Last Updated: September 2023
This Privacy Policy describes how Universa Investments L.P. and its affiliates (collectively, “Universa”, “we”, “us”, or “our”) collect, use, store and disclose personal information we obtain from certain sources indicated below and it describes the rights applicable to California residents with respect to their personal information. Prior versions of this Privacy Policy are available here that describe how we have collected, used, stored and disclosed such information for the past 12 months.
By visiting this website made available by Universa (the “Site”), you agree to be bound to the terms and conditions of this Privacy Policy and Terms of Use, which may be updated by us at any time. Your continued engagement with the Site or our services to which this Privacy Policy applies (see “Scope” below) after any such revisions indicates that you accept and consent to them, so please check this Privacy Policy periodically for updates. If you do not agree, please do not use or access the Site or our applicable services.
This Privacy Policy describes how we collect, use, store and disclose personal information we obtain through the Site and how, while a “business” under the California Consumer Privacy Act (“CCPA”), we (including the entities we control within our business) otherwise collect, use and disclose personal information about California residents who engage with us in a business-to-business capacity, as vendors, prospective business customers, office visitors, event attendees, or as individuals whose personal information is otherwise stored or processed in our contact management records or other systems.
This Privacy Policy does not apply to certain information that we or our service providers collect, use and disclose with respect to individuals who engage with us for investment services. They will receive our separate Privacy Notice governed by federal law at the time they seek such investment related services.
We may collect and maintain personal information in a number of ways, including when you visit our office and when you contact us by email or telephone.
• Identifiers. We collect contact information, such as name, email, address, phone number and title, if you or your representative provide us with this information in connection with prospective services or if they work with us as a service provider or vendor to our business. We also collect contact information from those who register for or attend our sponsored events. We use this information to communicate with such persons and conduct our business relationships.
• Information Collected Through Technology. We collect information about you automatically to support our business operations. We use cookies that are necessary to allow the technical operation of our Site and to enhance the security and functionality of our Site features, such as third-party cookies for embedded video performance. If you do not allow these cookies, some or all Site features may not function properly. These cookies do not track your activity on other websites. On password-protected Site pages, we also collect your username, password, IP address and location to improve the operation of the interactive features on those pages and to promote the security of those features available on those pages.
• Commercial Information. We may collect information needed for our operations, such as bank account information to process invoices and payments, transaction history and signatures. We also collect personal information to diligence prospective investments or as otherwise appropriate to pursue our investment strategies.
• Professional and Education Information. We may collect information needed for our operations, such as background or educational information, references, emergency contact information, information to identify conflicts of interest and similar information as needed to comply with our policies and procedures.
• Other Electronic Network Activity Information. We maintain various security measures to protect our technology infrastructure and may monitor those who connect to our internet network or otherwise interact with our technology infrastructure, such as by collecting browsing history or information about the device connected to our network.
• Audio and Visual Information. We maintain various security measures to protect our premises, including video cameras, and to facilitate our operations we may also collect audio recordings from those who contact us.
• Physical Security Information. We maintain various physical, technical and administrative security measures to protect our premises and operations, which capture personal information. These may include badges to enter the building and access certain parts of the premises and sign‐in processes for guests.
If you have provided us with non-personally identifiable information, including anonymous information and aggregate data collected automatically through cookies, we may use such non-personally identifiable information to understand better how visitors use the Site and to improve the Site. You can manage or disable cookies at any time by adjusting your browser settings. Please refer to the settings menu of your browser for instructions on how to change your cookie preferences.
We also collect identifying information, sensitive personal information (such as social security, driver’s license and passport numbers and bank account information) and additional commercial information as needed to effect investment transactions and provide investment services, as described in our Privacy Notice provided to those who engage with us for investment services.
Much of the information referenced above will have been provided by you, but some may come from other sources, such as your representatives, your business contact at Universa, automated sources (as described above) or a mutual referral contact.
We use personal information under this Privacy Policy, and consistent with our separate Privacy Notice for those who seek our investment services, to operate our business. For example, we may use personal information:
• To evaluate and effect investment transactions and contracts, manage the investment services we provide you and help maintain the administration, safety, security and integrity of our business and assets;
• To comply with any applicable compliance, legal and regulatory obligations, lawful requests and legal processes (such as to respond to subpoenas and requests during government investigations) as we believe appropriate, and to comply with the compliance obligations required by our service providers;
• To communicate with you about investments, our other services and products, and updates regarding our firm;
• To improve the services provided to you, as well as understand your interests and personalize your experiences with us;
• For marketing and promotional communications (as permitted by law and to the extent you do not opt out of receiving such promotional communications); and
• On occasion, we may ask for your consent to use your personal information for purpose(s) we explain at that time.
If you do not provide requested information in connection with our operations, we may be unable in some circumstances to comply with our obligations or pursue a relationship with you, and we will tell you about the implications of that decision.
It is our policy to not disclose your personal information, except we may disclose your personal information as permitted by law or otherwise described in this Privacy Policy and our separate Privacy Notice for those who seek our investment services, to the following types of parties:
• Our affiliates, for our and our affiliates’ purposes consistent with this Privacy Policy and consistent with our separate Privacy Notice;
• Service providers that act on our behalf and help us with our operations (for example, administrators or companies that assist us with hosting, database management services, processing transactions, generating financial reports, data processing, tax filings, technology services and maintaining books and records), provided, that these third parties may use your personal information only as authorized by their contracts with us;
• Our professional advisors, such as lawyers, bankers, accountants, brokers and insurers in the course of the professional services that they render to us;
• Another company, in the case of a proposed or actual merger, or acquisition or sale of all or part of our business;
• Any third party as required to comply with a law, regulation, or legal request (including for anti-money laundering purposes, know your customer requirements, tax reporting, as we believe necessary or appropriate to comply with lawful requests and legal process, such as a request from a government authority, and in response to requests from self-regulatory organizations and non-governmental regulators), for fraud prevention, or to protect the property or rights of us or others (however, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party or government request to disclose your information); and
• Any third party to which you direct us to disclose your personal information or which you consent to the disclosure of your personal information.
We do not sell personal information and we do not share personal information for cross-context behavioral advertising.
Our services are not directed to, and we do not knowingly collect or share personal information from anyone under the age of 16.
Our Site is not designed to respond to “do not track” signals received from browsers.
Our Site does not send any tracking technologies or cookies and, therefore, does not use Global Privacy Control.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means. We specify retention periods for our records, including your personal information, in our policies and procedures.
If you are a California resident, you may have certain rights if your personal information is protected by applicable California law, including the following rights (subject to certain exceptions and limitations):
• Right to Know. You have the right to request (a) the categories and specific pieces of personal information we collect and disclose; (b) the categories of sources from which we have collected your personal information; (c) the categories of third parties to whom your personal information was shared or disclosed for a business purpose; and (d) the business purposes for such collection and disclosure of your personal information.
• Right to Request. You have the right to request a list of the personal information (if any) disclosed to third parties for direct marketing purposes in the prior 12 months.
• Right to Delete. You have the right to access and then delete your personal information that we have collected from you or maintained about you (except to the extent we are required by law to retain any record).
• Right to Correct Inaccurate Information. If we maintain inaccurate information about you, you have the right to request correction of that inaccurate personal information, taking into account the nature of the personal information and the purposes of the personal information processing. We will use commercially reasonable efforts to correct this information.
• Right to Limit. We do not use or disclose sensitive personal information for purposes other than those permitted by CCPA regulations section 7027(m).
• Right to Opt-Out. You have the right to opt-out of the sale or sharing of personal information for cross-context behavioral advertising. However, we do not sell or share any personal information for cross-context behavioral advertising.
California residents also have the right to not be discriminated against for exercising any of the rights described above.
If you are a California resident and wish to exercise these rights, please contact us at 786-483-3140 or email at Contact@universa.net. There are circumstances where we are not required to comply with consumer requests and we will let you know if one of those situations is applicable.
We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please contact Compliance@universa.net.
To help protect your privacy and maintain security, we will verify your identity before granting access to your personal information or complying with your request. If you request to access or delete your personal information, we will verify your identity by comparing information we have on file against information you may provide us. If you designate an authorized agent to make a request to access or delete your personal information on your behalf, we may require you to (1) provide the authorized agent written permission to do so, and (2) verify your own identity directly with us (as described above).
We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
Please contact us if you are disabled and need a copy of this Privacy Policy prepared for you in a manner that is accessible. Any such request may be made via phone at 786-483-3140 or via e-mail at Compliance@universa.net.