PRIVACY NOTICE
This Privacy Notice describes how Governors Lane LP and its affiliates (“Governors Lane” or “we”) collect, use, store, and disclose nonpublic or other sensitive personal information furnished to us by our clients and investors. This Privacy Notice does not apply to Governors Lane employees or job applicants.
This Privacy Notice replaces all previous statements of our consumer Privacy Notice and may be amended by us at any time. We will provide you revised policies if there are any changes in how we handle your nonpublic personal information. If you end your relationship with us, we will continue to adhere to the policies and practices described in this Privacy Notice. If you have any questions about this Privacy Notice you may email us at dataprivacy@govlane.com.
Information That We Collect. In connection with providing you with our services, we obtain nonpublic personal information about you that may include the following:
• Information that we receive from you in subscription documents or other forms, including your name, address, photograph, nationality, place of birth, social security number, assets, and income.
• Other information (including potentially sensitive information) that may be derived from the information and documentation that we collect.
• Information about your investments with us and our affiliates
This information is collected primarily (i) in subscription agreements and related documents and background checks to satisfy anti-money laundering and sanctions compliance obligations, (ii) in correspondence and conversations with us and our representatives, and (iii) in your everyday business dealings with us. We may also receive your personal information from third parties or other sources, such as third-party account administrators and publicly accessible sources (e.g., the internet or social media).
How We Use and Disclose Your Information. We, along with our affiliates, use or disclose information in a limited and carefully controlled manner. We may disclose your personal information to third parties, and we and such third parties may process your personal information for the reasons listed below.
Instances in which we may disclose such information include:
• Legal and everyday business purposes: Your personal information may be used and shared for the purposes of administering the relationship between us (including communications and reporting), monitoring and analyzing our activities, and everyday business purposes. Your personal information may also be processed to comply with our policies and applicable legal and regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, compliance, or responding to subpoenas, court orders or other requests for information from regulatory, supervisory, law enforcement, judicial or other government agencies) or in litigation.
• For marketing purposes: We may use your personal information to market our products and services to you.
• To effect a transaction or manage your investments: Your personal information may be disclosed to or processed by certain service providers we have engaged to help us to effect a transaction that you request, to service your account, to review your requests for subscriptions or withdrawals, and to manage your investments.
• With your authorization or for other purposes permitted by law: Your personal information may be disclosed with or processed by certain persons with your consent, upon your instruction, or for any purposes permitted by applicable law.
For the purposes discussed in this Privacy Policy, we may combine the information that we collect with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.
Cookies and Tracking Technologies
We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies, and logging technologies (collectively, “cookies”) to automatically collect certain information when you visits our websites or interact with us. For example, the websites use these technologies to automatically collect information so we can conduct analytics. We may also embed web beacons, tags, and pixels in the emails we send to you to help us understand how you interact with those messages, such as whether and when you opened an email or clicked on any content within the email.
You may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies. However, if you block or otherwise reject cookies or similar technologies, certain websites (including this website) may not function as expected. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Analytics
We may use third-party web analytics services on our websites, such as those of Google Analytics. These service providers use the sort of technology described in the “Cookies and Tracking Technologies” section above to help us analyze how users use the websites, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the websites.
Without refusing cookies through your browser, you can opt out of Google Analytics by installing a Google Analytics Opt-out Browser Add-on for each web browser you use.
Notice Concerning Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. At this time, we do not recognize or respond to DNT signals. You can learn more about Do Not Track here.
Confidentiality and Security. We maintain technical, organizational, and administrative safeguards to protect your personal information. Our employees have limited access to your nonpublic personal information based upon their respective responsibilities. All employees are instructed to protect the confidentiality of your nonpublic personal information as described in these policies, which are strictly enforced.
Information for California Residents.
If you are a California resident, California law requires us to provide you with some additional information regarding how Governor’s Lane collects, uses, and discloses your “personal information” and “sensitive personal information” (as those terms are defined in the California Consumer Privacy Act (“CCPA”)). Terms defined in the CCPA have the same meaning when used in this notice. This notice only applies to California residents (“consumers” or “you”).
Please note the CCPA’s scope excludes personal information covered by certain financial services-specific privacy laws, including the Gramm-Leach-Bliley Act (“GLBA”) and the California Financial Information Privacy Act (“FIPA”). Our separate Privacy Notice that is provided to investors applies to this excluded data and has been provided to our fund investors.
Depending on how you interact with our website and services, we may collect the following categories of information from you, in addition to the information we collect in connection with providing financial products and services.
• Identifiers. Examples: A real name, alias, email address, postal address, account name, IP address, mobile device identifier, or other similar personal identifiers.
o We collect this information directly from you, through your use of our services, and third parties such as third-party account administrators and publicly accessible sources (e.g., the internet or social media).
o Our business and commercial purposes for collecting and disclosing this information are to operate our website, to perform services such as account servicing and internal operations, communicate with you, legal/compliance, and for everyday business purposes.
o We disclose identifiers to service providers, including Google Analytics as well as legal or governmental authorities when required by applicable law, or other parties in connection with a sale, acquisition, merger, or similar transaction related to our business.
• Internet usage information. Examples: Browsing history and use and interaction with our website.
o We collect this information through your use of our services.
o Our business and commercial purposes for collecting and disclosing this information are to operate our website, to communicate with you, and for legal and everyday business purposes.
o We disclose this information to service providers, including Google Analytics, as well as legal or governmental authorities when required by applicable law, or other parties in connection with a sale, acquisition, merger, or similar transaction related to our business.
• Professional or employment-related information. Examples: current employment and employment history.
o We collect this information directly from you and third parties such as third-party account administrators and publicly accessible sources (e.g., the internet or social media).
o Our business and commercial purposes for collecting and disclosing this information are to perform services such as account servicing and internal operations, communicate with you, legal/compliance, and for everyday business purposes.
o We disclose this information to service providers as well as legal or governmental authorities when required by applicable law, or other parties in connection with a sale, acquisition, merger, or similar transaction related to our business.
• Financial data. Examples: bank account number or other financial information.
o We collect this information directly from you.
o. Our business and commercial purposes for collecting and disclosing this information are to perform services such as account servicing and internal operations, legal/compliance, and for everyday business purposes.
o We disclose this information to service providers as well as legal or governmental authorities when required by applicable law, or other parties in connection with a sale, acquisition, merger, or similar transaction related to our business.
• Protected classification characteristics under California or federal law. Examples: Age, citizenship.
o We collect this information directly from you.
o Our business and commercial purposes for collecting and disclosing this information are to perform services such as account servicing and internal operations, legal/compliance, and for everyday business purposes.
o We disclose this information to service providers as well as legal or governmental authorities when required by applicable law, or other parties in connection with a sale, acquisition, merger, or similar transaction related to our business.
• Sensitive personal information. Examples: Social Security number, driver’s license number, passport number.
o We collect this information directly from you.
o Our business and commercial purposes for collecting and disclosing this information are to perform services such as account servicing and internal operations, legal/compliance, and for everyday business purposes.
o We disclose this information to service providers as well as legal or governmental authorities when required by applicable law, or other parties in connection with a sale, acquisition, merger, or similar transaction related to our business.
• Other information that identifies or can be reasonably associated with you
For more information on how we use and disclose this information and the categories of entities to which we disclose your information, please see the “How We Use and Disclose Information” section of the privacy notice, above.
We do not knowingly collect, solicit or disclose Personal Information from anyone under the age of 18.
Data Retention
We will retain Personal Information, including sensitive personal information, until we determine it is no longer necessary to satisfy the purposes for which it was collected and our legal obligations. As described above, these purposes include our business operations and complying with reporting, legal and accounting obligations. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process the personal information and whether we can achieve those purposes in other ways, the applicable legal requirements, and our legitimate interests.
Rights of California Consumers
The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:
• The right to request: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our business or commercial purposes for collecting, selling or sharing your Personal Information; (d) the categories of Personal Information disclosed for a business purpose and the categories of persons to whom it was disclosed; (e) the categories of your Personal Information (if any) that we have either sold, shared, or disclosed.
• The right to request that we delete your Personal Information, subject to certain exceptions.
• The right to opt out of our sale(s) or “sharing” (if any) of your Personal Information.
• The right to request we correct any inaccurate Personal Information maintained about you.
• The right to limit our use of your sensitive personal information to only use that is necessary to perform the services expected or provide the goods reasonably expected.
• The right not to receive discriminatory treatment for exercising your CCPA rights.
Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our services to you. If you ask us to delete it, you may no longer be able to access or use the services. You may submit requests relating to your exercise of your rights to us via: dataprivacy@govlane.com or 212-887-4000.
You may only make a verifiable request for access or data portability twice within a 12-month period. All verifiable requests must provide (1) enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and (2) sufficient detail that allows us to properly evaluate and respond to it. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
We do not sell or share (as those terms are defined in the CCPA) your personal information to third parties.
We do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.
If you have questions regarding this Notice, please contact us at dataprivacy@govlane.com.
Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
Updated: August 15, 2023