Privacy Policy

Investor Data Privacy Notice

Last updated: October 1st, 2024

Why are you seeing this notice?

You may be required to provide Personal Data as part of your investment into a fund or investment vehicle managed or advised by Creekstone Holdings or its affiliates (collectively, "Creekstone"). This notice explains how we use, store, and process your Personal Data under applicable data protection laws. You may have specific rights regarding your Personal Data as described in this notice.

“Personal Data” refers to any information that relates to an identified or identifiable individual, such as name, address, date of birth, identification numbers, or financial details. We request investors to provide this notice to any individuals whose Personal Data they provide to Creekstone.

Who is providing this notice?

Creekstone Holdings is a global financial services firm. This notice applies to Creekstone and any relevant affiliates or entities that manage or advise the fund in which you invest and act as “data controllers” determining how your Personal Data is used. Please refer to your subscription documents or offering materials for more specific details on the relevant entities.

What personal data do we collect about you?

The types of Personal Data we may collect include:

Contact information (e.g., name, email, phone number, postal address)
Demographic data (e.g., date of birth, nationality, gender)
Government-issued IDs (e.g., Social Security number, passport number, tax identification numbers)
Professional and employment-related details (e.g., employer, position)
Financial information (e.g., transaction history, bank account details, investment history)
Investment preferences and background check data (e.g., KYC, AML checks)
Monitoring data (e.g., telephone recordings, video calls, CCTV)

Where do we obtain your personal data?

We collect your Personal Data from several sources, including:

From you directly: via forms, emails, phone conversations, transactions, and your interactions on our website or online platforms.
From third parties: such as public records, government authorities, credit agencies, and transaction counterparties.

Why do we process your personal data?

We process your data for the following purposes:

Contractual obligations: Managing your investment, setting up accounts, and administering transactions.
Compliance with laws: Including KYC, AML, and tax reporting.
Legitimate business interests: Managing investments, assessing applications, maintaining investor relationships, and ensuring security.

Who we share your personal data with

We may share your Personal Data with:

Affiliates and related entities: For managing our relationship with you.
Fund managers, custodians, and administrators: For providing investment services.
Tax authorities: To comply with legal obligations.
Service providers: For business operations such as IT and cloud services.
Legal and professional advisors: For legal, regulatory, or audit purposes.

International transfers of personal data

We may transfer your Personal Data to countries outside your jurisdiction, including to countries that may not have the same level of data protection laws. In these cases, we ensure appropriate safeguards are in place, such as data transfer agreements.

Retention and deletion of your personal data

We retain your Personal Data only for as long as necessary for business purposes or legal obligations. Generally, we retain your data for the duration of your investment and for a reasonable period afterward in compliance with legal requirements.

Your rights

You may have rights under applicable data protection laws, including:
The right to access, correct, or delete your data.
The right to restrict processing or transfer your data.
The right to object to data processing in certain cases.
To exercise your rights, please contact us using the details provided below.

Monitoring

We monitor communications where required by law, including surveillance for legal and compliance purposes.

If you have any questions about this Data Privacy Notice or the Personal Data we hold about you, please contact us at: Creekstoneholdings@gmail.com

Changes to this data privacy notice

We regularly review this notice and may update it.