Maverick Capital, Ltd., its affiliates and the funds that they manage (collectively, “Maverick”) are required by various laws to make individuals aware of our established practices concerning the protection of their privacy and non-public personal information. Maverick collects non-public personal information about investors and employees in the regular course of doing business. The information includes but is not limited to information provided to use by investors in conjunction with their investments as well as information about their investments. Maverick discloses such information as permitted or required by law. Maverick does not sell personal data.
Access to personal information concerning our investors and employees is restricted to our employees, affiliates and required service providers (as described in more detail below). Maverick maintains and routinely reviews physical, electronic and procedural safeguards to protect the privacy of its investors and individual data.
Where your details are provided to any fund managed by Maverick (each, a “Fund”) as a consequence of your investment in the Fund, then Maverick, acting as a data controller may itself (or through a third party acting in its capacity as the applicable Fund’s administrator or its affiliates (collectively, the “Administrator”)) process your personal data or that of your directors, officers, employees and/or beneficial owners. The Administrator may also act as a data controller of your personal data in connection with the performance of its legal and contractual obligations as Administrator of the Fund.
1. Personal Data Collected
Maverick, as a “data controller”, and the Administrator, as a data processor, processes and discloses your personal data. The types of personal data collected, processed and disclosed varies. This information can include:
- E-mail address
- Social Security number
- Tax identification number
- Account balance
2. Method of Collecting Personal Data
Maverick may obtain your data from multiple sources including but not limited to:
- The Administrator;
- Applications for employment;
- Through transactions with any Fund;
- Third parties conducting background checks to satisfy anti-money laundering and sanctions compliance obligations; or
- Publicly available sources such as social media.
Cookies and Tracking Technologies
This website may use “cookies,” which from time to time automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of this website. Cookies also help us diagnose problems with our server.
3. Purposes of Processing and Legal Basis for Processing
Your personal data may be processed by Maverick or the Administrator (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:
- Managing and administering your holdings in a Fund, including assessing and processing applications, communicating with you about your holdings and account related activities on an on-going basis;
- To update and maintain records and provide NAV and other calculations;
- To manage and maintain Maverick’s relationships with you and for ongoing customer service;
- To enforce or defend a Fund’s rights, itself or through third parties to whom it delegates such responsibilities;
- To comply with any applicable legal, tax or regulatory obligations on Maverick or the Administrator, which derive from anti-money laundering and counter-terrorism legislation;
This use of your personal data is necessary for performance of your contract with Maverick.
- In order to carry out anti-money laundering checks and related actions including sharing data with police, law enforcement, tax authorities or other government and fraud prevention agencies where Maverick has a legal obligation, including screening transactions, reporting suspicious activity and complying with production and court orders;
- To report tax related information to tax authorities;
- To investigate and resolve complaints and manage contentious regulatory matters, investigations and litigation;
- To monitor electronic communications for investigation and fraud prevention purposes, crime detection, prevention and investigation;
This use of your personal data is necessary in order to comply with any legal or regulatory obligations.
The day to day running and management of a Fund including to:
- monitor, maintain and improve the processes, information and data, technology and communications solutions and services used by the Fund;
- perform general, financial and regulatory accounting and reporting;
- monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of the Fund to improve its service delivery; and
- protect Maverick’s legal rights and interests including screening transactions for fraud prevention and anti-money laundering purposes.
This use of your personal data is necessary for Maverick’s legitimate business interest in managing our business including legal, personnel, administrative and management purposes and for the prevention and detection of crime provided Maverick’s interests are not overridden by your interests.
4. Recipients of Data and International Transfer of Data
Maverick and the Administrator may disclose your personal data as follows:
- to their affiliates and third-party service providers engaged in connection with the oversight, safekeeping, administration, distribution or operation of a Fund, in order to process the data for the above-mentioned purposes (including Maverick and non-Maverick entities);
- to competent authorities (including tax authorities), courts and bodies as required by applicable law or requested by such entities or to affiliates for internal investigations and reporting; or
- to third party service providers engaged in background checks
If you are located within the European Economic Area (“EEA”), please be aware that the disclosure of personal data to the third parties set out above likely involves the transfer of data to the USA and other jurisdictions outside the EEA. Such countries may not have the same data protection laws as your jurisdiction and the Funds have, inter alia, authorised the Administrator as its agent to ensure the transfer of data by the Administrator outside the EEA is subject to a contract incorporating standard contractual clauses in the form adopted by the European Commission under Decision 2010/87/EU, Decision 2004/915/EC or an equivalent or replacement decision (the “Model Clauses”).
5. Retention period
Maverick and the Administrator will retain your personal data for a minimum period of 5 years from the date on which you redeem all your investment in the Funds or for as long as required for Maverick or the Administrator to perform the services or comply with applicable legal/regulatory obligations.
6. Consequences of not Providing Required Data
Where Maverick or the Administrator requires your personal data to comply with anti-money laundering or other legal requirements, failure to provide this information means a Fund may not be able to accept you as an investor and/or may be unable to process or release your investment. This may result in the Fund terminating its relationship with you. When you are asked for your information you will be informed whether it is a statutory or contractual requirement to provide the information and the consequences of not providing the information.
7. Data Subject Rights
You have various rights in relation to your personal data, including the right to request access to your personal data, correct any mistakes on Maverick’s records, request the deletion of your personal data, restrict the processing of personal data where you contest its accuracy or the lawfulness of its processing, or where your personal data are no longer required, object to use of personal data based on legitimate business interests, and ask not to be subject to automated decision making if the decision produces legal or other significant effects on you.
In addition, you are entitled to the portability of the personal data that you provided on the basis of consent or for the performance of the contract of which you are party and only to the extent that the processing is carried out by automated means. Maverick will acknowledge receipt of your request within 10 days and respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, Maverick may extend this period by two months and will tell you why. Maverick may request proof of identification to verify your request.
You have the right to lodge a complaint to Maverick’s Chief Compliance Officer or with a supervisory authority if you consider that the processing of your personal data infringes applicable data protection laws.
How to contact Maverick
If you have any questions about Maverick’s use or the Administrator’s use of your personal data, please contact Maverick at firstname.lastname@example.org or (214) 880-4000. To make a request under the California Consumer Protection Act, in addition to the contact information previously provided, California consumers and their agents may dial toll free +1 (844) 771-7319.