Scope of Policy
Lucy Labs Advisors LLC (“Lucy Labs”, the “Firm” or “we”) is committed to protecting its investors’ privacy. Lucy Labs has adopted this privacy policy (the “Privacy Policy”) which will apply to all Personal Information (defined below) which we gather about our clients and our directors, officers and employees in the course of conducting our business.
Collection and Use of Personal Information
In the course of our provision of investment management services to clients, Lucy Labs collects information about such clients and their beneficial owners (“Personal Information”) including residential address, telephone number, e-mail address, social insurance number, bank account numbers and other “know your client” information, including identity verification records required under applicable laws including the Proceeds of Crime (Money Laundering) and regulations and policies made thereunder and other statutes and regulations that take legislative measures against money laundering, terrorist financing and against financial dealings with certain sanctioned individuals and entities.
Personal Information is used for the following purposes:
- conducting an analysis of the suitability of a proposed investment in a fund for which Lucy Labs acts as a portfolio manager or investment fund manager (a “Fund”);
- processing the subscription for Fund securities, opening and servicing the account;
- developing an investment policy statement under an investment management agreement;
- verifying identity and other information provided to Lucy Labs (including bank account);
- if applicable, reporting the investment to the relevant securities regulatory authority;
- completing books and records information for the Funds or managed accounts;
- detecting and preventing fraud and other unauthorized or illegal activities; and
- meeting other legal and regulatory requirements.
Lucy Labs may use Personal Information to send client communications by mail, email or telephone marketing or to promote its Funds or other products and services that may be of interest to clients. Clients can opt-out of these marketing communications at any time by clicking on the unsubscribe link included in marketing email communications or by contacting Lucy Labs as set out under Contact Us below. Please note that clients will continue to receive certain transactional or informational electronic communications from Lucy Labs after opting out.
How Personal Information is Collected
Lucy Labs collects Personal Information directly from clients (such as information provided in the subscription agreement or account-opening documents).
Disclosure of Personal Information
Lucy Labs will not disclose, trade, rent, sell or otherwise transfer Personal Information, without consent, except as otherwise set out herein.
Service Providers: Personal Information may be transferred (or otherwise made available) to Lucy Labs’s affiliates and other third parties in the U.S. who provide services on Lucy Labs’s behalf. Lucy Labs may use service providers to verify Personal Information (such as identity and bank account number), administer the Funds or managed accounts, send email or other communications, or manage and analyze data. In the event Personal Information is transferred to the U.S. or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws. Service providers are given the information they need to perform their designated functions and are not authorized to use or disclose Personal Information for their own marketing or other purposes.
Legal/Compliance: Lucy Labs, its affiliates and other service providers may provide Personal Information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable U.S. or other law. Personal Information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business: Personal Information may be transferred as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Lucy Labs’s business or as part of a corporate reorganization or stock sale or other change in corporate control.
Safeguards and Retention
Lucy Labs has implemented reasonable administrative, technical and physical measures in an effort to safeguard the Personal Information in its custody and control against theft, loss and unauthorized access, use, modification and disclosure. Lucy Labs restricts access to Personal Information on a need to-know basis to employees and authorized service providers who require access to fulfill their job requirements. Lucy Labs has record retention processes designed to retain Personal Information of its clients for no longer than necessary for the purposes stated above or to otherwise meet legal requirements (which may extend beyond the end of a client’s relationship with Lucy Labs).
Access to Personal Information
Clients have the right to access, update and correct inaccuracies in their Personal Information in Lucy Labs’s custody and control, subject to certain exceptions prescribed by law. Clients may request access, updating and corrections of inaccuracies in Personal Information in Lucy Labs’s custody or control by emailing or writing to Lucy Labs at the contact information set out below. Lucy Labs may request certain Personal Information for the purpose of verifying the identity of the individual seeking access to his or her Personal Information records.
Changes to the Privacy Policy
This Privacy Policy may be updated periodically to reflect changes to Lucy Labs’s Personal Information practices. Lucy Labs will provide clients with an updated copy of its Privacy Policy annually or more frequently upon request.
Contact Us
Clients may contact Lucy Labs’s Privacy Officer with any questions or comments about this Privacy Policy, or to obtain access, update, and/or correct inaccuracies in Personal Information, or otherwise with any question or complaint about the manner in which Lucy Labs or its service providers treat Personal Information at the following contact information.
Please contact us here
Confidentiality
The relationship between Lucy Labs and our clients is our most important asset. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect the confidentiality, integrity and security of your nonpublic personal information. As we believe that all of our clients value their privacy, we do not disclose your nonpublic personal information to anyone unless it is required by law, at your direction, or is necessary to provide you with our services. We do not sell your nonpublic personal information to anyone.
Personal Information That We Collect, Maintain, and Communicate
We collect and maintain your nonpublic personal information, so we can provide investment management and/or tax preparation services to you. The types and categories of information we collect and maintain about you include:
- Information we receive from you to open an account or provide investment or tax services to you (such as your date of birth, social security number, address, telephone number, and financial information);
- Information about your transactions with us, our affiliates, or others to service your account (such as trade tickets and account statements);
- Information that we receive from third parties with respect to your account (such as trade confirmations from brokerage firms).
- Information provided to us by authorized parties acting on behalf of our clients such as accountants, attorneys, and investment consultants.
In order for us to provide investment management and tax services to you, we may disclose the non-public personal information that we collect and maintain in very limited instances, which includes:
- Disclosures that are authorized or requested by you;
- Disclosures that are required by law (for example, to cooperate with regulators or law enforcement authorities);
- Disclosures to companies that perform services on our behalf (such as data processors that provide investment accounting and reporting services, or otherwise assist us in delivering services to our clients) subject to agreements that prohibit such companies from disclosing or using the information other than for the services required or as permitted by law;
- Disclosures to companies as otherwise permitted by law, including those necessary to service your account (such as providing account information to brokers or custodians).
How We Protect Your Personal Information
To fulfill our privacy commitment, we have instituted firm-wide practices to safeguard the information that we maintain about you. These include:
- Maintaining physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information;
- Limiting access to nonpublic personal information to employees and third parties that are necessary or appropriate to provide services to you;
- Requiring third parties that perform services to us to agree by contract to keep your information strictly confidential;
- Protecting information of our former clients to the same extent as our current clients.