What Information Do We Collect?
In the course of serving as investment manager, 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 Investors and/or HighVista (“Service Providers”), such as attorneys, auditors, and administrator(s); or for regulatory or tax purposes as the information is required to
effectively manage 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.
We will retain Investor Information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. In some circumstances, we may anonymize Investor Information so that it can no longer be associated with you, in which case it is no longer Investor Information.
Website Visitors from outside the United States
UK, European Union, and Switzerland Residents
HighVista does not have an establishment in the UK, the European Union or Switzerland; it does not monitor data subjects in those jurisdictions; and it does not market its Services in those jurisdictions. HighVista is thus not subject to the EU or UK General Data Protection Regulation (GDPR) or any other data protection law in these jurisdictions.
Nevertheless, individuals from these jurisdictions should be aware that any data provided to us is transmitted to and processed in data centers located in the United States.
Although we are not subject to these (or any non-U.S.) data protection laws, if you are a resident in these jurisdictions, we will honor the following rights, subject to reasonable limitations consistent with our lawful and legitimate business needs and interests:
- Your request for an accounting of all Investor Information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
- Your request that we correct or update any Investor Information that pertains to you;
- Your request that we delete any Investor Information that pertains to you; and
- Your full or partial withdrawal of your consent to the collection, processing, and/or transfer of your Investor Information.
To request an accounting of your Investor Information, a correction or update to your Investor Information, deletion of your Investor Information, or to withdraw your consent to the collection, processing, and/or transfer of your Investor Information, please contact us through the “Contact Us” page on this website. Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
The California Consumer Privacy Act (CCPA) provides California residents with specific rights regarding their Investor Information. If you are a California resident, you have the following rights (and each Investor is individually and separately notified of these rights):
- The right to know which personal information is being collected.
- The right to know if personal data is being sold or shared, and to whom.
- The right to object to the sale of personal data
- The right to access one’s own personal information
- The right to equal service and price, even for consumers who exercise their privacy rights
When a request to know or a request to access is submitted, HighVista will ask that you provide certain pieces of information in order to verify your identity. If you submit a request for the specific pieces of information HighVista has collected about you, HighVista will also require a signed declaration under the penalty of perjury confirming you are the individual whose personal information is the subject of the request. If HighVista is able to verify your identity, we will respond to your request by (a) providing the requested information; or (b) explaining why the CCPA does not require HighVista to provide the requested information. If HighVista is unable to verify your identify, we will respond by explaining why your identity cannot be verified.
When a request to delete is submitted, HighVista will ask you to provide certain pieces of information in order to verify your identity. If HighVista is able to verify your identity, we will respond to your request by (a) deleting your personal information and, if applicable, directing any of our service providers to delete your personal information; or (b) explaining why the CCPA does not require HighVista to delete your personal information. HighVista may choose to delete personal information by de-identifying, aggregating, or completely erasing the information. High Vista will specify the manner in which your personal information is deleted.
HighVista will maintain records of requests made pursuant to the CCPA for a period of at least 24 months.
Requests shall be processed at no charge to the individual and shall be submitted no more than twice during a twelve (12) month period. Authorization and verification of identity will be required, and HighVista will verify the authenticity of the requests.
HighVista will not discriminate against individuals who exercise privacy rights conferred by the CCPA.
HighVista does not sell your information (as the word “sale” or “sell” is defined under the CCPA). To request access to your Investor Information or deletion of your Investor Information, please contact us through “Contact Us” page on this website. Once we have received your request, we will respond to you promptly to confirm your request and to advise you of the actions we will take in response to your request.
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.
HighVista’s Services are not designed to be used by persons under 18 years of age. If you are under the age of 18, you are not permitted to use this Website. If we learn we have collected or received Personal Information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us through “Contact Us” page on this website. For purposes of the CCPA, other state laws governing the collection and use of minors’ personal information, and the Children’s Online Privacy Protection Act (“COPPA”), HighVista does not have actual knowledge that it collects, maintains, or sells the Personal Information of any users under 18.
Questions or Concerns
Effective Date: July 21, 2021