This Website is owned and operated by Easterly Funds, LLC (“Easterly Funds”, “we” or “us”). Easterly Funds is a New York based SEC-registered investment advisor and asset management firm which invests in emerging managers and their hedge fund and/or mutual funds. We specialize in identifying, seeding, and growing alternative investment solutions for institutional and individual investors
Please read this Policy to understand how we may process your personal data provided via our Website.
By visiting our Website, you are accepting the terms of this Policy. Please note that this Website may contain links to third party websites and Easterly Funds is not responsible for the privacy policies of those third parties.
Easterly Funds, LLC of 515 Madison Avenue, 24th Floor, New York, NY 10022 is the controller of the personal data that we may collect about you via our Website and/or in subsequent communications between us and you.
Types of Information Collected
We may collect various types of information from you when you request our services including identity data (including name), contact data (including email address and telephone number), employment data (including job description), transaction data (such as, in connection with the investment services we provide) and any other data which you provide when you communicate with us via the “Contact Us” page.
Purposes for processing your personal data
We may process your personal data to enable us to perform the contract entered into between you and us, to ensure compliance with applicable legal and regulatory requirements and for the purposes of our legitimate business interests, including the following:
- to enable us to carry out our obligations arising from any contracts and to provide you with the information, products and services that you request from us, for example about the funds that we manage;
- to enable us to respond to an enquiry or other request you make when you contact us via our Website;
- to comply with our legal obligations, standards, policies and procedures;
- to notify you about changes to our services;
- to enable us to issue a notice or corrective action to you in relation to any of our services, if required;
- to better understand how you interact with our Website, including its functionality and features, and ensure that content is presented in the most effective manner;
- to communicate with you in connection with your investment, such as updating you with relevant market information you have requested in our [newsletters/reports]; and
- to provide you with information you have requested or which we feel may be of particular interest to you, or for sending invitations to events run by Easterly Funds, as described in the “Marketing” section below.
Easterly Funds may use your personal data for marketing related purposes, to send mailings (such as newsletters) which you have requested or which we feel may be of particular interest to you, where it is linked to the services we are providing you, and for sending invitations to events run by Easterly Funds. You may at any time unsubscribe by clicking on the “unsubscribe” link at the bottom of each marketing communication. or email us directly to unsubscribe email@example.com.
Sharing of personal information
Your personal data is not sold or rented to third parties. We may share your personal data with:
- our affiliated companies;
- Government bodies and regulatory agencies in the EU and overseas (for example, the SEC) to comply with our legal and regulatory obligations;
- a prospective seller or buyer in the event of a sale or purchase of any James Alpha Advisors business or asset so that the buyer can continue to provide you with information and services;
- our service providers that we engage to provide services for us. Where we provide your personal data to third-party services providers, they are required to keep your personal data confidential and secure, and must only use your personal data as instructed by us; and
- our service providers.
Keeping your Personal Data Secure
We will take all reasonable steps (including appropriate technical and organizational measures) to ensure your personal data is processed securely to protect the confidentiality, integrity, and availability of your personal data and in accordance with this Policy.
You should be aware that the transmission of information via the Internet is not completely secure. Although Easterly Funds will do its best to protect your personal data, it cannot guarantee the security of data transmitted thru the internet and any transmission is at your own risk. We cannot guarantee that such communications will not be intercepted or changed or that they will reach the intended recipient safely.
Easterly Funds does not guarantee that material on this Website will be free from viruses, worms or other code which may have contaminating or destructive properties. You are fully responsible for ensuring protective steps are taken such as virus checking.
You may have the right to request (a) access the to your personal data we hold about you; (b) request we correct any inaccurate personal data we hold about you; (c) request we delete any personal data we hold about you; (d) restrict the processing of personal data we hold about you; (e) object to the processing of personal data we hold about you; and/or (f) receive any personal data we hold about you in a structured and commonly used machine-readable format or have such personal data transmitted to another company.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.
To exercise any of your rights in connection with your personal data, please contact us by email at firstname.lastname@example.org or by mail to 515 Madison Ave, 24th Floor, New York, NY 10022. We will process any request in line with any local laws and our policies and procedures. If you are located in the EEA, you have the right to lodge a complaint about how we process your personal data with the supervisory authority in your country.
Change to this Policy
Easterly Funds reserves the right to modify this privacy statement or any part of it at any time.
Any changes to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy.
If you have any questions about the processing of personal data via this Website, please contact us at the following address email@example.com. If you contact us, we will do our utmost best to address any concerns you may have about our processing of your personal data.