ALKEON CAPITAL MANAGEMENT, LLC
Effective as of August 5, 2022
Personal Information We Collect
Information you provide to us. Personal information you provide to us may include:
- Contact and other demographic information, such as names, addresses, social security numbers, account information, assets and income.
- Profile information, such as your username and password and any account preferences for the Services.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us, and from discussions and other communications with our staff (or by registering for access to our website) and information we receive from third parties who refer investors who may be interested in our funds to us.
- Usage information, such as information about how you use the Services and interact with us, including information you provide when you use any interactive features of the Services.
- Marketing information, such as your preferences for receiving communications about our products, activities, and publications, and details about how you engage with our communications.
Information we obtain from other third parties. We may receive personal information about you from third-party sources, such as marketing partners, publicly-available sources, and data providers.
Cookies and Other Information Collected by Automated Means
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model; device identifier; browser type; screen resolution; IP address; the website you visited before browsing to our website; general location information such as city, state or geographic area; and information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
How We Use Your Personal Information
To operate the Services. We use your personal information to:
- provide, operate, and improve the Services;
- communicate with you;
- provide support and maintenance for the Services; and
- respond to your requests, questions and feedback.
To send you marketing and promotional communications. We may send you marketing communications as permitted by law. You may opt out of marketing emails by following the unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.
To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities. We also may use your personal information to carry out anti-money laundering checks and related actions which we consider appropriate or necessary to fulfill any of their legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with the our anti-money laundering policies and procedures.
For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
To fulfill other legitimate business interests. We may use your personal information to investigate, defend against, or prosecute any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum, or otherwise protect our legal rights; and as necessary to comply with any applicable regulatory, judicial or other legal obligation.
With your consent. In some cases we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.
How We Share Your Personal Information
Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the Services (such as customer support, hosting, analytics, email delivery, marketing, and database management services). In addition, we provide personal information to firms that effect transactions for the funds and assist it in servicing those funds and have a need for such information, such as a broker or fund administrator. These third parties may use your personal information only as authorized by their contracts with us, and we require third party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of our clients’ information and to use the information only for the purposes for which Alkeon discloses the information to them.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Alkeon restricts access to nonpublic personal information about its funds and their investors to its employees who need to know that information. Alkeon maintains physical, electronic and procedural safeguards that comply with federal standards to guard such personal information.
International Data Transfers
We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred outside of your state, province, or country to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 16. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us.
Effective August 2022
Your California Privacy Rights
Alkeon Capital Management, LLC (the “Investment Manager” or “Alkeon”) provides this statement of its practices regarding any personal information (as defined below) that is processed by Alkeon including personal information provided via its website, email, and telephone interactions with investors and potential investors who are California residents subject to the California Consumer Privacy Act or CCPA (such individuals, “You”). Where your details are provided to the Investment Manager as a consequence of your investment (or potential investment) in an Alkeon-managed investment fund or your interest in Alkeon (e.g., by registering for access to Alkeon’s website), then the Investment Manager (or a third party service provider) may collect, use and share your personal information or, if you are an entity, that of your (i) beneficial owners, (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity.
CCPA. In 2018, California passed a new law called the California Consumer Privacy Act (CCPA). If the CCPA is applicable to us and to you, you have the right to:
- know the categories of personal information collected about you in the prior 12 months and its sources and business purpose;
- know whether your personal information is sold or disclosed, and to whom, in prior 12 months; and
- access and then delete your personal information (subject to exceptions).
Sale; Non-Discrimination. We do not sell your personal information or discriminate in how we provide services based on your exercise of your privacy rights.
Definition. “Personal Information” is defined under CCPA to include information that identifies, relates to, describes, or is capable of being associated with a particular consumer or household.
Retention. Where related to investing and other regulated transactions, Alkeon retains Personal Information for a minimum of 6 years. In other contexts, we retain information for so long as required for Alkeon to perform services to Investors, to comply with legal or regulatory requirements or for other legitimate business purposes.
Verification Process for Access or Deletion of your personal information. If you would like to access or delete your personal information, and, to the extent you have the right to do so under CCPA, we must, where data is identifiable, verify your identity as the requester. Our verification process is to have you confirm data that is unique to you in our records, such as approximate full name, investment value, and zip code.
Agents. If you would like to exercise your access or deletion rights through an agent, please (a) provide the agent legally sufficient power-of-attorney documentation establishing the agent’s rights to act on your behalf or (b) (1) Provide the authorized agent signed permission to do so; (2) Verify your own identity directly with us as provided above; and (3) Directly confirm with us that you provided the authorized agent permission to submit the request.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
Requests for Access or Deletion and Questions About this California Rights Statement. Contact us at AlkeonTeam@alkeoncapital.com or call collect at +1 (212) 716-6840 if you have questions or concerns about this statement, to review and request changes to your information, or would like to request access or deletion of your personal information.
Effective August 2022
ALKEON CAPITAL MANAGEMENT, LLC
Alkeon Capital Management, LLC (the “Investment Manager” or “Alkeon”) is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by the Investment Manager is controlled by the Investment Manager and the Investment Manager is the data controller of your personal information.
Where your details are provided to the Investment Manager as a consequence of your investment (or potential investment) in an Alkeon-managed private investment fund (a “Fund”) or your interest in Alkeon (e.g., by registering for access to Alkeon’s website), then the Investment Manager, acting as a data controller, may itself (or through a third party such as a Fund’s administrator (the “Administrator”) acting in its capacity as the Fund’s administrator) process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (the foregoing collectively, “Your Personal Information”). When processing Your Personal Information, there may also be times when the Administrator will act as a data controller.
The Investment Manager’s European Union representative is located in the United Kingdom at Paternoster House, 65 St. Paul’s Churchyard, London EC4M 8AB and can be contacted at firstname.lastname@example.org.
Collection of Your Personal Information
The Investment Manager collects Your Personal Information from the following sources, as applicable:
- Subscription documents and other information provided by the Investor in writing, in person, by telephone, electronically or by any other means (this information includes (i) name, address, income, financial and investment qualifications, and tax-related information and (ii) in the case of individuals, birth date, nationality, passport or other identification number, and employment information, or in the case of entities, date and jurisdiction of formation, entity type, tax identification number, and business information);
- Transactions within the Fund, including account balances, investments, redemptions and management fees and performance allocations; and
- Other interactions with the Investment Manager (for example, discussions with our staff or by registering for access to Alkeon’s website).
Why We Use Your Personal Information
Your Personal Information may be processed by the Investment Manager and/or the Administrator (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes, as applicable:
- to facilitate your investment in a Fund and the management and administration of your investment in such Fund on an ongoing basis (the “Services”) which are necessary to fulfill all contractual and regulatory obligations related to your investment in the Fund, including without limitation the acceptance and processing of subscription documents and redemption and transfer requests;
- in order to carry out anti-money laundering checks and related actions which the Investment Manager and/or Administrator considers appropriate or necessary to fulfill any of their legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with the Investment Manager’s and the Administrator’s anti-money laundering policies and procedures;
- to comply with their legal obligations and, in particular, to report tax-related information to tax authorities;
- to disclose information to other third parties such as service providers of the Investment Manager and/or Administrator (including, for example, attorneys, accountants, auditors, or other professionals), regulatory authorities and technology providers in order to comply with any legal obligation imposed on the Investment Manager and/or Administrator or in order to pursue the legitimate interests of the Investment Manager and/or Administrator;
- to monitor, record and distribute communications related to the Investment Manager (including registration for access to its website), your investment in a Fund or for any of the purposes specified herein; and/or
- to otherwise pursue the legitimate interests of the Investment Manager and/or Administrator relating to your investment or your potential investment in a Fund or other interactions with the Investment Manager, and/or where the processing of Your Personal Information would be in the public interest.
Countries Having Access to Your Personal Information
The Investment Manager’s servers, which store and keep Your Personal Information, are located in the United States.
The Investment Manager also has service providers whose personnel will have access to Your Personal Information and that may be located in other countries which have an adequate level of protection of Your Personal Information.
The disclosure of Your Personal Information to the third parties set out above may involve the transfer of data to the United States and other jurisdictions outside the EEA. Such countries may not have the same data protection laws as your jurisdiction.
Collecting Investor Information Legally
The Investment Manager and the Administrator are able to legally collect and use Your Personal Information either because:
- You have consented to their doing so; and/ or
- Collecting and using Your Personal Information is necessary for the Investment Manager and/or the Administrator to fulfill their legitimate business interests, which may include (i) to fulfill contractual obligations to Fund Investors or otherwise perform the Services; or (ii) to investigate, defend against, or prosecute any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum, or otherwise protect their legal rights; and/ or
- It is necessary to comply with any applicable regulatory, judicial or other legal obligation.
Retention of Investor Information
The Investment Manager and the Administrator will retain Your Personal Information for the purposes described in (1), (2), and (3) in the immediately preceding paragraph as long as required for the purposes described above.
You have the right to:
- obtain confirmation from the Investment Manager that Your Personal Information is being collected, used, and retained as described above and to access Your Personal Information held by the Investment Manager;
- have Your Personal Information corrected if it is inaccurate or incomplete at any time;
- erasure, or the right to be forgotten, which means you can request deletion or removal of any of Your Personal Information the Investment Manager holds about you at any time, subject to the Investment Manager’s or the Administrator’s rights to retain Your Personal Information for legitimate business purposes;
- block or suppress the Investment Manager collecting and using Your Personal Information, which means the Investment Manager can continue to store Your Personal Information but cannot further collect or use it in any way;
- obtain and reuse any of Your Personal Information that the Investment Manager holds about you for your own purposes across different services, which allows you to move, copy or transfer Your Personal Information easily from the Investment Manager to another place identified by you to the Investment Manager in a safe and secure way without hindrance to the usability of Your Personal Information;
- object to the Investment Manager collecting, using or retaining Your Personal Information where this is based on:
- your legitimate interest or the performance of a task in the public interest; or
- direct marketing even if otherwise legally permitted; and
- withdraw your consent to the use of Your Personal Information at any time, as described below.
To make any requests as listed above, please contact the Investment Manager at AlkeonTeam@alkeoncapital.com.
The Investment Manager will confirm any requests relating to your rights above within one to two months of receipt of your request, depending on its complexity.
Withdrawal of Your Consent
You can tell the Investment Manager to stop collecting, using and retaining Your Personal Information at any time by emailing the Investment Manager at AlkeonTeam@alkeoncapital.com.
You should note that notwithstanding your withdrawal of consent, the Investment Manager may be legally required to retain some or all of Your Personal Information.
Where the Investment Manager or the Administrator requires Your Personal Information to comply with AML or other legal requirements, failure to provide this information will mean that you may be unable to be accepted as an investor in the Fund and/or may be mandatorily redeemed from the Fund if you are already an Investor.
Protection of Investor Information
The Investment Manager maintains appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards that comply with the GDPR to protect customer information, including:
- the pseudonymization and encryption of Your Personal Information where appropriate;
- ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- ensuring the Investment Manager can restore access to Your Personal Information in a timely manner if a physical or technical incident occurs; and
- regular testing, assessment and evaluation of the effectiveness of its technical and organizational measures to attempt to ensure Your Personal Information is secure.
The Investment Manager restricts access to the personal and account information of Investors to those employees who need to know that information in the course of their job responsibilities. The Investment Manager will destroy, erase or make unreadable data, computer files and documents containing Your Personal Information that is non-public prior to disposal.
Making a Complaint
If you would like to make a complaint about the way the Investment Manager has collected, used or retained Your Personal Information, please contact us at AlkeonTeam@alkeoncapital.com.
You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by the Investment Manager or its service providers infringes the GDPR.
Former Customers and Investors
Page Last Updated January 2021
ALKEON CAPITAL MANAGEMENT, LLC
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Effective August 2022