AlphaQuest LLC (“AlphaQuest”), as a member of the financial services industry, has been and continues to be subject to laws and regulations regarding the collection and exchange of non-public personal information (“NPPI”) about a client. AlphaQuest may use NPPI in order to develop, offer, and deliver products and services, respond to inquiries from you or your representatives, or to fulfill legal and regulatory requirements. AlphaQuest may collect NPPI about you from many sources, including the following.
- When you visit or use our website, information collected from an Internet collection device (“cookie”),
- From a client or a client’s representatives on applications or forms,
- From third-party vendors,
- From agents with which AlphaQuest has a marketing arrangement,
- From AlphaQuest affiliates, and
- When candidates submit information through the Careers pages.
Clients that choose to invest in AlphaQuest’s trading programs may provide AlphaQuest with NPPI. Such information may include:
- The client’s name, address, email address, telephone number, Social Security or other ID number,
- Information regarding income, financial goals, interests, assets, and source of funds, and
- From transactions made by or with AlphaQuest’s clearing firms (including account balances and cash deposits/withdrawals).
AlphaQuest pledges its commitment to maintain the confidentiality of NPPI and not to disclose NPPI to any nonaffiliated, third parties other than, (a) regulatory agencies or, (b) affiliated or nonaffiliated third parties, including your representatives, in order for them to assist AlphaQuest in providing services to you or, (c) otherwise as permitted by law. However, affiliated and nonaffiliated third parties who receive NPPI in order to assist us in providing services to you are restricted from using your information for any other purpose. Further, AlphaQuest agrees to protect a client’s NPPI by restricting access to such NPPI to those employees and independent contractors with a legitimate need for the information. If a client decides to terminate their investment services relationship with AlphaQuest, AlphaQuest agrees to adhere to the privacy policy and practices as set forth above. In the event AlphaQuest amends its privacy policy, it agrees to provide clients with appropriate notice when such privacy policy changes.
Client information will be retained by AlphaQuest for a period of five years after a client decides to end their business relationship with AlphaQuest, as per applicable regulation.
The policies and practices described in this disclosure are subject to change. Clients will be notified of a change or an annual update regarding the policy and general updates.
AlphaQuest has procedures in place to respond to requests to correct inaccurate information in a timely manner, and to update information and remove old information. Clients may verify their NPPI on file with AlphaQuest by reviewing their account statements from AlphaQuest(s) that perform clearing services. If a client needs to inform AlphaQuest of a correction they may do so via telephone (212) 838-7222, or email [email protected]. Clients should notify AlphaQuest immediately if they receive information that they believe to be inaccurate. Clients with questions regarding the privacy policy should contact AlphaQuest’s Chief Compliance Officer at the telephone and e-mail address provided herein.
Privacy Policy Annex
EU General Data Protection Regulation
This Annex outlines the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679), the (“GDPR”), as it relates to the data protection obligations of AlphaQuest (the “Company”) and your data protection rights as they relate to your registration and use of AlphaQuest’s website, www.alphaquest.com (the “Website”).
Your personal data
You understand that by virtue of registering on the website and your associated interactions with AlphaQuest or by virtue of you otherwise providing AlphaQuest with personal information on individuals connected with you (for example directors, trustees, employees, representatives, shareholders, limited partners, investors, clients, beneficial owners or agents), you will provide AlphaQuest with certain personal information which constitutes personal data within the meaning of the GDPR. This includes, but is not restricted to, data such as your name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your investment activity.
In AlphaQuest’s use of this personal data, AlphaQuest will be characterized as a “data controller” under the GDPR. AlphaQuest’s affiliates and delegates may act as “data processors” under the GDPR.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Why AlphaQuest may use your personal data
You understand that AlphaQuest may collect, store and use this data for lawful purposes including, in particular: (i) where this is necessary for compliance with a legal obligation to which AlphaQuest is subject (such as the anti-money laundering obligation to verify the identity of AlphaQuest’s customers and, if applicable their beneficial owners) and retain copies of materials in respect thereof for seven years after the relationship terminates); (ii) to verify investor eligibility / qualification; and/or (iii) where this is necessary for the purposes of the legitimate interests of AlphaQuest or a third party and such legitimate interests are not overridden by your interests, fundamental rights or freedoms.
It is noted that the GDPR states that the use of personal data for direct marketing purposes (that is, providing you with information on products and services that may be of interest including the reporting of AlphaQuest’s trading program performance) may be regarded as being for the purposes of a legitimate interest. Analyzing personal data for quality control, business and statistical analysis, tracking fees and costs, training and related purposes are also legitimate interests for AlphaQuest using your personal data.
Accordingly, you understand and agree that AlphaQuest may use your personal data for such purposes as described in this Annex, provided that AlphaQuest is acting in a fair, transparent and accountable manner and has taken appropriate steps to prevent such activity having any unwarranted impact on you and also noting your right to object to such use, as discussed in this Annex.
Given the specific purposes for which AlphaQuest envisages using your personal data, under the provisions of the GDPR, AlphaQuest does not anticipate being required to obtain your consent to do so. Should AlphaQuest wish to use your personal data for other specific purposes that require your consent, AlphaQuest will ensure it has already obtained your consent or contact you to request your consent for such usage.
Why AlphaQuest may transmit your personal data
You understand that in certain circumstances AlphaQuest and/or its authorized affiliates and/or delegates may be legally obliged to share your data and other financial information with respect to your interest in AlphaQuest with a regulatory authority and they, in turn, may exchange this information with foreign tax authorities including tax authorities, such as the IRS that are located outside the EEA.
The data protection measures AlphaQuest takes
Any transmission of your personal data by AlphaQuest or its duly authorized affiliates and/or delegates outside the EEA shall be in accordance with the conditions in the GDPR.
AlphaQuest and its duly authorized affiliates and/or delegates shall apply appropriate information security measures designed to protect data in AlphaQuest’s / its affiliates and/or delegates’ possession from unauthorized access by third parties or any form of computer corruption.
AlphaQuest shall notify you of any personal data breach affecting you that is likely to result in a high risk to your interests, fundamental rights or freedoms.
Your data protection rights
You understand that you have certain rights regarding AlphaQuest’s use of this personal data such as (but not limited to):
- the right to access your personal data (in an easily readable form);
- the right to examine and correct your personal data;
- the right to restrict the use of your personal data;
- the right to withdraw any consent given to the processing of your personal data (where applicable);
- the right to receive information regarding any entities AlphaQuest discloses your personal data to; and
- the right to lodge a complaint with the relevant.
You also have the right to object to the processing of your personal data where AlphaQuest has considered this to be necessary for the purposes of AlphaQuest’s legitimate interests.
Please note that the right for your personal data to be erased (the “right to be forgotten”) that applies in some contexts under the GDPR is not likely to be applicable to most, if not all, of the personal data you provide to AlphaQuest through the Website, given the specific nature of the purposes for which AlphaQuest uses the personal data, as described in this Annex.
Getting in touch
As AlphaQuest does not process personal data on a large scale, AlphaQuest is not required to designate a data protection officer. However, should you have any queries or wish to discuss your data protection rights with AlphaQuest, please contact:
Darren Johnston
Chief Compliance Officer
AlphaQuest LLC
126 East 56th Street, 25th Floor
New York, NY 10022
P: 212-838-7222
[email protected]