The Parthenon - Athens, Greece

Privacy Policy

Privacy Policy for U.S. and Non-European Investors

We take precautions to maintain the privacy of personal information concerning the current and prospective individual Subscribers.  These precautions include the adoption of certain procedures designed to maintain and secure such Subscribers’ nonpublic personal information from inappropriate disclosure to third parties.  Federal regulations require the Fund to inform Subscribers of this privacy policy.

We collect nonpublic personal information about its Subscribers from the following sources:

  • Information we from a Subscriber in these Subscription Documents or other related documents or forms;
  • Information about a Subscriber’s transactions with us, our affiliates, or others, including service providers that are necessary to carry on our everyday business; and
  • Information we may receive from a consumer reporting agency.

We do not disclose any nonpublic personal information about prospective, existing or former Subscribers to anyone, except to service providers that have been advised as to proper handling of the information and otherwise as permitted or required by law and regulation.

We restrict access to nonpublic personal information about Subscribers to those employees and our agents who have been advised as to the proper handling of such information and who need to know that information in order to provide services to its Subscribers.  We may also disclose such information to our affiliates and to service providers and financial institutions that provide services to us that are necessary or appropriate for the administration of your account and the effectuation of its transactions or are otherwise permitted by law, such as prime brokers and administrators. We will require such third- party service providers and financial institutions to protect the confidentiality of the Subscribers’ nonpublic personal information and to use the information only for purposes for which it is disclosed to them.  We may also disclose nonpublic personal information to regulatory authorities as required or permitted by applicable law.  We maintain physical, electronic, and procedural safeguards that comply with federal standards to safeguard the

Privacy Policy for European Investors Only
  1. Introduction
    1. We are committed to safeguarding the privacy of website visitors and service users.
    2. This policy applies where we are acting as a data controller with respect to the personal data of service users; in other words, where we determine the purposes and means of the processing of that personal data.
    3. In this policy, “we”, “us” and “our” refer to Vanshap Capital, LLC. For more information about us, see Section 10.
  2. Credit
    1. This document was created using a template from SEQ Legal (https://seqlegal.com).
  3. How we use your personal data
    1. In this Section 3 we have set out:
      1. the general categories of personal data that we may process;
      2. the purposes for which we may process personal data; and
      3. the legal bases of the processing.
    2. We may process your account data (“account and transaction data”). The account and transaction data may include your name, email address, mailing address, Tax ID, driver’s license, and bank account information. The source of the account and transaction data is you. The account data may be processed for providing our services and communicating with you. The legal basis for this is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and legitimate interests, namely the proper administration of our business and compliance with investment adviser record retention rules in the United States.
    3. We may process information contained in any enquiry you submit to us regarding receiving detailed information about us and/or our services (“enquiry data”). Enquiry data typically only includes a name, employer name, and email address but in certain cases may also include a mailing address, phone number, and investor qualification data. The enquiry data may be processed for the purposes of offering, marketing and selling investment services to you. The legal basis for this processing is Consent.
    4. We may process information contained in or relating to any communication that you send to us or that we send to you (“correspondence data”). The correspondence data will typically include your email address and requests or instructions received via email or physical mail. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and compliance with investment adviser record retention rules in the United States.
    5. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    6. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
    7. In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for regulatory compliance or with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
    8. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
  4. Providing your personal data to others
    1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy
    2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
    3. We may disclose personal data to our service providers as reasonably necessary for conducting legitimate business interests namely the proper administration of our business and compliance with investment adviser record retention rules in the United States.
    4. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for regulatory compliance or with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  5. International transfers of your personal data
    1. We and our other group companies have our offices in the United States and therefore subject to local privacy, compliance, and record retention obligations as established by the United States. These laws may contradict or may not meet the minimum thresholds or standards as established by the European Commission.
  6. Retaining and deleting personal data
    1. This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    3. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for regulatory compliance or with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  7. Amendments
    1. We may update this policy from time to time. We may notify you of significant changes to this policy by email or written communication.
  8. Your rights
    1. In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    2. Your principal rights under data protection law are:
      1. the right to access;
      2. the right to rectification;
      3. the right to erasure;
      4. the right to restrict processing;
      5. the right to object to processing;
      6. the right to data portability;
      7. the right to complain to a supervisory authority; and
      8. the right to withdraw consent.
    3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
    4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
    5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance or legal obligations; or for the establishment, exercise or defence of legal claims.
    6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
    7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
    8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
    9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
    10. To the extent that the legal basis for our processing of your personal data is:
      1. consent; or
      2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

      and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

    11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
    12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
    13. You may exercise any of your rights in relation to your personal data by written notice to us.
    14. Cookies
      1. Our website, www.vanshapcapital.com uses cookies to allow you to sign into the password protected areas and to understand how you use our website. Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our website we may collect information from you automatically through the use of cookies or similar technology. You can set your browser not to accept cookies, and the website below tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result. For further information, visit allaboutcookies.org.
      2. Our company uses cookies for two primary purposes. 1) Functionality; our company uses cookies so that we recognize you on our website and your ability to login to password protected areas. 2) Activity tracking; Our company uses cookies to collect information about your visit to our website including the content viewed.
    15. Our details
      1. Our website is owned and operated by Vanshap Capital, LLC.
      2. We are registered with the Securities and Exchange Commission as an investment adviser in the United States under registration CRD# 162206.
      3. Our principal place of business is at 1530 Wilson Boulevard, Suite 530 Arlington, VA 22209
      4. You can contact us:
        1. by the postal address given above;
        2. by telephone at 571-933-6950 or
        3. by email at partners@vanshapcapital.com
      5. You can contact the Data Protection Officer, David Shapiro:
        1. by the postal address given above;
        2. by telephone at 571-933-6952 or
        3. by email at dshapiro@vanshapcapital.com