HighVista Strategies

HighVista Strategies LLC Privacy Policy

Protecting the confidentiality, integrity, and security of non-public personal information is fundamental to the way HighVista Strategies LLC (“HighVista”), the Investment Manager to one or more funds (the “Funds”), conducts business. As the Funds’ Investment Manager, HighVista takes its privacy responsibilities very seriously. As required under applicable federal law, this Privacy Policy sets forth the privacy policies of HighVista and its Funds, and it details the extent to which HighVista protects the non-public personal information of visitors (collectively, “Visitors”) to www.highvistastrategies.com (the “Site”).

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.”

Like most websites, we, our service providers, and our third-party partners may collect certain information about your interaction with the Site.  This information may be stored in log files. Information stored in log files may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, pages viewed and other information.  We collect this information through the use of cookies and other similar technologies. 

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.

HighVista will also disclose information about an Investor if the Investor directs HighVista to do so, in connection with any government or self-regulatory organization request or investigation, or as otherwise required by law. If you redeem your investment, HighVista may continue to share your information as described in this Privacy Policy.

We may also disclose personal information pursuant to a request from law enforcement, or as otherwise required by law, or, in our sole discretion, to protect our rights, property or interests, including to enforce this Privacy Policy or other legal requirements.  Information collected may also be transferred as part of a merger or other combination, or as part of a restructuring, bankruptcy, transfer of assets, or to our successors in interest.

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.

Changes to our Privacy Policy

From time to time, we may modify this Privacy Policy in our sole discretion.  If we make any updates or changes to this Privacy Policy, all modifications will be posted to this site, and will be effective immediately upon our posting.  Visiting the Site, or using the Site, after updates are posted and effective constitutes acceptance of any changes.

Policy last updated April 2017