Privacy Policy

Your Privacy Is Our Priority

At Anthelion, we value the confidence you have placed in us. In trusting us with your assets, you provide us with personal and financial data. Anthelion is committed to maintaining the confidentiality of the personal nonpublic information (“personal information”) entrusted to us by our customers. Your privacy is very important to us, and we are dedicated to safeguarding your personal information as we serve your financial needs.

Our Privacy Policy

We believe you should know about Anthelion’s Privacy Policy and how we collect and protect your personal information. This Privacy Policy (“Policy”) describes our practices and policy for collecting, sharing and protecting the personal information of our prospective, current and former customers. The Policy is applicable to Anthelion Associates, Inc., its affiliates and subsidiaries, as well as the products Anthelion and its affiliates distribute or manage (“Anthelion”).

Our Commitment to Privacy

The relationship between Anthelion and our clients is our most important asset. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect the confidentiality, integrity and security of your non-public personal information. As we believe that all of our clients value their privacy, we do not disclose your non-public personal information to anyone unless it is required by law, at your direction, or is necessary to provide you with our services. We do not sell your non-public personal information to anyone.

Information We Collect

The type of personal information we collect and use varies depending on the context of your interaction with us and our website.

We collect personal information that enables us to serve your financial needs, develop and offer new products and services, maintain our business operations, and fulfill legal and regulatory requirements. Information that we collect and use includes:

  • Information about who you are (e.g., Name, Date of Birth, contact details, government identification number);

  • Information associated with your product or service (e.g., bank account details and purchases and redemptions of fund shares);

  • Information about contact with us (e.g., meetings, phone calls, letters and emails/electronic messaging);

  • Information that is collected automatically (e.g., via cookies when accessing our website); and

  • Information collected when visiting one of our offices (e.g., images collected via closed-circuit TV (CCTV).

Why We Collect Personal Information

We collect and process your personal information only as necessary or appropriate for our business purposes. There are certain lawful bases for which we are allowed to use your personal data. Most commonly, we will rely on one or more of the following lawful bases for processing your personal data:

  • where it is necessary for the performance of a contract;

  • where it is necessary for compliance with a legal obligation to which we are subject;

  • where it is necessary for the purposes of the legitimate interests pursued by us or a vendor, except where such interests are overridden by your interests or fundamental rights and freedoms, which require protection; and/or

  • where you have provided consent as required by applicable law, we may send you information regarding Anthelion products and services.

Generally, we do not rely on your consent as a lawful basis for processing your personal data.

Personal Information That We Collect, Maintain, and Communicate

We collect and maintain your non-public personal information, so we can provide investment management services to Funds or Accounts in which you may invest. The types and categories of information we collect and maintain about you include:

  • Information we receive from you to open an account or provide investment services (such as your date of birth, social security number, address, telephone number, and financial information);

  • Information about your transactions with us, our affiliates, or others to service your account (such as trade tickets and account statements);

  • Information that we receive from third parties with respect to your account (such as trade confirmations from brokerage firms); and

  • Information provided to us by authorized parties acting on behalf of our clients such as accountants, attorneys, and investment consultants.

In order for us to provide investment management services, we may disclose the non-public personal information that we collect and maintain in very limited instances, which includes:

  • Disclosures that are authorized or requested by you;

  • Disclosures that are required by law (for example, to cooperate with regulators or law enforcement authorities);

  • Disclosures to companies that perform services on our behalf (such as data processors that provide investment accounting and reporting services, or otherwise assist us in delivering services to our clients) subject to agreements that prohibit such companies from disclosing or using the information other than for the services required or as permitted by law; and

  • Disclosures to companies as otherwise permitted by law, including those necessary to service your account (such as providing account information to brokers or custodians).

How We Protect Your Personal Information

To fulfill our privacy commitment, we have instituted firmwide practices to safeguard the information that we maintain about you. These include:

  • Maintaining physical, electronic and procedural safeguards that comply with federal regulations to guard your non-public personal information;

  • Limiting access to non-public personal information to employees and third parties that are necessary or appropriate to provide services to you;

  • Requiring third parties that perform services to us to agree by contract to keep your information strictly confidential; and

  • Protecting information of our former clients to the same extent as our current clients.

The privacy of individuals who visit the Site is important to us. Personal information submitted electronically to Anthelion is treated in the same manner as information submitted via a mail service or during an office visit. We do not compile personal information or other information for sale to third parties.

Anthelion does collect and retain statistical and technical data about visits to the Site, such as the date and time of the visit, the length of the visit, and the pages visited. We use this information to improve the content of our web services and to help us understand how visitors use our services. This information may be shared with an outside consultant to improve the quality of the Site and prevent pay-per-click fraud.

Anthelion retains the right to monitor network traffic to identify any unauthorized attempts to cause damage to or manipulate current information on the Site.

The Site does not currently use “cookies”. We retain the right to use cookies in the future. Cookies are simple text files stored by your web browser and are used to enhance our functionality and your browsing experience. None of the information collected identifies you personally, but instead stores a randomly generated identifying tag on your computer. Cookies are commonly used to increase an application’s functionality and stores information such as: a list of forms you wish to download, search strings, your browsing preferences, etc. Many cookies are only stored temporarily. You have the ability to refuse a cookie or delete the cookie file from your computer using many widely available methods.