Effective Date: September 1, 2018
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;
employment and education history;
language proficiencies and other work-related skills;
citizenship and work authorization status;
military and veteran status;
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
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
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.
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;
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 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).
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.
Children’s Personal Information
How To Contact Us
The Dorian Fund L.P.
Attn: Privacy, Legal and Compliance
448 W. 19 th Street, Suite 223
Houston, TX 77008
The Dorian Fund Group L.P.