In providing financial services and products to you, we or our service providers will collect certain nonpublic personal information about you. Our policy is to keep this information confidential and strictly safeguarded, and to use or disclose it only as needed to provide services to you, or as permitted by law. Protecting your privacy is important to us.
The nonpublic personal information we have about you comes from sources such as account applications and forms, from other written, electronic or verbal correspondence, from other financial advisers or consultants, among others, and includes information you provide when you open an account, subscribe for an interest in one of our private funds, buy shares of one of our mutual funds, visit our website, or otherwise communicate with us or with a third-party who has obtained your consent to share such information with us. This information may include, but is not limited to: your name, address, social security number, date of birth, investment objectives and experience, financial circumstances, employment and your account and account transactions, e-mail address, driver’s license number or passport number age, marital status, income level, occupation, information relating to your specific financial condition, We may also collect information through your use of our website, including device identifiers and IP addresses.
We disclose nonpublic personal information about you only to our affiliates, to third parties we hire to help us provide products and services to you, as specifically authorized by you, or as otherwise allowed or required by law. We do not sell your
personal information to anyone.
We have physical, electronic and procedural safeguards in place that are designed to protect the security and confidentiality of your information. These include confidentiality agreements with companies we hire to help us provide services to you, password protected user access to our computer files and strict confidentiality policies that apply to all Driehaus personnel.
This Privacy Notice is from the Driehaus Mutual Funds, Driehaus Capital Management LLC and Driehaus Capital Management (USVI) LLC.
We are sending to you or posting this Privacy Notice on our website to let you know how we treat personal nonpublic information about you, as a present or former Driehaus Mutual Fund shareholder, as a client of DCM LLC or as an investor in a private fund managed by DCM LLC.
We gather various types of information about you when you inquire about our products or services, during the account opening process and throughout your on-going relationship with us. See the section above entitled “Information We Collect” for a list of this information. We also have records of your account transactions, including the dollar amounts you have invested or withdrawn, your account balances and our communications with you. We may receive additional information about you from custodian banks, prime brokers, or others that service your account.
We use information about you to provide our financial products and services to you, such as managing your investment account or servicing your Driehaus Mutual Funds account. We share this information among the Driehaus Mutual Funds and Driehaus affiliated companies. We also may disclose it, as permitted by law, to third parties that we use to provide our services to you, including outside broker-dealers, custodian, administrators, transfer agents, accountants or attorneys. Additionally, from time to time, we must give information about our business to regulatory authorities. This may include personal information about you.
We do not sell personal nonpublic information about our clients, investors in the products we offer, Fund shareholders, employees or third persons.
The California Consumer Privacy Act (“CCPA”), as amended, gives you the right to know what personal information we intend to or have collected about you and why. For clients and investors of DCM, affiliated private funds, and Driehaus Mutual Funds, we described how we process your personal nonpublic information in our Privacy Notice.
For purposes of this notice, “personal information” means information that identifies, relates to, describes, references, is capable of being associated with or could reasonably be linked, directly or indirectly, with you or your household. Personal information does not include information that is publicly available nor does it include deidentified or aggregated consumer information.
The types of personal information we collect about you depends on the nature of your interactions with us. We may have collected the following categories of personal information from you in the last 12 months:
Identifiers potentially including, without limitation, full name, home address, internet protocol (IP address), email address, account name, Social Security number (SSN), drivers license number, passport number, or other similar identifiers;
Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code. Section 1798.80(e)) potentially including, without limitation, name, signature, SSN, driver’s license number, passport number, employee identification numbers, insurance policy number, bank account number, credit or debit card number, or any other financial information, medical information, or health insurance information;
Protected Classification Characteristics under California or federal law potentially including, without limitation, race, color, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, age, religion, national origin, disability, veteran or military status, citizenship status, and genetic information or ancestry;
Commercial Information potentially including, without limitation, records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies, personal trading account information, industry memberships;
Biometric Information potentially including, without limitation, genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract or template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait or other physical patterns, and sleep, health or exercise data;
Internet or Similar Network Activity potentially including, without limitation, information regarding interaction with our website, applications or advertisement, browsing history and search history, login credentials;
Geolocation Data potentially including, without limitation, physical location or movements;
Sensory Data potentially including, without limitation, audio, electronic, visual, thermal or similar information;
Professional or employment-related information potentially including, without limitation, current or past job history or performance evaluations;
*Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) *including, without limitation, education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information and disciplinary records; and
Inferences drawn from other personal information included above to create a profile reflecting a person’s preferences or characteristics.
We collect personal information in many ways, including directly and indirectly from you, through electronic technologies through which you interact with us, such as our internet and intranet sites, internal computer and communications networks, email and voice mail messages and systems, text and instant message systems and third-party services and publicly available sources such as Linkedin and Facebook. We also collect information via other electronic means such as physical access control technologies, reception logs, and closed-circuit TV.
We do not sell any personal information we collect. Personal information is only shared with third parties for legitimate business or employee related purposes.
We may share your personal information with third party service providers, agents, sub-contractors and other persons that provide services to us in order to carry out our business activities, with third parties who are engaged by us to provide services to us, such as accountants, auditors, lawyers, marketing companies, etc., or to regulators or government agencies in order to comply with applicable law or judicial process.
The CCPA provides you the right to request access to specific pieces of information we have collected from you. You also have the right to request that we delete personal information about you, however we may not be able to delete personal information if we are required to retain this information for legal or ongoing business purposes. You can contact us at 1-800-688-8819 or by submitting a request through our website at www.driehaus.com/contact.
If we do not delete certain items of personal information because we have a legal right or obligation to retain that information, we shall notify you of that. Further, if we do not delete certain items of personal information because we have a legal right or obligation to retain that data, we shall delete that information at such later time that we no longer have a legal right or obligation to retain that information.
We are not required under CCPA to provide information to you about our collection of your personal information or our sale and disclosure of personal information about you more than twice within a 12-month period. Additionally, we may refuse to honor unfounded or excessive repetitive requests to us or charge a reasonable administrative fee for honoring those requests, and in either case, will notify you of our decision.