Privacy Statement

Aperture Investors, LLC and its affiliates (collectively, “Aperture”) take your privacy and the security of your personal information seriously. This Privacy Statement (the “Privacy Statement”) is meant to help you understand what personal information we collect on you, how we use and protect such information and the rights and choices you have with regard to such information.

Please read this Privacy Statement carefully. In the event that you have any questions or concerns about the guidelines set forth in this Privacy Statement, please contact us at the contact details set forth at the end of this Privacy Statement.

A. What Information Do We Collect About You?

We may collect personal information that you provide to us directly (for example, your name, title, postal and email address, investable assets, investor type, social media profiles) and we may also collect information that you provide to us indirectly (for example, your IP address, browser type and version). Some examples of instances where and how we collect information about you are provided below.

When You Visit and Browse our Website

We collect general information about the devices you use to access our website and services (such as make, model, operating system, IP address, and browser type) and information about your online behavior. By collecting this information, we learn how to best tailor our website for our current and future visitors. To collect this information, we use technical methods such as cookies, as further explained below.

Cookies and Other Similar Technologies

Aperture and our third-party service providers utilize “cookies” and similar technologies to support the operation of our website and the offering of our services and products. Cookies are small files of data that a website or online service exchanges with a web browser or application on a visitor’s device (e.g., computer, tablet, or mobile phone). Cookies help Aperture collect information about users of our website, including date and time of visits, pages viewed, amount of time spent using our website, or general information about the device used to access our website. You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie, or if you delete cookies from your device, you may experience some inconvenience in your use of our website. For example, we may not be able to recognize you, your device, or your online preferences. Both Aperture and our third-party service providers may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising.

When You Join Us For the Latest Updates

If you select the option entitled, “Join Us For the Latest Updates,” we will collect the personal information you provide in order to complete your registration. However, there is no obligation to select this option, and your choice will not affect your ability to use our website.

When You Contact Us or When We Contact You

We collect personal information you provide about yourself anytime you contact us about our website or services. You can choose not to provide this information, but then you might not be able to send us requests via our website. We may also use technical methods in HTML e-mails that we send visitors to our website to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails.

B. How Do We Use Your Personal Information?

We may use or share some of the personal information we collect about you with our affiliates or third-party entities (i) primarily to communicate with you about market news, our firm and about other financial products that we offer, (ii) to send you administrative communications either about your interactions with us or about features of our website, including any future changes to this Privacy Statement, or (iii) as otherwise permitted by law.

Other Uses

We may also share your personal information with a select group of third-party service providers that carry out certain functions on our behalf. The categories of service provider that we use include companies that improve the functionality of our website, provide analytic services, or help to gather your information or communicate with you. These companies are allowed to gather, receive, and use your information only for the purposes described in this Privacy Statement or as required by law.

We may also disclose your personal information when (a) such disclosure is required by law, a court of law, or as requested by any governmental, self-regulatory organization or law enforcement authority; (b) to the extent necessary for a reorganization, restructuring, merger, acquisition or transfer of assets related to our business; or (c) we determine such disclosure is required or advisable in order to 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, and/or third parties, including the safety and security of tangible and/or intangible property that belongs to us or to third parties.

We seek to ensure that the entities with which we share your personal information (both affiliates and non-affiliated third parties) protect the confidentiality and security of your information and use it only for its intended purpose.

C. Transferring Your Personal Information to Other Countries

The entities with which we might share your personal information may be located outside of the jurisdiction in which the personal information was collected. Where required, we have put in place appropriate safeguards designed to make sure your personal information remains adequately protected when transferred internationally. For instance, the transfer of personal information out of the European Economic Area or the UK to third countries that have not been granted an adequacy decision by the European Commission will be made pursuant to a valid data transfer mechanism under applicable data protection laws, including on the terms of the European Commission standard contractual clauses.

You may ask for further information on the safeguards that we have put in place, where required, for the transfer of your data outside of the jurisdiction in which it was collected by contacting us as indicated below at “How To Contact Us”.

D. How Long Do We Keep Your Personal Information?

We will seek to retain your personal information for the amount of time necessary to accomplish the purpose for which it was collected. We will also retain personal information that could be relevant to legal proceedings or must otherwise be retained under applicable law or regulations for longer periods.

E. How Do We Protect Your Personal Information?

We have implemented technical, administrative, and physical security measures to protect your personal information from unauthorized access and improper use. We review our security procedures in order to consider appropriate new technology and methods on a periodic basis. Except as otherwise required by law, rule or regulation, only authorized persons will be allowed to view your personal information.

F. Do Not Track.

“Do Not Track” is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated Do Not Track signals. Third-parties, such as our analytics providers, may collect data that relates to you on our website. We cannot control third-parties’ responses to Do Not Track signals. Third-parties’ responsiveness to Do Not Track signals is governed by their respective privacy policies. Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.

Questions, Concerns, and Complaints

Should you wish to make an inquiry or complaint about Aperture’s use of your personal information, you may contact us at the contact details set forth below.

You also have the right to lodge a complaint with the appropriate regulatory body/supervisory authority, in particular in the country where you reside, place of work or of an alleged infringement of the law.

How To Contact Us

If you have any questions concerning our privacy practices described in this Privacy Notice please contact us at [email protected] or call 1-212-521-5180.

Changes to this Privacy Statement

We reserve the right to change our Privacy Statement from time to time as necessary, including due to changes in the law or to our data processing practices or activities.

Last updated December 1, 2021

Your Rights under the EU General Data Protection Regulation

You have the right (subject to certain limitations) to confirm that Aperture is processing your personal information, to access the personal information we keep about you, to restrict or object to the processing of your personal information, and to rectify, erase, and port your personal information.

If you wish to exercise any of these rights, please contact us at the contact details set forth below.

You have the right to obtain:

  • Confirmation that we process your personal information; and
  • Access to the personal information we have about you.

Your Right to Rectification

You have the right to have inaccurate personal information rectified.

Your Right to Erasure

You have the right to have your personal information erased if:

  • Your personal information is no longer necessary for the purpose which we originally collected or processed it for;
  • We are only relying on your consent to process your personal information, and you decide to withdraw your consent; and
  • You object to the processing of your personal information, and we have no overriding legitimate interest or other valid basis to continue the processing of your personal information.

Your Right to Restrict Processing

As an alternative to requesting the erasure of your personal information, you have the right to limit the way we use your personal information in certain circumstances:

  • You contested the accuracy of your personal information, and we are verifying the accuracy of such information;
  • We have unlawfully processed your personal information and you oppose erasure and request restriction instead;
  • We no longer need your personal information, but you need us to keep it in order to establish, exercise or defend a legal claim; or
  • You have objected to us processing your personal information, and we are considering whether we have legitimate grounds to continue processing your personal information.

Your Right to Object to Processing

You have the right to object to certain types of processing of your personal information, namely:

  • Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
  • Direct marketing (including profiling); and
  • Processing for purposes of scientific/historical research and statistics.

Your Right to Data Portability

Under limited circumstances, you have the right to obtain from us and reuse your personal information for your own purposes. This right allows you to move, copy or transfer your personal information easily, without hindrance to usability. If you request it, we may transmit your personal information directly to another organization if this is technically feasible.

How To Contact Us

If you have any questions concerning our privacy practices described in this Privacy Statement please contact us at [email protected] or call 1-212-521-5180.

Your Rights under the California Consumer Privacy Act

California Collection Notice

If you are a California resident, California law requires us to provide you with some additional information regarding how Aperture collects, uses, and shares your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). 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 California Financial Information Privacy Act (FIPA). Our separate Privacy Notice applies to this excluded data.

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 (such as your name and contact information, IP address, and mobile device identifiers)
    • We share identifiers with service providers, including Google Analytics.
    • Our business and commercial purposes for collecting and sharing this information are to operate our website, to communicate with you, and to engage in legal and everyday business purposes.
  • Internet usage information (such as browsing history and use and interaction with our website)
    • We share internet usage information with service providers, including Google Analytics.
    • Our business and commercial purposes for collecting and sharing this information are to operate our website, to communicate with you, and to engage in legal and everyday business purposes.

This information is used and disclosed for the various business purposes and to the categories of third parties described in the “How Do We Us Your Personal Information” section of the Privacy Notice, above.

Your California Privacy Rights

If you are a California resident, you may have certain rights.

California law may permit you to request that we:

  • Provide you with the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
  • Provide you with access to and/or a copy of certain personal information we hold about you.
  • Delete certain personal information we have about you.

You may have the right to receive information about the financial incentives that we offer to you for your personal information (if any). You also have the right not to be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we may need certain information to provide services to you or for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use some of our services.

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.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please send us an email at [email protected] You will need to provide additional information to verify your identity before we fulfill your request. 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 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.

Additional Information for California Residents

Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties and gives California residents the right to opt out of the “sale” of personal information. We do not engage in such activity and have not engaged in such activity in the past twelve months, nor do we have actual knowledge that we have engaged in such activity in connection with individuals under 16 years of age. We do share certain information and allow parties to collect certain information about your activity, for example through cookies. We explain our use of cookies and how you can control cookies in various sections of the Privacy Statement above.

How To Contact Us

If you have any questions concerning our privacy practices described in this Privacy Statement, please contact us at [email protected] or call 1-212-521-5180.

By continuing to access this website, you agree to the following:
  • Access to the information contained in this website may be restricted by laws and regulations applicable to the jurisdiction of the user. All users must ensure that their use of this information and any investment decision taken as a result does not contravene any such restrictions. It is your responsibility to be aware of and to observe all applicable laws and regulations of any relevant jurisdiction.
  • Aperture Investors UK, Ltd is not authorised to actively market products and services within EU27. Information on products can be found at www.generali-investments.lu and for any sales enquiries, please contact Generali Investment Partners at [email protected]