This Privacy Policy (the Policy) describes how Aurora Capital Group collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and our websites.

In this Policy when we refer to Aurora Capital Group or “we”/”us”/”our” we mean Aurora Capital Group, Aurora Asset Management, Inc. and other entities that are associated with us. If you are a resident of the European Union (EU) or the United Kingdom (UK), the GDPR, to the extent applicable, imposes certain obligations on us, as a data controller, and grants certain rights to data subjects located in the EEA or UK (“data subject,” “you” or “your”). This Privacy Policy provides information on our use of your personal data in accordance with, each as amended from time to time and as applicable, the EU General Data Protection Regulation (Regulation (EU) 2016/679) (together with applicable implementing laws, the “EU GDPR”), or by the EU GDPR as retained by The Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 pursuant to the European Union (Withdrawal) Act 2018 (each as amended, and together with the UK Data Protection Act 2018 and other applicable implementing laws, “UK GDPR”, and together with the EU GDPR as applicable, “GDPR”).The rights discussed in certain sections of this Privacy Policy may be subject to exemptions or other limitations under applicable law.

If you are a California resident, please review our section “Additional information for California residents” for additional disclosures, our Notice at Collection, and a description of your rights under the California Consumer Privacy Act.

We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.

This Policy describes:

• Categories of information that we collect
• How we use the information we collect
• How we share information with third parties
• How long we keep your information
• Your rights regarding your personal information
• Cookies
• How to contact us and other important information

The information that we collect and where we obtain it from

“Personal information” is any individually identifiable information or information that, in combination with other information, could reasonably allow the identification of an individual.

We will collect and process the following categories of personal information about you:

Information that you provide to us

We may process personal information that you provide us through direct interactions, including when you email us or contact us through various channels as follows:

• Signing up for access to our Site: when you sign up for access to our website or when you contact us with queries or respond to our communications the personal information you provide may include your full name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.
• In connection with our provision of investment advisory services: if you are a client of Aurora Capital Group you will provide us with personal information when you or the company you represent becomes a client, including in subscription or transfer agreements, investor questionnaires and other relevant forms. If you are not a client we may collect or receive your personal information because you are involved in one of our client’s matters.
• Recruitment application: when you apply for a role with us you may provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, home address and home telephone number, mobile telephone number and other details set out in your application.

Information we otherwise collect about you

We will also collect information about when you use our services or when we otherwise interact or correspond with you. We use various technologies to collect and store information when you visit our website. We may, for example, collect information about the type of device you use to access the website, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites and other interactions with our website or use of certain online tools, the web pages and the search terms you enter on our websites. For information about how we use Cookies and the choices you may have, please see our Cookies Policy.

Information we obtain indirectly from other sources

• If you apply for a position with us we may collect personal information relating to past employment, qualifications and education, opinions from third parties about you, past employment history and other details about you, which will be provided to us by a third party that provides background screening services to us.
• If we collect or receive your personal information in the context of our provision of investment advisory services we might receive information from third parties relevant to the services we are providing (e.g. counterparties in transactions), your representatives (including financial advisors, investment consultants, brokers or other financial institutions), public websites and other public sources, through know-your-client procedures including anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed person checks and sanctions checks,  and others such as regulators and authorities. That information could include your name, contact details and other information relevant to the investment advisory services that we are providing to our client.

In addition to the categories of personal information above, through the various sources mentioned above, we may collect the following personal information:

• Identifiers such as further contact information, nationalities, date of birth, passport number, driver’s license number or other identification documentation, social security numbers, tax identification number or other unique identifier numbers, gender, signature, employment-related or professional information (including occupation and investment experience), sources of wealth, asset, income and other financial and investment information.
• Commercial information, including investments considered, records of products or services purchased, obtained or considered, or other purchasing histories or tendencies.
• Audio, electronic, visual, or similar information.

How we protect your information

We do not disclose any non-public personal information about you to anyone, except as permitted or required by law and regulation.

We seek to carefully safeguard your private information and, to that end, restrict access to non-public personal information about you and only our employees and service providers that have a “need to know” your information to perform their jobs, such as to conduct our business, and who have agreed to the proper handling of such information and who have agreed to keep the information confidential are authorized to have access to your personal information.  It may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them.  We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information.  In addition, we will continue to assess new technology for protecting information with regard to our investors.

How we use the information we collect

We may do the following with your personal information:

1. use it to provide investment advisory services to the relevant client
2. use it to engage in marketing and business development activity in relation to our investment advisory services. This may include sending you newsletters, marketing communications and other information that may be of interest to you
3. assess and process applications for an investment in a fund and other dealings regarding fund investments, including performing know-your-client procedures, issuing and redeeming/withdrawing shares or interests in a fund, receiving payments from and making payments to investors, calculating net asset value, and overseeing these processes
4. use it for general business administration, including communicating with investors, communicating with service providers and counterparties, keeping records, accountancy and audit services, risk monitoring, the administration of IT systems and monitoring and improving products, assessing creditworthiness, otherwise in furtherance of any contract entered into with respect to the activities of any fund, and any other processing necessary for the purposes of us carrying out our activities
5. where you have applied for a position with us, to review and process your job application, including any related background checks
6. to comply with legal and regulatory obligations that we have to discharge
7. use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings
8. record and monitor your use of our website for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports
9. use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our website and our business, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes
10. use it to look into any complaints or queries you may have
11. ensure the security of information systems, and
12. use it to prevent and respond to actual or potential fraud or illegal activities.

Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.

Grounds for using your personal information

We rely on the following legal grounds to process your personal information, namely:

• Consent - we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
• Performance of a contract - we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
• Legitimate interest - we may use your personal information for our legitimate interests (or those of a third party), some examples of which are given above, and where we consider that your interests and fundamental rights do not override our legitimate interests.
• Compliance with law or regulation - we may use your personal information as necessary to comply with applicable laws/regulations.

Failure to provide your personal information may affect our ability to provide services to you.

How we share information with third parties

We share personal information among our US and international offices and the various companies and entities that make up our international network. We may share your information (as described above) with our affiliates as permitted by applicable law, such as to provide you with services that you have requested.  Our affiliates are entities controlled or owned by us, or entities that control us or are under common control with us. As a result, your personal information may be transferred between locations in the US, the UK, the  European Union and other relevant jurisdictions for the purposes described above.

We may also share your personal information outside the Firm with nonaffiliated service providers and financial institutions only if they agree to protect the confidentiality of your non-public personal information and to use the information only for purposes for which it is disclosed to them. This sharing may include:

• Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers, and investor portal administrators.
• Third parties relevant to the investment advisory services that we provide. This may include, but is not limited to, attorneys, accountants, auditors, brokers, bankers and other professional service providers, regulators, authorities and governmental institutions.
• To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
• Third parties in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Where we transfer your personal information as noted above, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information.

Please see below for more details of the protection given to your personal information when it is transferred outside the UK and the European Union.

How long we keep your information and security of your information

How long we hold your personal information for will vary and will depend principally on:

• The type of personal information and the purpose for which we are using your personal information - we will need to keep the information for as long as is necessary for the relevant purpose, and
• legal obligations - laws or regulation may set a minimum period for which we have to keep your personal information.

In general, we will retain your personal information for as long as we require it to perform our contractual rights and obligations or for periods required by our legal and regulatory obligations.  We seek to maintain appropriate physical, electronic and procedural safeguards designed to protect your personal information. Given the nature of information security, there is no guarantee that such security measures and safeguards will always be successful.

Your rights regarding your personal information

Depending on where you are located, you may have a number of legal rights in relation to the personal information that we hold about you under certain laws such as the GDPR. You can exercise your rights by contacting us using the details set out below.

These rights include:

• Opting out of email communications. We may send communications about our services and events to you. You can opt out of these communications by contacting us using the details in contact details below.
• Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed other than to our client and as authorised by our client.
• Requesting that we correct your personal information if it is inaccurate or incomplete.
• Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
• Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
• In some circumstances, receiving some personal information in a structured, commonly used and machine- readable format and/or requesting that we transmit those information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
• Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
• Making a complaint to us, or lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
• We can, on request, tell you which data protection authority is relevant to the processing of your personal information. 

How to exercise your rights or make complaints under the GDPR

If you wish to exercise any of the above rights as an EEA or UK data subject or to make a complaint to us, please contact us at the details set out below and include “GDPR Rights Request” as the subject of your communication.

Transfers of personal information outside the EU or the UK

Our activities and the jurisdictions in which we are established are such that it may be necessary for personal information that we obtain from you to be transferred and/or processed outside of the EEA or the UK, chiefly but not limited to the United States and the Cayman Islands. Personal information may be accessible by employees and other persons working on our behalf, located outside of the EEA or the UK, including by certain service providers (including but not limited to technical service providers and electronic data storage providers) who may process the information you give us. In circumstances where we transfer personal information outside the EEA or the UK, we will seek to ensure a similar degree of protection is afforded to it by ensuring that, where possible, personal information is generally transferred only to persons in countries outside the EEA or the UK in one of the following circumstances:

• to persons and undertakings in countries that have been deemed to provide an adequate level of protection for personal information by the European Commission or the equivalent entity in the UK;
• to persons and undertakings to whom the transfer of such personal information is made pursuant to a contract that is compliant with the model contracts for the transfer of personal information to third countries from time to time approved by the European Commission (as supplemented where and if required) or the equivalent entity in the UK;
• to persons and undertakings outside of the EEA or the UK pursuant to other appropriate safeguards for the transfer of personal information;
• to persons and undertakings based in the United States if they are part of the EU-U.S. Data Privacy Framework which requires them to provide similar protection to personal information shared between the EEA and the United States, as well as personal information shared between the UK and the United States pursuant to the Data Protection (Adequacy) (United States of America) Regulations 2023 for the UK Extension to the EU-U.S. Data Privacy Framework (the UK-US Data Bridge); and/or
• as otherwise permitted by applicable law, including for example where there is consent for the transfer.

You can contact us through the information provided in the contact information section below for further information on specific mechanisms we utilize for transferring personal information outside the EEA or the UK and the countries to which such transfer may be made (which may include, but are not limited to, the United States and Cayman Islands).

Additional information for investors in our Cayman Islands funds

• Where investors hold interests in funds established in the Cayman Islands (each a “Cayman Fund”), those funds are subject to the Data Protection Law (as amended) of the Cayman Islands (the “DPL”). For the purposes of this Client Privacy Notice, “we” or “us” includes each relevant Cayman Islands fund as a data controller (for the purposes of the DPL).
• The DPL grants individual investors certain rights in respect of personal information provided to the funds, including the right to access their personal information. In respect of institutional investors that provide us with personal information on individuals connected to the investor for any reason in relation to its investment in the Cayman Fund, the DPL may be relevant for those individuals too.
• Each Cayman Fund collects and maintains information for purposes connected with its business, including (without limitation) permitting the relevant Cayman Fund to make required updates to its registers, books and records in respect of an investor’s subscription; facilitating the Cayman Fund’s communications with investors regarding the Cayman Fund and their investment; facilitating the Cayman Fund’s compliance with applicable legal or regulatory obligations (including undertaking investor due diligence including anti-money laundering and counter-terrorist financing checks, including verifying the identity and addresses of investors (and, where applicable, their beneficial owners)); and complying with a legal, tax, accounting or regulatory obligation to which the Cayman Funds or the third party are subject.
• Due to the international nature of the Cayman Funds’ business and the service providers to the funds, your personal data may be transferred to jurisdictions that do not offer equivalent protection of personal data as under the DPL. In such cases, the Cayman Funds will process personal information or procure that it be processed in accordance with the requirements of the DPL, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal information on the Cayman Funds’ behalf.

Additional information for California residents

The California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time, “CCPA”) imposes certain obligations on Aurora Capital Group, or Aurora Asset Management, Inc., and its affiliates (together, “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information, our Notice at Collection, and a description of your potential rights under the CCPA. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.

Terms used herein have the meaning ascribed to them in the CCPA. Aurora Capital Group, or Aurora Asset Management, Inc., and its affiliates (together, “we” or “us”) is a “business.” “Personal information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or a household.

Notice at Collection and Use of Personal Information

Personal Information We Collect and Personal Information We Have Disclosed for a Business Purpose

In the preceding 12 months, we may have collected the following categories of personal information from or about you. We may collect all or just a few of these categories with regard to a particular California Resident. Also, in the preceding 12 months, we may have disclosed for a business purpose personal information about you to our service providers or other entities that have agreed to limitations on use of your personal information. We may disclose all or just a few of these categories with regard to a particular California Resident:

• Identifiers such as, your name, address, date of birth, email address, social security number, driver’s license number, passport number, or other similar identifiers.
• Personal information protected under California Civil Code Section 1798.80(e), including, for example, your signature or bank account or other financial information.
• Characteristics of protected classifications under California or federal law, including, your sex or gender, national origin, or marital status.
• Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies. For example, funds invested in the prior year, investments considered, or sources of wealth.
• Internet or other electronic network activity information, including, for example, information regarding your interaction with our website or use of certain online tools.
• Audio (e.g., voicemail), electronic, visual or similar information.
• Professional or employment-related information, including your current or former employer or your current professional title.
• Inferences drawn from any of the information identified above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. For example, information on your potential interest in investing in new funds based on various information.
• Sensitive personal information under the CCPA such as your social security number, passport number, driver’s license, citizenship and immigration status or state identification card.

Personal information under the CCPA does not include deidentified information, aggregate consumer information or publicly available information that is lawfully made available from government records.

 

Purposes for Collecting and Using Personal Information

In the preceding 12 months, we may have collected your personal information for the following business or commercial purposes. We may collect personal information for all or just a few of these purposes with regard to a particular California Resident.

• Performing services on behalf of the fund, including, for example, maintaining or servicing accounts, providing customer service, processing transactions, processing subscriptions and redemptions, verifying information, assessing creditworthiness, processing payments, or providing similar services on behalf of the fund.
• Performing our contractual obligations to a California Resident as a subscriber to the fund, including, processing initial subscriptions and providing updates on the fund’s performance, providing tax reporting and other operational matters.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, including, preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks.
• Enabling or effecting commercial transactions, including, using your bank account details to remit funds and process distributions.

How Long We Keep Your Personal Information

We retain your personal information as described in the “How Long We Keep Your Information and Security of your Information” paragraph in the “Data Protection Privacy Policy” above.

Sale or Sharing of Personal Information

We do not sell or share your personal information (as such terms are defined under the CCPA).

For more information about our privacy practices, please review our “Data Protection Privacy Policy” at the top of this document, and our entire “California Privacy Policy.”

Our Collection, Use and Disclosure of Personal Information and Sensitive Personal Information

Information We Have Collected and Our Purpose for Collecting It

In the preceding 12 months, and depending on how you interact with us, we may have collected the categories of personal information listed above in “Personal Information We Collect.” We may have collected all or a few of these categories of personal information for the business or commercial purposes identified in “Purposes for Collecting and Using Personal Information.”

Sources of Personal Information

In the preceding 12 months, we may have collected personal information about you from the following categories of sources. We may collect personal information from all or just a few of these categories of sources with regard to a particular California Resident.

• Directly from you or your representatives, including (i) through forms or related documentation you complete when subscribing for shares or interests, (ii) in written, electronic, or verbal correspondence and conversations, (iii) through transactions with regard to funds, and when you provide remittance instructions, (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or (v) from information captured on applicable websites.
• From our service providers such as our fund administrator.
• From law enforcement.
• From government records and other publicly accessible directories and sources, including, bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities.
• From credit reporting agencies, sanctions screening databases, and fraud prevention and detection agencies and organizations.

Disclosure of Personal Information

We do not sell or share your personal information (as those terms are defined under the CCPA). We do not knowingly sell or share the personal information of California residents under 16 years old. In the preceding 12 months, we may have disclosed the categories of personal information identified in the “Personal Information We Collect” paragraph with the following categories of third parties. We may disclose personal information with none, all, or just a few of these third parties with regard to a particular California Resident:

• Counterparties and intermediaries (e.g., broker-dealers) in connection with investments and transactions or for operational purposes.
• Third parties as needed to complete a transaction, including financial institutions or advisors, entities that assist with fraud prevention, custodians or lenders to or creditors of a fund.
• Social network or recruiting agencies.
• Fund administrators.
• Professional services organizations such as legal counsel.
• Client relationship management software providers.
• Law enforcement.
• Regulators and other government agencies as required or permitted by law.
• Individuals, entities, or regulatory bodies in connection with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons.
• Individuals, entities, or regulatory bodies to exercise or defend legal claims on behalf of you.
• Individuals, entities, or regulatory bodies at your direction or with your consent.
• Other individuals, entities, or regulatory bodies as otherwise required or permitted by law.

In the preceding 12 months, we may disclose all or just a few of the categories of personal information identified in the paragraph labelled “Personal Information We Collect” to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us or our affiliates or opposing counsel and parties to litigation; (ii) any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets; and (iii) other third parties as may otherwise be permitted by law. We may also disclose for a business purpose such personal information upon reasonable request by the fund in which you have invested or at your request or direction or with your consent. In addition, we may disclose personal information to the third parties listed above to comply with our legal obligations or for the purposes identified above in “Purposes for Collecting and Using Personal Information” paragraph.

We may also disclose your personal information to our service providers, including our money laundering reporting officer, IT providers, archiving service providers, auditor, email providers, professional services organizations or other entities with which we have contracted to provide support and services and that have agreed to limitations on the use of your personal information for a business purpose or that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.

Use and Disclosure of Sensitive Personal Information

As noted above in “Personal Information We Collect”, under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.

California Residents’ Rights Under the CCPA

If your personal information is subject to the CCPA, you may have certain rights concerning your personal information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“request to delete”); (iv) opt-out of the “sale” (as the term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); (v) opt-out of the “sharing”  (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (vi) limit the use and disclosure of sensitive personal information where required by the CCPA (“right to limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit); (vii) correct inaccurate personal information (“request to correct”); and (viii) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“request to know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting or selling the personal information; (d) the categories of third parties to whom we disclosed personal information about your for a business purpose; and (e) the specific pieces of personal information we have collected about you;.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you where permitted by the CCPA or another law or regulation.

How to Submit a Request Under the CCPA

You may submit requests to know, request to correct, or request to delete (“Consumer Rights Requests”), as described above, through our website at the following link www.auroracapiitalgroup.com. You may submit requests to delete through by emailing us at support@auroraasset.com.

We are only required to respond to verifiable Consumer Rights Requests made by you or your legally authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request.  Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name, email address, account login credentials or other account information, answers to security questions, name, government identification number, date of birth, contact information, or other personal information. Any information gathered as part of the verification process will be used for verification purposes only.

You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the provided methods. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf.  We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

Changes to this Privacy Policy

We may update this privacy policy from time to time and to reflect changes in our personal information practices. We encourage you to review the most current privacy policy provided to you.

Contact for More Information

If you have any questions or concerns about this California privacy notice please email us at support@auroraasset.com.

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How to contact us and other important information

If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at:

Data Protection Liaison- support@auroraasset.com