Privacy Policy

January 2020

Financial companies choose how they share your personal information.  Federal law gives our clients the right to limit some but not all sharing.  Federal law also requires us to tell you how we collect, share, and protect your personal information.  Please read this “Privacy Policy Notice” carefully to understand what we do.

Atreides Management, LP (“Atreides” or the “Firm”) does not disclose nonpublic personal information about its prospective, existing or former clients to third parties other than as described below.

If you are invested in a Cayman fund managed by Atreides, you are also entitled to the protections set forth in the Cayman Privacy Notice you should have received in connection with your investment in that fund.

Personal information we collect. Atreides collects personal information about you in connection with providing advisory services to you.  This information includes your social security number and may include other information such as your:

  • Assets;
  • Investment experience;
  • Transaction history;
  • Income; and
  • Wire transfer instructions.

 

How Atreides collects this information. Atreides collects this information from you through various means. For example, when you give the Firm your contact information, enter into an investment advisory contract with the Firm, buy securities (i.e., interests in a fund) from the Firm, tell the Firm where to send money, or make a wire transfer. Atreides also may collect your personal information from other sources. The Firm maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information which the Firm believes are adequate to prevent unauthorized disclosure of such information.

How Atreides uses this information. All financial companies need to share customers’ personal information to run their everyday business and the Firm uses the personal information collected from you for everyday business purposes. These purposes may include for example:

  • To provide advisory services to you.
  • To open an account for you.
  • To process a transaction for your account.
  • To market products and services to you.
  • To respond to court orders and legal investigations.

Disclosure to others.  Atreides may provide your personal information to firms that assist the Firm in servicing your account and have a need for such information, such as a broker or fund administrator. Atreides may also disclose such information to service providers and financial institutions with whom Atreides has joint marketing arrangements (i.e., a formal agreement between financial companies that together market financial products or services to you, such as placement agents).  Atreides requires third-party service providers and financial institutions with which the Firm has joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which the Firm discloses the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. Atreides notes that the Federal privacy laws only give you the right to limit the certain types of information sharing that the Firm does not engage in (e.g., sharing any personal information with others in order for them to market to you).

How Atreides protects your personal information. To protect your personal information from unauthorized access and use, Atreides maintains physical, electronic, and procedural safeguards that comply with Federal law to safeguard nonpublic personal information which the Firm believes are adequate to prevent unauthorized disclosure of such information. These measures include computer safeguards and secured files and buildings.

Your California Privacy Rights.  The Firm complies with the California Consumer Privacy Act of 2018 (“CCPA”) by providing California residents with the following rights with respect to their personal information.

The right to know what personal information the Firm has collected, used, disclosed and sold.  To submit a request to know, California residents may call Atreides at (617) 422-0000.  California residents may also designate an authorized agent to make a request for access on their behalf on the Investment Manager’s website at www.atreidesmgmt.com.

The right to request that the Firm delete any personal information it has collected.  To submit a request for deletion, California residents may call Atreides at (617) 422-0000.  California residents may also designate an authorized agent to make a request for deletion on their behalf on the Investment Manager’s website at www.atreidesmgmt.com.

When California residents exercise these rights and submit a request, the Firm will verify their identity by asking them for their email address, telephone number, and/or information about their account with the Firm. The Firm will endeavor to honor customers’ requests unless such a request conflicts with certain lawful exemptions under the CCPA.  Please note that the Firm is only required to honor such requests twice in a twelve (12) month-long period.

Exercise of these rights will have no adverse effect on the price and quality of the Firm’s services.

For the twelve (12) month-long period prior to the date of this Privacy Notice, the Firm has not sold any personal information about its customers; nor does it have any plans to do so in the future.

Who to contact with questions.  If you have any questions about this Privacy Notice, please contact Dunyelle Rosen by email at Dunyelle@AtreidesMgmt.com.