Privacy Notice to California Residents — PAAMCO Prisma, LLC
The California Consumer Privacy Act and California Privacy Rights Act
The California Consumer Privacy Act, California Civil Code § 1798.100 et seq. as amended by the California Privacy Rights Act (“CPRA”) (with any implementing regulations and as may be amended from time to time, “CCPA”), imposes certain obligations on PAAMCO Prisma, LLC and its affiliates (collectively, “PAAMCO Prisma”, “we” or “us”) and grants certain rights to California residents, including individuals who visit our websites, representatives of institutional investors, consumers, and vendors, including other investment advisers (“California Resident,” “you” or “your”) with regard to the collection of personal information. If you are a California Resident, please review this Privacy Notice to California Residents (“Privacy Notice”) for information about how and why we collect, use, and disclose your personal information, our Notice at Collection and your potential rights with regard to your “personal information” under the CCPA. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law, and are only applicable to California Residents.
This Privacy Notice does not apply to (i) PAAMCO Prisma personnel or job applicants seeking employment at PAAMCO Prisma or (ii) certain personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.
Terms used herein have the meaning ascribed to them in the CCPA. PAAMCO Prisma is a “business.”
Notice at Collection and Use of Personal Information
Personal Information We Collect
Depending on how you interact with us, we may collect all or a subset of these categories of personal information from or about you including:
- Identifiers such as, your name, address, date of birth, email address, social security number, driver’s license number, passport number, online identifiers, or other similar identifiers.
- Additional information subject to California Civil Code Section 1798.80(e), such as your signature or bank account or other financial information.
- Characteristics of protected classifications under California or federal law, including, but not limited to, sex or gender, national origin, or marital status.
- Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested in the prior year, investments considered, or sources of wealth.
- Audio, electronic, visual, or similar information.
- Internet or other electronic network activity information, including, for example, information regarding your interaction with our website or use of certain online tools.
- Professional or employment-related information, including your current or former employer or your current professional title.
- Non-public education information, including personally identifiable information as defined in the Family Educational Rights and Privacy Act.
- Inferences drawn from any of the information identified above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. For example, information on your potential interest in investing in new funds based on various information.
- Certain information that may qualify as “sensitive personal information” under the CPRA, such as your social security number, passport number, driver’s license, or state identification card; your account log-in, financial account information; and your racial or ethnic origin.
Purposes for Collecting and Using Personal Information
We may have collected your personal information for all or a subset of the following purposes, including:
- Performing services on behalf of the fund, including, for example, maintaining or servicing accounts, providing customer service, processing transactions, verifying information, processing payments, or providing similar services on behalf of the fund.
- Communicating with you.
- Performing our contractual obligations to a California Resident as a subscriber to the fund, including, processing initial subscriptions and providing updates on the fund’s performance and other operational matters.
- Business management and planning, including accounting and auditing and monitoring for compliance with regulatory requirements, contractual obligations, and internal policies.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, including, preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks.
- Enabling or effecting commercial transactions, including, using your bank account details to remit funds and process distributions.
- Providing advertising and marketing services to you. We do this to meet our business interests in expanding our business. We only send direct electronic marketing messages where recipients have agreed to this or as otherwise permitted by applicable law. Individuals can opt out of receiving such messages at any time by contacting us via the channels provided below.
- Administering and improving our website or digital offerings.
- Internal operations, including troubleshooting, data analysis, testing, research, and statistical and survey purposes.
Data Retention
We will retain your personal information for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. To determine the appropriate retention period for your personal information and sensitive personal information, we will consider the amount, nature and sensitivity of the personal information, the potential risk from unauthorized use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal requirements.
Our Collection, Use, and Disclosure of Personal Information and Sensitive Personal Information
Information We Have Collected and Our Purpose for Collecting It
In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information listed above in Personal Information We Collect. We may have collected all or a few of these categories of personal information for the business or commercial purposes identified in Purpose for Collecting and Using Personal Information.
Categories of Sources from Which Personal Information is Collected
We may collect personal information about you directly from you and/or your intermediaries through sources such as:
- Account applications, subscription agreements, and other forms or related documentation.
- Written, electronic, or verbal correspondence with us or our service providers.
- Investor transactions.
- An investor’s brokerage or financial advisory firm, financial advisor, or consultant.
- From information captured on applicable websites.
In addition, we may collect personal information from different sources, such as:
- Our affiliates, our service providers, or our affiliates’ service providers.
- Public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities.
- From credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.
Our Disclosure of Personal Information
In the preceding 12 months, we may have disclosed for a business purpose some of the categories of personal information with the following categories of third parties as described in the following chart.
| Category of Personal Information | Category of Third Party |
| Identifiers (for example your name, address, DOB, SSN, driver’s license, passport number and online identifiers) |
|
| Additional information subject to Cal. Civ. Code § 1798.80(e) (for example, a signature, state identification card number, financial information, or bank account information) |
|
| Characteristics of protected classifications under certain federal or state laws (for example gender, age, national origin, citizenship or marital status) |
|
| Commercial Information (for example records of products or services purchased, obtained or considered or purchasing histories or tendencies including funds in which you are invested, investments considered or sources of wealth) |
|
| Internet or Electronic Network Activity Information, including interactions with our website or use of certain online tools |
|
| Audio (e.g., voicemail), electronic, visual or similar information |
|
| Professional or Employment Related Information, including occupation, compensation, employer and title |
|
| Non-public education information, including personally identifiable information as defined in the Family Educational Rights and Privacy Act |
|
| Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds |
|
In addition, we may disclose, and in the preceding 12 months may have disclosed, all or just a few of the categories of personal information identified in Personal Information We Collect above to the following categories of third parties:
- Law enforcement.
- Judicial courts, regulators and other government agencies as required or permitted by law.
- Individuals, entities, or regulatory bodies in connection with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons.
- Individuals, entities, or regulatory bodies to exercise or defend legal claims on behalf of you.
- Individuals, entities, or regulatory bodies upon your request, at your direction, or with your consent.
- Other individuals, entities, or regulatory bodies as otherwise required or permitted by law.
We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in Purposes for Collecting and Using Personal Information. Additionally, we may disclose your personal information to third parties upon your request, at your direction or with your consent.
Use and Disclosure of Sensitive Information
As noted in the paragraph labelled Personal Information We Collect, under California law, certain personal information we collect and process may be considered “sensitive personal information.” The CPRA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not using or disclosing your sensitive personal information for purposes that would require that we provide you with a right to limit.
Sale of Personal Information
PAAMCO Prisma does not knowingly sell your personal information.
Your Rights Under the CCPA
The CCPA provides California Residents with certain rights, namely:
- Knowledge of and access to information collected (“Request to Know”);
- Deletion of information collected (subject to exceptions such as our legal obligation to maintain certain employment data) (“Request to Delete”);
- Knowledge of what personal information is sold or disclosed and to whom;
- Opt-out of sale or sharing of information collected;
- Correction of inaccurate information collected (“Request to Correct”);
- Limit use and disclosure of sensitive personal information collected; and
- Not to be discriminated or retaliated against for exercising rights under the CCPA.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you as permitted by the CCPA or another law or regulation.
How to Submit a Request Under the CCPA
You may submit requests through the following toll-free telephone number, 1-888-393-3067, or submitting the request form by clicking on the link below.
California Consumer Privacy Act Request Form
PAAMCO Prisma
660 Newport Center Drive
Suite 930
Newport Beach, CA 92660
We are only required to respond to verifiable requests made by you or your legally authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
Changes to this Privacy Notice
We may update this Privacy Notice from time-to-time at our sole discretion. If you do not agree to any changes we make to this Privacy Notice, you must not continue to use our services.
Contact for More Information
This Privacy Notice is available in alternative formats upon request. If you have any questions or concerns about this California Privacy Notice, or to request this Privacy Notice in an alternative format, please email Privacy@PaamcoPrisma.com.
PAAMCO Prisma’s general privacy policy is viewable here: PaamcoPrisma.com/privacy-policy.
This California privacy notice was last updated on March 30, 2023.