Home Our Edge Investment Capabilities Leadership Contact Client Portal Privacy Click here to read more about Privacy in the European Economic Area (EEA). Effective: October 15, 2020 YOUR PRIVACY IS IMPORTANT TO US. PLEASE READ THIS PRIVACY POLICY TO LEARN ABOUT THE INFORMATION THAT PAAMCO PRISMA, LLC COLLECTS FROM YOU AND HOW PAAMCO PRISMA, LLC USES THAT INFORMATION. This Privacy Policy applies to information that PAAMCO Prisma, LLC and its affiliates (collectively, “PAAMCO Prisma”, “we,” “us”, or “our”) collect on www.paamcoprisma.com (the “Site”) and any other PAAMCO Prisma websites, applications, and digital services on or to which this Privacy Policy is linked or referenced. This Privacy Policy does not apply to services that do not display or link to this Privacy Policy. BY USING THE SITE YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SITE. 1. SCOPE This Privacy Policy describes the information we collect and why we collect it, what we do with the information we collect, and how you can manage your Personal Data (defined below). This Privacy Policy does not apply to information that is collected by any third-party websites or services that you may access through the Site. Our agreements with certain customers may contain provisions about the collection, use, storage, and disposal of information collected through the Site and offline. If a provision of a customer agreement conflicts or otherwise is inconsistent with a provision of this Privacy Policy, then the provision of the customer agreement will prevail but solely to the extent of the conflict or inconsistency. This Privacy Policy is incorporated into and made a part of PAAMCO Prisma’s Terms of Use. If you have not done so already, please also review the Terms of Use. The Terms of Use include provisions that limit PAAMCO Prisma’s liability to users and other important terms. 2. INFORMATION WE COLLECT Personal Data is information that directly or indirectly identifies you as an individual, such as your name, email address, mailing address, telephone number and location. Activity Data is information that, by itself, does not individually identify you, such as browser type, operating system, the webpages you viewed and how long you viewed them. PAAMCO Prisma generally does not treat Activity Data as Personal Data. We may, however, link together different types of Activity Data or link Activity Data to Personal Data. If linked information identifies (or can be used to identify) an individual person, PAAMCO Prisma treats the linked information as Personal Data. 3. HOW WE COLLECT INFORMATION PAAMCO Prisma collects information in the following ways: When You Give PAAMCO Prisma Information You are required to create an account to use certain features of the Site. When you create an account, we ask you for Personal Data, such as your name, email address, telephone number, and the type of investor you are (e.g., individual, analyst, broker). We may also collect and retain a record of all communications with you. Data Collection Technology We use Data Collection Technology that collects information, such as how long you spend on various webpages on the Site, which webpages you view, your search queries, error and performance reports and the webpages that you visited before and after using the Sites, as well as browser type, time zone, language settings, and operating system. Data Collection Technology deployed through the Site includes web beacons, cookies, and analytic services. A web beacon (also called a pixel tag or clear GIF) is computer code that communicates information from your device to a server. Some of PAAMCO Prisma’s content and emails may contain embedded web beacons that allow a server to read certain types of information from your device, allow us to count the number of people who have viewed content, to know when you opened an email message and the IP address of your device. Web beacons help PAAMCO Prisma develop statistical information to provide better and more personalized content. Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history, and activities conducted while using the Site. To learn more about cookies and web beacons, visit www.allaboutcookies.org. Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Site. PAAMCO Prisma also uses analytics services, such as Google Analytics, to collect Activity Data. Generally analytics services do not identify individual users. Many analytics services allow you to opt out of data collection. For example, to learn more about Google Analytics practices and to opt out, visit www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout. Collection of Investor Information PAAMCO Prisma may also collect or receive Personal Data regarding investors from sources including: subscription documents or other related documents or forms; consumer reporting agencies; and investor transactions with PAAMCO Prisma, its affiliates, or other parties. 4. DO NOT TRACK PAAMCO Prisma does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you. 5. HOW WE USE AND SHARE YOUR INFORMATION PAAMCO Prisma does not disclose any Personal Data about its Site users to any nonaffiliated third party, except as set forth below. We may use or disclose certain Personal Data we collect about you when you visit and browse the Site as part of our normal business operations, or to send you administrative communications either about your interactions with us or about features of the Site, including any future changes to this Privacy Policy. We may also store your Personal Data and share it with our affiliates, which are other financial institutions that provide investment-related research and services to PAAMCO Prisma, as permitted under applicable law. Personal Data shared with PAAMCO Prisma affiliates can include names, addresses, taxpayer identification number, assets under management, fees received, and performance returns. We may use or disclose this information for marketing, research and other business purposes, and we may associate your Personal Data with other information we collect about you, such as details about your usage patterns and interests, but we will not sell this information or disclose it to third parties. We may also use service providers to facilitate our services or platform functions on our behalf. These companies and individuals may have access to your Personal Data, as needed to perform their functions, but may not use it for another purpose. We will use or disclose Personal Data when we believe that such disclosures are required by law, regulation, legal process, subpoena, document request, or governmental request. For example, it may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them. We may also do so to help enforce our Terms of Use, protect your safety or security, including the safety and security of property that belongs to you, or protect the safety and security of our websites, databases or third parties, including the safety and security of tangible or intangible property that belongs to us or to third parties. Also, in the event that PAAMCO Prisma, or substantially all of the assets of PAAMCO Prisma or one or more of its businesses, are acquired or merged with another entity, whether an affiliate or a third party, user information may be one of the transferred assets. We may transfer all user information (which may include Personal Data) to our acquirers or successors. However, PAAMCO Prisma reserves the right to use any Personal Data in any manner permitted by law. 6. HOW WE PROTECT AND STORE INFORMATION PAAMCO Prisma takes precautions intended to help protect information that we collect and store. However, no system or electronic data transmission is completely secure. Any transmission is at your own risk and we expect that you will use appropriate security measures to protect your information. You are responsible for maintaining the security of your account credentials and other authentication involved in obtaining access to password-protected or secure areas of the Site. PAAMCO Prisma will treat access to the Site through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Site without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below. PAAMCO Prisma maintains physical, electronic, and procedural safeguards to protect Personal Data. Employees with access to Personal Data are supervised and receive periodic training on implementation of this Privacy Policy. PAAMCO Prisma retains information for as long as necessary to fulfill the purposes for which you provided the information, to comply with law legal obligations, to resolve disputes, to enforce agreements, and for other similar essential purposes. 7. LINKS TO OTHER WEBSITES AND SERVICES The Site may include links to third-party websites and services which are not operated by us. When you click these links, you are navigating away from the Site. A link to a third-party website or digital service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or digital service, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any Personal Data that you provide to these other websites and services. 8. NOTICE TO INTERNATIONAL VISITORS The Site is operated by PAAMCO Prisma in the United States but the information that you provide is accessible to affiliates, vendors, and suppliers in other countries. If you are visiting the Site from a country other than the United States, your communication with PAAMCO Prisma will necessarily result in the transfer of information across international boundaries. The level of legal protection for Personal Data is not the same in all countries. If you are using the Site from outside of the United States, by providing your Personal Data to us, you consent to the transfer of your Personal Data to the United States for processing consistent with this Privacy Policy in the United States and in any country to which we may transfer your information in the course of our business operations. 9. LIMITATION OF LIABILITY AND DISCLAIMERS PAAMCO Prisma, its affiliates and their respective officers, directors, managers, partners, members, shareholders, employees, affiliates, and agents (collectively “Related Persons”) make no representations or warranties and specifically disclaim any and all warranties of any kind, express or implied, whether oral or written, with respect to the Site and the Content, including any representations or warranties with respect to merchantability, fitness for a particular purpose, title, non-infringement, availability, security, accuracy, freedom from viruses or malware, completeness, timeliness, functionality, reliability, sequencing, or speed of delivery. Your use of the Site and the Content is on an “as is” and “as available” basis to the fullest extent permissible under applicable law. Any oral or written advice provided by PAAMCO Prisma and its agents does not, and will not, create any warranty. In no event shall PAAMCO Prisma, its affiliates, or their Related Persons be liable to any party for any claims, liabilities, losses, costs, or damages under any theory, including but not limited to any direct, indirect, punitive, special, incidental, reliance, consequential, or exemplary damages, including lost profits, loss of data, or damage to real, tangible or intangible property arising out of, or in connection with, any access, use (or inability to use), or distribution of the Site or any Content therein. This is true even if PAAMCO Prisma has been advised of the possibility of such damages or losses. YOU AGREE THAT PAAMCO PRISMA’S MAXIMUM LIABILITY UNDER THESE TERMS IS LIMITED TO $1,000. YOU FURTHER AGREE THAT THE LIMITATIONS OF LIABILITY SET FORTH ABOVE WILL SURVIVE ANY TERMINATION OR EXPIRATION OF THESE TERMS AND WILL APPLY EVEN IF ANY LIMITED REMEDY SPECIFIED HEREIN IS FOUND TO HAVE FAILED OF ITS ESSENTIAL PURPOSE. APPLICABLE LAW MAY NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY OR DAMAGES. ACCORDINGLY, THE EXCLUSIONS AND LIMITATIONS SET FORTH ABOVE MAY NOT APPLY IN THEIR ENTIRETY TO YOU. YOU UNDERSTAND AND AGREE, HOWEVER, THAT OUR LIABILITY WILL BE LIMITED TO THE EXTENT PERMITTED BY LAW. You acknowledge and agree that the above limitations of liability, together with the other provisions in these Terms that limit liability, are essential terms and that PAAMCO Prisma would not be willing to grant you the rights set forth in these Terms but for your agreement to the above limitations of liability. 10. GOVERNING LAW AND FORUM The laws of the State of New York govern these Terms of Use. Any dispute relating to these Terms of Use or your use of the Site shall be resolved solely in the state or federal courts located in New York City. You agree to waive trial by jury in any such action. 11. CHANGES TO THIS PRIVACY POLICY The Effective Date of this Privacy Policy is set forth at the top of this webpage. We reserve the right to change our Privacy Policy as business needs require. If we make material changes to the way we use Personal Data, we will post a notice about the changes prominently in the Site. Your continued use of the Site after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions. HOW TO CONTACT PAAMCO PRISMA Please contact us at: NEWPORT BEACH 660 Newport Center Drive Suite 930 Newport Beach, California 92660 Phone: +1 (949) 261-4900 NEWPORT BEACH 660 Newport Center Drive Suite 930 Newport Beach, California 92660 Phone: +1 (949) 261-4900 LONDON 11 Bressenden Place Suite 6.04 London, SW1E 5BY Phone: +44 (0) 20 3905 2900 MEXICO CITY Phone: +52 55 3300 5872 ISTANBUL Phone +90 212 386 28 60 ©2021 PAAMCO Prisma | Privacy | CCPA | EU and Cayman Privacy | Terms of Use Home Our Edge Investment Capabilities Leadership Contact Client Portal You can opt-out if you wish. Cookie settings ACCEPT