal data will be transferred. Please contact the Administrator for copies of the Standard Contractual Clauses that have been entered into on behalf of Pharo Management and the Fund. COLLECTING INVESTOR INFORMATION LEGALLY There are a number of legal basis under which Pharo Management is permitted to legally collect and process your personal information, such as: you have given your consent for Pharo Management to do so as explained at the end of this EU Privacy Policy; and/or we have assessed that it is in our legitimate interests to process your personal data for limited market purposes in order to maintain, expand and develop our business; collecting and using your personal information is necessary for Pharo Management to fulfil our contractual obligations to you by virtue of you being an investor; it is necessary to comply with any applicable regulatory, judicial or legal obligation. RETENTION OF INVESTOR INFORMATION Pharo Management, the Fund and the Administrator will retain your personal information for as long as is required for them to perform the Services or perform investigations in relation to the Services and in order to enable them to comply with their legal obligations and exercise their legal rights. YOUR RIGHTS You have the right to: be informed about the personal information Pharo Management collects from you and uses, which this EU Privacy Policy seeks to do; obtain confirmation from Pharo Management that your personal information is being collected and used by Pharo Management and to access the personal information held by Pharo Management; have your personal information corrected if it is inaccurate or incomplete at any time; erasure, or the right to be forgotten, which means you can request deletion or removal of any personal information Pharo Management holds about you at any time, subject to Pharo Management’s legal obligations; block or suppress Pharo Management collecting and using your personal information, which means Pharo Management can continue to store such personal information but cannot further collect or use it in any way; obtain and reuse any personal information Pharo Management holds about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from Pharo Management to another place notified by you to Pharo Management in a safe and secure way without hindrance to the usability of your personal information; and object to Pharo Management collecting or using your personal information. where this is based on: a legitimate interest or the performance of a task in the public interest; or direct marketing. To make any requests as listed above, please contact the relevant Representative (as detailed below) depending on your location. Pharo Management will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where the request is more complex. WITHDRAWAL OF YOUR CONSENT Where Pharo Management relies on your consent to process your personal data, you can request that Pharo Management stop collecting and using your personal information at any time by emailing the relevant Representative (as detailed below) depending on your location. Where Pharo Management, the Fund or the Administrator requires your personal information to comply with AML or other legal requirements, failure to provide this information may mean that you will be unable to be accepted as an Investor in the Fund. You should note that notwithstanding your withdrawal of consent, we may be legally required to retain and/or continue processing some or all of Your Personal data. FORMER CUSTOMERS AND INVESTORS This same EU Privacy Policy applies to former Investors in the EU and the EEA. PROTECTION OF INVESTOR INFORMATION Pharo Management maintains appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards that comply with the GDPR to protect customer information, including: the pseudonymization and encryption of your personal information where appropriate; ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services; ensuring Pharo Management can restore access to personal information in a timely manner if a physical or technical incident occurs; and regular testing, assessment and evaluation of the effectiveness of its technical and organizational measures to ensure your personal information is secure. Pharo Management restricts access to the personal and account information of Investors to those employees who need to know that information in the course of their job responsibilities. Pharo Management will destroy, erase or make unreadable data, computer files and documents containing nonpublic personal information prior to disposal. JOB APPLICANTS Where you are an applicant for an employment position/ opening (“Applicants”) at Pharo Management (such as through https://www.pharo.com/careers/) each of the Investment Manager and Investment Advisors shall be data controllers with regard to your personal information. All relevant elements of this Privacy Policy shall apply to Applicants equally as it applies to Investors, including but not limited to, collection of information, disclosure of personal information, lawful collection of personal information, your rights, protection of personal information etc. Retention of personal data How long we hold your personal data for will vary. The retention period will be determined by various criteria including: the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data. In some instances, we may retain your information to consider you for other roles and future opportunities with us which may be of interest to you. If you do not want us to retain your information, or want us to update it at any stage, please contact the relevant Representative (as detailed below) depending on your location. FURTHER INFORMATION This EU Privacy Policy replaces all previous disclosures we may have provided you about our information practices in the EU. Pharo Management reserves the right to change this Privacy Policy at any time. The examples contained within this EU Privacy Policy are illustrations and are not intended to be exclusive. This Privacy Policy complies with the GDPR regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you. If you have any questions about this EU Privacy Policy, please contact the relevant Representative (as detailed below) depending on your location. UK REPRESENTATIVE Pharo Management (UK) LLP is the UK representative of Pharo Management, Inc, Pharo Management (UK) LLP, Pharo Management (HK) Limited, Pharo Macro Fund Ltd, Pharo Trading Fund Ltd, Pharo Gaia Fund Ltd, and Pharo Africa Fund Ltd. You can contact the UK representative at privacy@pharo.com. EU REPRESENTATIVE Laven, acting through its Paris branch located at 128 Rue La Boetie 75008 has been appointed designated representative of Pharo Management, Inc, Pharo Management (UK) LLP, Pharo Management (HK) Limited, Pharo Macro Fund Ltd, Pharo Trading Fund Ltd, Pharo Gaia Fund Ltd, and Pharo Africa Fund Ltd (“Group”), in accordance with art. 27 of the General Data Protection Regulation (the Regulation (EU) 2016/679) (“GDPR”). The Group has mandated Laven to be the European representative of the Group with regards to any communications or enquiry from EU supervisory authorities and/or EU data subjects on all issues related to the processing of personal data. Please contact Laven on info@eurorep.eu; the postal address is FAO EuroRep, c/o Laven (Tech) Limited, 128 Rue La Boetie 75008, Paris, France. When contacting Laven regarding the Group, please quote the name of the company and the Ref: 0089. MAKING A COMPLAINT If you would like to make a complaint about the way Pharo Management has collected or used your personal information, please contact the relevant Representative (detailed above) depending on your location. You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by Pharo Management or its service providers infringes the GDPR. 2. US PRIVACY POLICY This Privacy Policy describes how Pharo Management handles any personal information collected on this website. This Privacy Policy does not apply to information that Pharo Management may collect through other means. Please note that this Privacy Policy is supplemented by privacy notices tailored to our specific relationships with you, including privacy notices that are sent to individuals as required under applicable laws and regulations. INFORMATION WE COLLECT Personal Information When you visit the website, Pharo Management may collect certain personal information about you, such as: general identification and contact information such as your name and email address; and other personal information that you may provide through submission of forms or other documents. Non-personal Information Pharo Management will also collect the following non-personal information when you visit the website: through your browser or device, certain information is collected such as your IP address and domain name used (the IP address is a numerical identifier assigned either to your Internet service provider or directly to your computer); the type of browser and operating system you use; and the date, time, and duration for which you visit the website, the number of times you have visited the website, and where you come from. For the purposes of collecting some of the above-referenced information, Pharo Management uses tracking tools on the website, such as browser cookies and web beacons. A cookie and a web beacon are pieces of data stored on your device containing information about your visit. Third-party analytics service providers, such as Google Analytics, may use cookies and web beacons through the website to provide Pharo Management with information about how you use and interact with the website. HOW WE USE INFORMATION THAT WE COLLECT Pharo Management and the Fund may share personal information that it collects in the following ways: to respond to your requests or questions; to inform you about Pharo Management; to communicate with you about your relationship with us; to improve the website and the services provided; for security purposes; and for other purposes permitted by law. HOW WE SHARE INFORMATION THAT WE COLLECT Pharo Management may share your personal information with its employees, agents or third-party service providers for purposes of performing their jobs, including to respond to requests or questions that you may have. In addition, Pharo Management may share your information with governmental authorities or third parties for purposes of complying with legal requirements or to respond to legal requests, such as in the case of a court order or subpoena or in connection with a regulatory investigation. Finally, Pharo Management might also share information that it collects with others when it is investigating potential fraud or for other reasons as permitted by law. PROTECTION OF INFORMATION Pharo Management is strongly committed to protecting any personal information collected through the website against unauthorized access, use, or disclosure. Pharo Management will not sell or otherwise disclose any personal information collected from the website, other than as described herein. In addition, Pharo Management maintains appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards, including but not limited to: the pseudonymization and encryption of your personal information where appropriate; ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services; ensuring they can restore access to personal information in a timely manner if a physical or technical incident occurs; and regular testing, assessment and evaluation of the effectiveness of their technical and organizational measures to ensure your personal information is secure. These security procedures have been integrated into the design, implementation, and day-to-day operations of the website as part of a continuing commitment to the security of electronic content as well as the electronic transmission of information. For security purposes, Pharo Management employs software to monitor traffic to identify unauthorized attempts to upload or change information or otherwise damage the website. Any information that an individual provides to Pharo Management by visiting the website will be stored within the United States. If you live outside of the United States, you understand and agree that Pharo Management may store your information in the United States. The website is subject to US laws, which may or may not afford the same level of protection as those in your country. For information on how Pharo Management collects, utilizes, and maintains nonpublic personal information about individuals based in the European Union or the European Economic Area as required under the General Data Protection Regulation, please see Pharo Management’s EEA and UK Privacy Policy. TRACKING TOOLS As indicated above, Pharo Management collects non-personal information on the website through the use of tracking tools, such as browser cookies. Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. Options you select are browser and device specific. If you block or delete cookies, not all of the tracking that we have described in this Privacy Policy will stop. Some websites have "do not track" features that allow you to tell a website not to track you. These features are not all uniform. Pharo Management does not currently respond to those signals. If you block cookies, certain features on Pharo Management’s website may not work. If you block or reject cookies, not all of the tracking described herein will stop. CHILDREN The website is meant for adults. Pharo Management does not knowingly collect personally identifiable information from children under age 18. If you are a parent or legal guardian of a child under 18 who believes that child may have visited the website, please email us at the address below referenced in the “Contact Us” section. LINKS TO OTHER SITES OR THIRD-PARTY SERVICES If a link to a third-party site is included on the website and you click on it, you will be taken to a website that Pharo Management does not control. This Privacy Policy does not apply to the privacy practices of that website. Read the privacy policy of other websites carefully. We are not responsible for these third-party sites. FURTHER INFORMATION AND UPDATES This Privacy Policy should not be construed as giving business, legal, or other advice or warranting as fall-proof the security of information provided through the website. The internet is not 100% secure, and Pharo Management cannot promise that your use of the website will be completely safe. Pharo Management disclaims any liability with respect to any information obtained by a third party through illegal entry into or breach of the website. Pharo Management will maintain all information as long as needed to comply with internal policies or applicable laws or for record-keeping purposes. Pharo Management and the Funds each reserves the right to change this Privacy Policy at any time. Pharo Management will notify you of any material changes in this policy by posting an updated copy on the website. Please check the website periodically for updates. CONTACT US For questions regarding this Privacy Policy, please contact privacy@pharo.com. © Pharo Management (UK) LLP 2021 Terms of use & disclaimer Regulatory disclosures Privacy policy COVID-19 Statement LIBOR Transition Cookies Security Sitemap By continuing to browse this website you are agreeing to our use of cookies. View our cookie policy.