CCPA

Effective:  March 2021

The California Consumer Privacy Act

California enacted the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time, “CCPA”), in 2018 and it is effective as of January 1, 2020.  The CCPA imposes certain obligations on PAAMCO Prisma, LLC and its affiliates (collectively, “PAAMCO Prisma”, “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to personal information.  If you are a California Resident, please review the following information about 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.

Terms used herein have the meaning ascribed to them in the CCPA. PAAMCO Prisma is a “business.” “Personal information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or a household. The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations.  In addition, the CCPA does not apply to certain information, like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations.

Business or Commercial Purpose for Collecting Personal Information

In the preceding 12 months, we may have collected your personal information for the following business or commercial purposes.  We may collect personal information for all or just a few of these purposes with regard to a particular California Resident.

• 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.
• 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.
• 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.

Categories of Personal Information We Collect and Disclose for a Business Purpose

In the preceding 12 months, we may have collected or disclosed the following categories of personal information from or about you to our service providers or other entities that have agreed to limitations on use of your personal information.  We may collect or disclose all or just a few of these categories with regard to a particular California Resident.

• Identifiers such as, your name, address, date of birth, email address, social security number, driver’s license number, passport number, or other similar identifiers.
• Personal information protected under California Civil Code Section 1798.80(e), including, for example, your signature or bank account or other financial information.
• Characteristics of protected classifications under California or federal law, including, your 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. For example, funds invested in the prior year, investments considered, or sources of wealth.
• 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.
• 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.

Personal information under the CCPA does not include deidentified information, aggregate consumer information or publicly available information that is lawfully made available from government records.

Categories of Sources from Which Personal Information is Collected

In the preceding 12 months, we may have collected personal information about you from the following categories of sources.  We may collect personal information from all or just a few of these categories of sources with regard to a particular California Resident.

• Directly from you or your representatives, including through forms or related documentation you complete when subscribing for shares or interests, in correspondence and conversations (including by email), through transactions with regard to funds, and when you provide remittance instructions.
• From our service providers such as our fund administrator.
• From law enforcement.
• From government records and 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, and fraud prevention and detection agencies and organizations.

Categories of Third Parties With Which We Share Personal Information

In the preceding 12 months, we may have shared your personal information with the following categories of third parties.  We may share personal information with none, all, or just a few of these third parties with regard to a particular California Resident. We do not sell your personal information.

• Law enforcement.
• 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 at your direction or with your consent.
• Other individuals, entities, or regulatory bodies as otherwise required or permitted by law.

We may disclose all or just a few of the categories of personal information identified in the paragraph labelled “Categories of Personal Information We Collect and Disclose for a Business Purpose” to our service providers or other entities with which we have contracted to provide support and services and that have agreed to limitations on the use of your personal information for a business purpose or that fit within other exemptions or exceptions in the CCPA.

California Residents’ Rights Under the CCPA

If your personal information is subject to the CCPA, you may have certain rights concerning your personal information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”); and (iv) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting or selling the personal information; (d) the categories of third parties with which we share personal information; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information, like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where 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 required to provide certain information or to delete personal information only in response to verifiable requests made by you or your authorized agent. Any information gathered as part of the verification process will be used for verification purposes only.

When you submit a Request to Know or Request to Delete, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the information you are requesting and the type of request you are making, account login credentials or other account information, answers to security questions, name, government identification number, date of birth, contact information, or other personal information.

You are permitted to designate an authorized agent to submit a Request to Know or a Request to Delete on your behalf and have that authorized agent submit the request through the aforementioned methods. If an authorized agent seeks to submit a Request to Know or a Request to Delete on behalf of a California Resident, the authorized agent must provide: (i) signed authorization from the California Resident authorizing them to act on the California Resident’s behalf, unless they can provide proof that the California Resident has granted them power of attorney pursuant to California Probate Code Sections 4000 to 4465; and (ii) proof of their registration with the California Secretary of State to conduct business in California. We also require that the California Resident directly verify their own identity with us and directly confirm with us that they provided the authorized agent permission to submit the request.

Contact for More Information

If you have any questions or concerns about this California privacy notice please email privacy@paamcoprisma.com.

This California privacy notice was last updated on March 1, 2021.