What Information Do We Collect?
In the course of serving as investment manager to the Funds, HighVista acquires non-public information concerning current, prospective and past investors (collectively, the “Investors”) from several sources, including the subscription agreement and related documents, correspondence, and discussion between the Investor and HighVista representatives, and transactions with HighVista. The non-public personal information obtained may include, but is not limited to, the Investor’s name, address, social security number, government-issued identification, tax identification number, net worth, total assets, income and other financial information necessary to determine required accreditation and qualification standards as well as financial sophistication. We refer to all of this information as “Investor Information.”
Our Site does not honor Do-Not-Track signals.
How Do We Use Your Information?
We use the Investor Information we collect to provide you with information and services that you agree to receive from HighVista and to process your requests, communicate with you, provide you with other services and updates, as well as to administer our website and comply with applicable laws.
We use other information collected from Visitors to analyze demographic and other trends, administer the Site, and track aggregate usage of the Site.
What Information Do We Disclose?
As a matter of policy, HighVista does not disclose Investor Information other than to: affiliated entities, when required to do so by business operations; non-affiliated entities that perform services for the Funds and/or HighVista (“Service Providers”), such as attorneys, auditors, and Fund administrator(s); or for regulatory or tax purposes as the information is required to effectively manage the Funds and the business. For instance, it may be necessary for HighVista to disclose information about a particular investor pursuant to anti-money laundering regulations in order to accept a subscription from that Investor or make an investment in a particular fund.
How We Protect Your Information
All HighVista employees are bound to protect the confidentiality of personal information and to prevent unauthorized use, access to, or disclosure of such information. The use of, and access to, personal information is restricted to those employees who need to know that information to provide services for HighVista. To enforce this policy, HighVista maintains and regularly reviews physical, electronic, and procedural safeguards designed to protect personal information from unauthorized access and disclosure. However, no information security safeguards can be guaranteed to be completely secure, so you should use caution whenever providing personal information online, electronically or otherwise.
Access to Information
California’s “Shine The Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. HighVista does not distribute your personal information to outside parties for their direct marketing.
Policy last updated April 2017