May 2018

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Financial companies choose how they share your personal information. Federal law gives our clients the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

We do not disclose non-public personal information about our clients or former clients to third parties other than as described below.

Personal information we collect

We collect personal information about you in connection with our providing advisory services to you. This information includes your social security number and may include other information such as your:

  • Assets;
  • Investment experience;
  • Transaction history;
  • Income; and
  • Wire transfer instructions
  • Website cookies, beacons, history and logs

How we collect this information

We collect this information from you through various means. For example when you give us your contact information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates or other non-affiliated companies.

Statistical Information About Your Visit to our Website

When you visit the Argentiere Website, our systems collect personal information and statistical or non-personally identifiable information about your visit to our sites (e. g., IP address, pages visited, origin of visitor domains, and types of browsers used). However, unless you actively submit personal information, we do not typically identify you via the non-personally identifiable information. Notwithstanding the foregoing, to the extent permitted by applicable law, we reserve the right to combine non-personal information with personal information that you have actively submitted.

Use of Cookies

Argentiere and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base. A “cookie” is a piece of information that the Argentiere Website sends to your browser. Your browser stores the cookie on your system. The cookie will allow Argentiere to remember information about you and your preferences until either you exit your current browser window (if the cookie is temporary) or you disable or delete the cookie. Many users prefer to use cookies to help them navigate a website as seamlessly as possible. If you do not want Argentiere to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. Rejecting cookies may affect your ability to use some of our services on the Website.

Argentiere does not display or provide advertising facilities to third parties. The only third-party cookies used are for statistical and marketing purposes and provided by Google Analytics.

Web Beacons

Argentiere uses web beacons alone or in conjunction with cookies to compile information about site visitors’ usage of the site and interaction with emails from Argentiere. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a website tied to the web beacon, and a description of a website tied to the web beacon. For example, Argentiere may place web beacons in marketing emails that collect information when you click on a link in the email that directs you to Argentiere’s websites. We use web beacons to operate and improve Argentiere’s site and email communications. Argentiere may use information from web beacons in combination with personal data to provide you with information about Argentiere its funds and business.

Your Ability to Opt-Out of Further Notifications

From time to time, we may send emails providing information on fund performance, events, research and publications unless you have opted out. If you would like to opt-out of being notified, please contact us at the address given at the end of this Privacy Statement.

Please be aware that current investors and clients may not opt out of receiving information regarding fund performance and account management of any holding or position within the fund.

How we use this information

All financial companies need to share customers’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example:

  • To provide advisory services to you;
  • To open an account for you;
  • To process a transaction for your account;
  • To market products and services to you;
  • To respond to court orders and legal investigations

Disclosure to others.

We may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker or fund administrator. We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with nonaffiliates for them to market to you).

How we protect your personal information.

To protect your personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include computer safeguards and secured files and buildings.

Who is providing this Privacy Policy Notice:

This Privacy Policy Notice relates to the following entities:



Argentiere complies with the Regulation 2016/679, the “General Data Protection Regulation” (“GDPR”) of the European Parliament and of the Council on the protection of natural persons regarding the processing of personal data and on the free movement of such data. The GDPR supersedes EU Data Protection Directive (also known as Directive 95/46/EC).

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Argentiere is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles.

Argentiere complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. Under those provisions and under certain circumstances, Argentiere is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Argentiere may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Scope of this Notice (GDPR)

This Notice addresses data subjects residing in the EEA and Switzerland (“EAA and Swiss Persons”) whose data Argentiere may receive from persons or other businesses in the EEA or Switzerland, e.g., EEA and Swiss residents who are mentioned or referred to in documents to be produced in pre-trial discovery proceedings, etc.

Categories of EEA and Swiss Data

Argentiere collects data largely for businesses and rarely if ever for consumers. Thus, Argentiere solely receives business-related information from the EEA and Switzerland. Occasionally, Argentiere also receives contact information related to individual representatives of businesses with whom Argentiere is dealing (including, without limitation, names, addresses, work phone numbers, work email addresses, etc.), and, in connection with our fund administrator, Argentiere processes data that may be relating to EEA and Swiss residents on behalf of, and in accordance with instructions from, persons or businesses (collectively “EEA and Swiss Data”). Since EEA and Swiss Data covered by this Notice is by definition sent to Argentiere by another company in the EEA or Switzerland (e.g., a supplier to Argentiere), the categories of data sent and the purposes of processing often depend on such other company, with whom the EEA or Swiss Persons typically have a closer employment, business or other relationship (and which therefore, can provide additional information on categories of data shared with us).


Argentiere shares EEA and Swiss Data with affiliates and contractors, which process EEA and Swiss Data on behalf of Argentiere. Argentiere also shares EEA and Swiss Data with other third parties for the purposes for which Argentiere receives the EEA and Swiss Data (e.g., performance of contractual obligations) and as required or permitted by law. With respect to marketing emails, EEA and Swiss Persons may opt-out of receiving further email marketing communications from Argentiere by sending an email to, or by following opt-out instructions that are contained in each marketing email. EEA and Swiss Persons may also send an email to this address to ask to opt-out of disclosures to third parties, but such a limitation on data sharing may make it difficult or impossible for Argentiere to provide the requested services. Notwithstanding other statements in this Notice, Argentiere may disclose EEA and Swiss Data where it is legally required to disclose (e.g., under statutes, contracts or otherwise) or the disclosure is permitted by law and Argentiere has a legitimate business interest in such disclosure.

Access and Review

EEA and Swiss Persons whose EEA and Swiss Data Argentiere holds may request access to, and the opportunity to update, correct or delete some or all of the EEA and Swiss Data that Argentiere holds about them. To submit such requests or raise any other questions, please contact Argentiere as described below. Argentiere reserves the right to take appropriate steps to authenticate an applicant’s identity, charge an adequate fee before providing access and deny requests, except as required by applicable law.

Who to contact with questions:

If you have any questions about this Privacy Policy Notice please contact Privacy Administrator at Landis+Gyr Strasse 1, 6300 Zug, Switzerland, telephone: +41 41 560 23 00; or email us at

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