Effective Date: September 1, 2018
We at The Dorian Fund L.P., along with our affiliates listed in Appendix A of this Privacy Policy (collectively, “The Dorian Fund” or “Dorian Fund”), respect your concerns about privacy. This Privacy Policy describes the types of personal information we obtain, how we use the information, with whom we share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.
This Privacy Policy applies to the privacy practices of The Dorian Fund with respect to its processing of personal information online through Dorian Fund websites and mobile applications listed in Appendix B of this Privacy Policy (collectively, the “Sites”), as well as our offline privacy practices (unless they are specifically covered by a separate privacy policy).
Information We Obtain We may obtain information about you in various ways, such as through our Sites, subscription documents and other documents and forms we receive from you or on your behalf.
The types of personal information we obtain include:
contact information (such as name, postal and email address, and telephone number);
date of birth;
information used to create your online account (such as username and password);
information about your transactions with us, our funds or our affiliates; and other personal information you provide to us, such as through emails, subscription documents and other onboarding documents (that may include Social Security numbers, tax ID numbers or other government- issued identification numbers, to the extent permitted by applicable law), and other forms and documents you send us.
In addition to the information listed above, if you are a job candidate and apply for a position with Dorian Fund or create an account to do so, or if we conduct a background check in connection with a job opportunity with Dorian Fund, we may collect the following types of personal information to the extent permitted by applicable law:
Social Security number, national identifier or other government- issued identification number;
date of birth;
gender;
employment and education history;
language proficiencies and other work-related skills;
citizenship and work authorization status;
military and veteran status;
ethnicity;
self-identified disability status;
results of criminal background checks;
information provided by references; and
other information about your qualifications for employment, such as information contained in your résumé and compensation history and related information.
Providing personal information to us is voluntary on your part. If you choose not to provide us with certain information, we may not be able to offer you certain of our products and services, and you may not be able to access certain features of our Sites.
In connection with operating our business and marketing our products and services, to the extent permitted by applicable law, we may obtain personal information from consumer reporting agencies, our related entities, the responsible entities or administrators of managed investment schemes for which we provide services (“Fund”), regulatory or government authorities, industry bodies, professional associations and other third parties.
Information We Obtain by Automated Means
When you visit our Sites, open our emails or interact with Dorian Fund- related tools, widgets or plug- ins, we may obtain certain information by automated means, such as through cookies, web server logs, web beacons and JavaScript. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages or applications to web servers and may be used to transmit information back to a web server.
The information we obtain in this manner may include IP addresses, unique device identifiers, browser and operating system characteristics, device characteristics, language preferences, clickstream data, referring/exit URLs, information on actions taken, dates and times of activity and other technical information. These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our products, services and Sites; (3) tailor our products, services and Sites around your preferences; (4) measure the usability of our products, services and Sites and the effectiveness of our communications; and (5) otherwise manage and enhance our products, services and Sites.
If you wish to disable the storage of cookies on your computer, you may do so by using the settings on your browser or device. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your device. Please note, however, that without cookies, you may not be able to use all of the features of our Sites. For more information on deleting or controlling cookies, visit www.aboutcookies.org.
To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.
Third-Party Analytics Services
We use third-party web analytics services on the Sites, including Google Analytics, Sitecore and Webtrends. The analytics providers that administer these services use technologies such as cookies, web beacons and web server logs to help us analyze how visitors use the Sites. The information obtained for this purpose (including your IP address and other information collected by automated means) will be shared with or collected directly by these third-party service providers, and other relevant third parties who use the information to evaluate use of the Sites. To learn more about these analytics services and how to opt out (where applicable), please visit:
Google Analytics: www.google.com/intl/en/analytics/learn/privacy.html
Sitecore: www.sitecore.net/en/legal/privacy-policy
Webtrends: www.webtrends.com/terms-policies/privacy/privacy-statement
Online Tracking and Interest-Based Advertising
When you use the Sites, we may collect personal information about your online activities, over time and across third-party websites, to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent to the processing of your personal information for direct marketing purposes.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on the Sites and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.
The Sites are not designed to respond to all types of “do not track” signals received from web browsers. To learn how to opt out of ad network interest- based advertising in the United States, please
visit www.aboutads.info/choices, www.networkadvertising.org/choices, and prefer ences-mgr.truste.com.
How We Use the Information We Obtain
We may use and process the personal information we obtain to: provide and manage our products, services and Sites;
create, manage and administer accounts you hold with us or with one of our funds;
establish and manage your online account with Dorian Fund;
communicate with you and respond to your inquiries;
send you promotional and advertising materials, newsletters and other communications;
verify your identity and conduct identity and background checks for anti-money laundering purposes where you or your related organization are applying for our products or services;
manage career opportunities, including for recruitment purposes (such as processing job applications and conducting background checks in accordance with applicable law), employee onboarding and other human resources purposes;
perform data analyses (such as market and customer research);
develop, manage and improve our business, products, services and Sites (such as by enhancing, improving and analyzing our products, services and Sites; developing new products, services, websites and apps; managing our communications; determining and managing the effectiveness of our advertising and marketing; and performing accounting,
auditing, billing and reconciliation activities and other internal functions);
protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities;
conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Privacy Policy and our Terms of Use); and for other purposes required or authorized by law, including other purposes for which you have provided your consent.
As a general matter, we use the personal information we obtain to comply with applicable legal requirements, carry out our contractual obligations and pursue our legitimate interests (such as managing our Sites and client relationships). Where required by applicable law, we obtain consent to process personal information. We also may use the personal information we obtain in other ways for which we provide specific notice at the time of collection.
Information We Share
We do not sell or otherwise share personal information about you, except as described in this Policy. We share your personal information with our affiliates for the purposes identified in this Privacy Policy. We also share the information with service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include fund administrators and entities that provide web hosting, analytics and other IT services. In addition, we may share your personal information with your authorized representatives.
We also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government entities based on a lawful disclosure request; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent harm or financial loss; (5) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (6) otherwise with your consent. We reserve the right to transfer personal information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution or liquidation).
Data Transfers We may transfer the personal information we obtain about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. To the extent required by applicable law, when we transfer your information to recipients in other countries, we will protect that information as described in this Privacy Policy.
Your Rights and Choices We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, ask us to remove your information from our mailing lists or to submit a request regarding your personal information, please contact us as indicated on our website or in our Contact Us section of this Privacy Policy. You also can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.
To the extent provided by the law of your jurisdiction, you may (1) request access to the personal information we maintain about you; (2) request that we correct, amend, erase or restrict the information; or (3) exercise your right to data portability, by contacting us as indicated below. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response. Where provided by law, you may withdraw any consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
Links to Third-Party Websites, Apps and Other Features
Our Sites may provide links to other websites, apps and features for your convenience and information. The providers of the websites, apps and features may use automated means to collect information regarding your use of the Sites and your interactions with the other websites, apps and features. These websites, apps and features may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. To the extent that any website, app or feature is not owned or controlled by us, we are not responsible for the content, any use of the website, app or feature, or the privacy practices (including cookie practices) of the website, app or feature. How We Protect Personal Information We maintain administrative, technical and physical safeguards designed to protect the personal information we obtain against unauthorized or unlawful use, disclosure, access, loss, destruction or damage.
Retention of Personal Information To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy or (2) we have another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data.
Children’s Personal Information
The Sites are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Sites. If we become aware that we have collected personal information from a child under the age of 13 through the Sites, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information through the Sites, please contact us as specified in the Contact Us section of this Privacy Policy.
Updates To Our Privacy Policy
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our privacy practices. We will indicate at the top of this Policy when it was most recently updated.
How To Contact Us
If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please email us at info@dorianfund.com . You also may write to us at:
The Dorian Fund L.P.
Attn: Privacy, Legal and Compliance
448 W. 19 th Street, Suite 223
Houston, TX 77008
Appendix A
The privacy practices of the following affiliates of The Dorian Fund L.P. are covered by this Privacy Policy:
The Dorian Fund Group L.P.
Appendix B
This Privacy Policy applies to Dorian Fund online processing of personal information through the following websites and mobile apps:
www.dorianfund.com