Privacy Notice
By means of this privacy notice, Volt Investment Holdings LLC and Volt Investment Holdings B.V. (together, "Volt", "we" or "us") informs its EU and US clients and investors about the processing of their personal data. Volt respects the privacy of its customers and processes their personal data in accordance with the applicable data protection legislation.
We use the word 'you' to refer to anyone within the scope of this privacy notice.
What Do We Do With Your Personal Data?
The applicable data protection legislation, including federal law, requires us to tell you how we collect, share, and protect your personal data. Please read this notice carefully to understand what we do.
We do not disclose nonpublic personal information about our (former) clients or investors to third parties other than as described below.
Personal data we collect
We collect personal data about you in connection with providing our advisory services to you or in connection with your investment in one or more funds or accounts managed or advised by us. This data may include your social security number where such processing is allowed by applicable law and may include other data such as your:
- Contact details (including home address, telephone number and email);
- Gender, age and nationality;
- Identification documents and photos;
- Investment experience and risk tolerance;
- Transaction activity and history;
- Assets and income information;
- Source of funds;
- Tax information;
- Information to allow Know Your Customer (KYC) and Anti Money Laundering (AML) requirements to be fulfilled; and
- Bank account details.
As part of our compliance with legal obligations such as AML/KYC, we may be required to process special categories of personal data, as well as criminal convictions and offences.
How we collect this information
We collect this information through various means, including directly from you. For example, when you give us your contact information, complete subscription documents, tax forms and other related documentation that you complete when you subscribe for an investment in a fund, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates or other non-affiliated companies and publicly available sources.
How we use this information
All financial companies need to share customers’ personal information to run their everyday business, and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example:
- To provide advisory services to you.
- To establish and administer 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.
- To comply with our legal and regulatory obligations.
Disclosure to others
We may provide your personal data to:
- our affiliates and to firms that assist us in servicing your account and have a need for such information, such as fund administrators, financial institutions, attorneys, auditors, accountants, professional advisors and Know Your Client (KYC) and Anti-Money Laundering (AML) administrators;
- service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between non-affiliated financial companies that together market financial products or services to you, such as placement agents). We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them;
- Tax authorities, to comply with applicable law and regulation; and
- Regulators, supervisory authorities or other bodies, to comply with legal obligations.
How we protect your personal information
To protect your personal information from unauthorized access and use, we use security measures that comply with Federal and EU data protection law. These measures include computer safeguards and secured files and buildings.
Who to contact with questions
If you have any questions about this Privacy Notice, please contact the Firm’s Chief Compliance Officer, Matthew Mandino at matt@voltinvestmentholdings.com or +1 (917) 830-9573.
Changes
We reserve the right to unilaterally change or update this Privacy Notice. To the extent required by applicable law, we will inform you of such changes or updates.
Information for US Clients or Investors
Financial companies choose how they share your personal information. Federal law gives our clients and investors the right to limit some but not all sharing.
Our sharing practices as referred to in the section 'disclosure to others' 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. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you).
Information for EU Clients or Investors
Purposes and legal grounds. We rely on the following legal grounds for processing when processing your personal data: the performance of a contract with you, a legal obligation, your consent and our legitimate interests. Our legitimate interests include marketing, advertising, research and optimizing our services. Please find an overview of the purposes for which we process your personal data, including the legal ground relied upon, below:
| Purpose | Legal Ground |
|---|---|
| To provide our services to you, including advisory services, establishing and administering fund investments, processing a transaction for you, and meeting our contractual obligations to fund investors | The performance of a contract with you |
For legitimate interests to:
|
Our legitimate interests, or those of a third party, to process your personal data |
| To undertake investor due diligence, KYC and AML screening, verify the identity of our investors (and beneficial owners, as required), verify compliance with sanctions and laws, and comply with obligations such as CRS and FATCA | To comply with applicable legal and regulatory obligations |
| Marketing and advertising our products and services, including investor letters and presentations | Our legitimate interests and where necessary your consent |
| To comply with laws and regulations, respond to court orders and comply with legal, regulatory or tax authority investigations | To comply with a legal obligation and our legitimate interest |
Transfer of your personal data
We will only transfer your personal data to third parties mentioned in the section 'disclosures to others' for the purposes included in this privacy notice, and only to the extent that such is permitted under the applicable data protection legislation.
To be able to provide our services, it might be necessary that we transfer your personal data to other countries, including countries outside the European Economic Area such as the United States. If we do so, we take all measures necessary to safeguard your personal data and to ensure that the transfer of your personal data to such countries is permitted under the applicable data protection legislation. For more information on the safeguards we have implemented please reach out to us using the contact details included below.
How long we retain your personal information
We will not store your personal data longer than necessary to achieve the purposes stated in this privacy notice, unless we are required by law to do so.
Generally, we retain your personal data at least seven years to meet our statutory retention obligation.
Your Rights
You have the following rights:
- Right of access, this means you can make a request to obtain access to the personal data concerning you;
- The right to rectification or correction of your personal data;
- The right to erasure of the personal data concerning you;
- The right to restriction of the processing;
- The right to data portability, this means that you have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit those data to another controller;
- The right to object; and
- The right to withdraw your consent.
You can exercise these rights by contacting us using the contact details included below.
In addition to the above stated rights, you also have the right to lodge a complaint with a supervisory authority. The supervisory authority for the Netherlands is the Autoriteit Persoonsgegevens.