PRIVACY POLICY

Last updated: March 2024

Cinctive Capital Management LP and its affiliates and the funds and accounts sponsored or managed by them, including Cinctive Global Fund LP, Cinctive Global Fund Ltd., Cinctive Global Master Fund Ltd., Cinctive Macro Fund LP, Cinctive Macro Fund Ltd. and Cinctive Macro Master Fund Ltd. (collectively, the “Adviser,” “Cinctive,” “we,” “us,” or “our”) are committed to protecting the confidentiality and security of information that we collect about individuals.  This Cinctive Capital Privacy Notice (this “Privacy Notice”) describes our data collection and privacy practices with respect to the Personal Information we collect online and offline, including in the course of providing investment fund offerings to our investors and prospective investors (“Investors”) and in connection with the investment funds and accounts to which the Adviser acts as an investment manager (the “Funds”).  By accessing this website and our services, you agree to the collection and use of Personal Information as described in this Privacy Notice and in our Terms and Conditions at https://www.cinctive.com/privacy-policy.

“Personal Information” as used herein means non-public information that is reasonably capable of being linked to or associated with an individual.

Types of Personal Information We Collect

We collect, and in the 12 months prior to the date of this Privacy Notice, we may have collected, and will continue to collect, all of the following categories of Personal Information about Investors and individuals, including our employees and job applicants (collectively, “Employees”), and business partners or commercial customers (collectively “B2B Contacts”) with which we interact, as applicable:

• Contact information and other personal identifiers, such as name, signature, postal and email address, phone number, account name, Social Security number, tax ID number, drivers’ license and passport information.

• Demographic and protected class information: about Employees, including age, sex, gender identity or expression, disability, citizenship status, marital status, national origin, religion, requests for family care, medical or parental leave, or disability status.

• Internet or other electronic activity information: information about your computer, mobile device, browser, and cookie information.

• Financial information: bank account or credit card information to process or receive payments.

• Educational and professional background information: from Employees or Investors, degrees or certifications obtained, educational institutions attended, work and/or military histories; from B2B Contacts, records regarding your work (e.g., location, job title, seniority, etc.). 

• Audio & Video information: recordings of calls made to customer support; security camera footage if you visit one of our physical office locations.

Sources of Personal Information

We may collect Personal Information directly from an Investor, Employee, or B2B Contact directly, through the Funds’ administrator(s), including administrator employees, affiliates, agents or contractors, through an Investor’s agent (including the Investor’s financial adviser), or any other third-party who communicates with the Funds or the Adviser on an Investor’s, Employee’s, or B2B Contact’s behalf. The Adviser may also gather Personal Information about an Investor from subscription documents, transactions, interactive discussions (from which Personal Information about Employees or B2B Contacts may also be collected), and from time to time, banking references or consumer reporting agencies.

Purposes for Collection

We collect Personal Information to undertake the following data processing activities for Investors and individuals, including Employees and B2B contacts as specified:

• administer human resources functions for Employees such as performance reviews and appraisals, sick leave, training, internal organizational charts, internal communications, and termination or retirement issues; 

• administer payroll, benefits, insurance, and other benefits-related functions for Employees;

• manage communications including authorizing, granting and administering Employee access to or use of our systems, facilities, devices and records;

• to investigate and resolve complaints, grievances or misconduct;

• preparing for and acting in relation to inquiries, investigations or proceedings, by governmental, administrative, judicial or regulatory authorities, including civil litigation;

• network and system security and access-related issues, including by protecting the company by monitoring internet access and use and emails transmitted;

• managing customer relationship information, including records of products and services provided;

• health and safety purposes;

• defending legal claims; and

• any other purposes relating to carrying out our business.

Disclosures of Personal Information

The Adviser and the Funds do not share any Personal Information about Investors with non-affiliated third-parties, except as necessary or appropriate in connection with the processing and administration of the Fund's investments, in connection with the Adviser’s and the Funds’ general business operations, or as otherwise required or permitted by law.

For example, Personal Information about Investors may be disclosed as necessary and in a manner required by applicable law, rules or regulations to process an Investor's subscription to a Fund, to the extent required in connection with an investment or transaction the Adviser proposes to make, or to the Adviser’s service providers that are subject to appropriate contractual obligations to maintain the confidentiality and security of the Adviser’s or the Funds’ records. Personal Information may also be disclosed to the extent an Investor specifically authorizes the disclosure, and for other purposes required or permitted by law, such as where reasonably necessary to prevent fraud, unauthorized transactions or liability, to prevent, detect or respond to data security vulnerabilities or incidents, or to respond to judicial process or subpoena.

From time to time the Adviser or a Fund may disclose Personal Information in a manner required by applicable law, rules or regulations to (i) a non-affiliated third-party that provides various services, including promotional services, on behalf of the Adviser or a Fund or (ii) a non-affiliated third-party financial institution, such as a prime broker, in connection with joint promotions by the Adviser or a Fund and the third-party. In such cases, it is the Adviser’s policy to enter into a contractual agreement with the recipient that (a) prohibits it from disclosing or using Investor Personal Information other than to carry out the services provided by the third party pursuant to the parties’ contract and (b) requires the recipient to maintain the security and confidentiality of the information in accordance with applicable laws, rules and regulations.

Adviser may disclose Personal Information about Employees or B2B Contacts to service providers to facilitate an employment relationship, to provide requested products or services, or to promote products or services or employment opportunities to a B2B Contact or Employee, respectively.

The following chart describes the categories of Personal Information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Privacy Notice: