This notice contains disclosures required by the California Consumer Privacy Act (“CCPA”), is only relevant to residents of California, and applies only to the collection or other use of “personal information” that is subject to the CCPA. Consumers with disabilities may access this notice by downloading or printing the notice from https://brahman.com/ccpa-download.
Information We Collect. In the past 12 months, we have collected the following categories of personal information about California consumers:
We collect personal information from the following categories of sources:
Use of Personal Information. We may use the personal information we collect for one or more of the following purposes:
o Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
o Legal compliance; and
o Internal operations;
Retention of Personal Information. We retain the personal information collect, including sensitive personal information, for at least as long as is required by the Investment Advisers Act of 1940 or other applicable regulations.
Disclosing Personal Information. We may disclose personal information in one or more of the categories identified above to:
Sharing Personal Information. The CCPA defines sharing as the sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising.
In the past 12 months, we have not sold or shared any personal information we collect to third parties, and we have disclosed the categories of personal information we collect only as set forth above.
Rights of California Consumers. The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:
You may submit requests relating to your exercise of rights under the CCPA to us:
via phone 212-681-9797;
We may need to request additional information from you to verify your identity or understand the scope of your request. In verifying requests, we will require you to provide, at a minimum the address and phone number on file. If we are unable to verify your identity, we will need to deny your request.
You may designate an authorized agent to make a CCPA request on your behalf. In such case, we will ask the agent to provide proof that you have given the agent signed permission to act on your behalf. In addition, we will ask you to either (1) verify your identity directly with us in the manner described above or (2) directly confirm with us that you have provided the agent permission to make the request on your behalf.
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