Privacy Policy

This Privacy Policy sets forth how Dean Ryle Asset Management, LLC, its subsidiaries and affiliates (referred to herein collectively as “Dean Ryle” or “we”) collect and process personal information about you. We are providing this Privacy Policy to you to satisfy disclosure requirements required under data protection and privacy regulations adopted by regulatory authorities in the jurisdictions in which Dean Ryle conducts business. These regulations require that Dean Ryle ensure that you understand how we collect, use, process and share your personal information.

This Privacy Policy applies to visitors to this website (the “Site”), visitors to our offices, individuals who call Dean Ryle personnel in certain of our offices, third-party service providers, vendors and suppliers, business contacts and prospective clients and investors. Dean Ryle provides separate privacy notices to other categories of individuals, such as current clients and investors, job applicants, and persons connected with underlying investments of Dean Ryle funds and as such information regarding these categories of individuals is not included here. If you provide personal information to us about any person other than yourself, you must ensure that the other person understands how their information will be used.

If you visit this website, you should review this Privacy Policy carefully and in conjunction with the Terms and Conditions of the Site, which detail other important information surrounding your use of the Site.

This Site is not intended for use by children under the age of 13. We do not knowingly collect information from or relating to children.

Collection of Personal Information

Website Visitors

Depending on how you choose to use the Site, we may need you to provide the following information:

to contact us - name, address, e-mail address, telephone number and other contact details along with any other information you choose to provide;
to login to our client/investor portal - username and password; and
to subscribe to certain communications - email address and country of residence (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us).

For information on technology and cookies used on the Site, see the section entitled “Use of Technology and Cookies” below.

Office Visitors and Callers

When you visit Dean Ryle offices or telephone certain Dean Ryle employees, we may collect certain personal information such as:

name, organization and other contact details;
video images of you in certain areas of the buildings in which our offices are located from CCTV footage; and
date and time of your visit to Dean Ryle offices.

Third-Party Service Providers, Vendors and Suppliers

In the process of engaging third-party service providers, vendors and suppliers, Dean Ryle may collect certain personal information about them and/or about their individual representatives and associates including:

name, job title, telephone number, email address and other contact details;
the name of the third-party service provider, vendor or supplier with whom you are associated and its address; and
information required to process payments, such as a tax I.D. number and wire instruction details.

We may also collect personal information about you from companies who maintain anti-money laundering and terrorism sanction screening and know your customer databases.

Business Contacts and Prospective Clients and Investors

Dean Ryle may collect personal information about individuals or representatives of organizations with whom Dean Ryle has a business relationship (or with whom Dean Ryle seeks to establish a business relationship), as well as prospective clients and investors. Such information may include:

name, address, telephone number, email address and other contact details;
organization name and address, job title; and
investor type, strategy, product and communication preferences (if you choose to receive marketing communications, you will have the option to opt-out of receiving such communications at any time by contacting us).

Use of Personal Information

Your personal information will be processed: (i) in order to comply with our legal and regulatory obligations; (ii) because we need the information in order to comply with our obligations under contract; and/or (iii) because we have a legitimate business interest in processing it, including for the following purposes (as applicable):

to respond to your questions and handle and resolve complaints;
to perform research with respect to the usage of the Site (applicable to website visitors);
to personalize and enhance your website experience (applicable to website visitors);
to maintain the security of our premises, personnel, assets, systems and intellectual property and to manage access to our premises and our disaster recovery procedures (applicable to office visitors);
to pay you for your services (applicable to third-party service providers, vendors and suppliers);
in order to comply with our obligations in connection with record-keeping requirements and applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of jurisdictions in which Dean Ryle conducts business (applicable to office callers, third-party service providers, vendors and suppliers);
to maintain and provide appropriate management of our relationship with you;
to engage your services in the future (applicable to third-party service providers, vendors, suppliers and business contacts);
to contact you to set up meetings and/or phone calls between you and your Dean Ryle business contact(s); and
to process your subscription requests and to send marketing communications about Dean Ryle to you (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us) (applicable to website visitors, business contacts and prospective clients and investors).

Where required by applicable law, we will obtain your prior consent before sending you direct marketing communications.

For information on how we use and process technology and cookies on the Site, see the section entitled “Use of Technology and Cookies” below.

Where Dean Ryle is relying on its legitimate interests as the ground for processing your personal information, we must carry out an assessment to ensure our interests do not override any rights you may have.

Sharing and Transfer of Personal Information

We may share the personal information we store about you with:

Dean Ryle affiliated entities;
Third-party service providers, vendors, contractors, and agents of Dean Ryle as part of normal business operations, including providers:
1. engaged to assist in know your customer and identity verification and anti-money laundering and terrorism screening (applicable to third-party service providers, vendors and suppliers);
2. of accounting, banking and other data processing services;
3. of information technology services and platforms/applications;
4. of call recording and storage services (applicable to office callers);
third party outsourcing providers;
building security personnel (applicable to office visitors);
third parties acting on your behalf such as consultants and other agents;
governmental authorities and/or law enforcement officials where required;
financial institutions to wire payments to you (applicable to third-party service providers, vendors and suppliers); and
advisors who provide audit, financial and legal advice to Dean Ryle.

Dean Ryle may also disclose your personal information to particular parties pursuant to your express consent, to fulfill your instructions, to comply with applicable laws and regulations or to fulfil other applicable requirements.

Personnel employed by service providers generally may have access to your personal information for the purpose of performing duties for Dean Ryle but are prohibited from using such information for other purposes.

Safeguarding of Personal Information

Dean Ryle maintains established internal policies and procedures as well as physical and electronic safeguards that comply with applicable standards to safeguard access to personal information in our possession from accidental or unlawful destruction, loss, alteration, unauthorized use or disclosure. We endeavor to limit access to personal information about you to those employees, agents and other authorized parties who need to know the information to enable Dean Ryle to provide products or services to you. Please note that such safeguards, however, do not guarantee that personal information transmitted via the Internet or stored in our systems or is otherwise under Dean Ryle’s care will be absolutely safe from unauthorized use or intrusion from third parties due to the inherent nature of the Internet.

Retention of Personal Information

Personal information stored by Dean Ryle is generally retained for a period of ten years from (a) the date the data record was created or (b) a particular trigger event depending on the type of data record containing the personal information. Examples of trigger events are (i) the tax filing year in which an invoice for services received is paid, (ii) date of contract expiration or termination, and (iii) account closure or fund dissolution date.

Your Rights

The rights described in this paragraph are applicable to you only if you reside in a jurisdiction where the provision of such rights is required by the data protection and privacy laws and regulations of the governing regulatory authority. As such, where required by applicable law or regulation, you may ask Dean Ryle for a copy of your personal information, to correct it, to erase it or to transfer it to other organizations. You may also have rights to object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent. In particular, you have rights to object to direct marketing at any time.

You should also be aware that these rights may be limited (for example, access to personal information may be denied if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information). In addition, Dean Ryle may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your personal information. Where we must collect and process personal information in order to comply with applicable law or enter into and perform services under an agreement with you if you do not provide the personal information we may not be able to enter into the agreement or provide services as contemplated by any agreement we have in place. Where we are not able to fulfill a request, you make because your rights are limited, we will inform you of the reasons as to why when responding.

Should you have any questions or requests in relation to your rights, please email DataPrivacyTeam@deanryle.com. We will attempt to deal with all requests at the earliest opportunity. In addition, if you have unresolved concerns you have the right to complain, where permitted, to competent data protection authorities.

Use of Technology and Cookies

Dean Ryle may collect certain information about you through the use of technology, such as cookies. Cookies are pieces of information, or files, placed on your device’s disk that provide information including how and when pages on the Site are accessed by users. To find out more about cookies please visit www.allaboutcookies.org, which contains further information about behavioral advertising and online privacy.

We use the following types of cookies on our Site:

Required Cookies - These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for, such as remembering your login details, cannot be provided.

Analytics Cookies - These cookies remember choices you make, such as the duration of your session. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized (such as the IP address through which you visit the Site) and they cannot track your browsing activity on other websites. Dean Ryle uses a Google Analytics cookie to collect this information; you have the right to opt-out of having the Google Analytics cookie placed on your browser.

When visiting the Site, you may receive a pop-up consent banner informing you of our use of cookies and asking you to agree to allow us to use particular analytics cookies while you browse the Site. In the consent banner, you may click “Cookie Consent Tool” to see which cookies we have on our Site and choose whether to accept or opt-out of certain cookies while on the Site. Should you choose not to give your consent for us to use some or all of the analytics cookies on our Site, these cookies will not be placed on your browser while you browse the Site.

You may also configure your browser to set preferences regarding cookies such that you can have your computer warn you each time a cookie is sent. Note that you may decline placement of cookies if your internet browser permits, though this may impact your experience of using the Site, and certain portions of the Site may be inaccessible to you if you choose to do so. You may at any time delete any cookies from your hard drive. Aggregated data gathered from cookies is used by Dean Ryle to help maintain and improve the information provided on this Site for users. Dean Ryle may also employ other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We take seriously the protection of your personal information and have contracts in place with these authorized third parties to protect your personal information. We may also use these technical methods in HTML e-mails that we send Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. Dean Ryle may collect the information from use of these technical methods in a form that is personally identifiable.

During some Site visits, Dean Ryle may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page. Dean Ryle may use this information to measure Site activity, to develop ideas for improving the Site and for any other purpose to the extent permitted by applicable law.

Links to Third-Party Websites

The Site may contain links to third party websites which, in some cases, may be integrated into, and appear to be part of, the Site. Dean Ryle encourages you to read the privacy policies of other websites you link to from this website and disclaims any responsibility for the privacy policies and procedures of any third-party websites that you reach via a hyperlink contained on this Site. Such hyperlinks are provided for your convenience only, and you access them at your own risk.

Updates to this Privacy Policy

Dean Ryle reserves the right in its sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting and we will indicate in the Privacy Policy when it was most recently updated. You should review this Privacy Policy periodically for changes applicable to you. Additionally, note that by accessing this Site subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended.

Please direct any questions regarding Dean Ryle’s Privacy Policy to DataPrivacyTeam@deanryle.com.

Dean Ryle Asset Management, LLC

800 Third Avenue

Suite 2800, New York, NY, 10022

Phone: 1-631-250-2829

This Privacy Policy is dated August 30, 2020