This Privacy Notice (the “Notice”) sets out the basis on which Drumlin Capital Management, LLC (“Drumlin”) uses your personal information. Drumlin is committed to protecting your personal information and respecting your privacy. Drumlin will use your personal information fairly and lawfully. If you are viewing this Notice on www.drumlincapital.com (the “Site”), you accept that your use of the Site indicates your consent to the practices described in this Notice.
1. PERSONAL INFORMATION
Whose personal information is collected?
Drumlin collects and uses information about certain groups of individuals, including:
- Clients and investors (current, prospective and former) and any of their directors, officers, employees, partners, shareholders or agents;
- Suppliers and service providers, professional advisors, and consultants;
- Individuals who contact Drumlin by email or phone and any visitors to the Site; and
- Employees, contractors, etc. (current, prospective and former).
What types of personal information is collected?
Drumlin may collect and use personal information that is:
- Directly provided by you;
- Related to services provided to you by Drumlin;
- Received from your representatives or advisers, and third parties, including administrators of products advised by Drumlin; or
- Collected using cookies and other technologies when visiting the Site.
The Site uses cookies to distinguish you from other users and help ensure that the Site is operating smoothly. A ‘cookie’ is information placed on a user’s computer by a website. While cookies are not considered personal information, they are generally used on the Site to:
- Monitor traffic – we use anonymous information to track how people are using the Site, including time of visit, pages visited, etc.
- You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent (each browser is different, so check your help menu).
- If you disable the use of cookies on your web browser or remove or reject specific cookies from Drumlin website, then all functionality might not be available to you.
Purpose for collecting the personal information:
Drumlin may use the information held about you to:
- Assess your suitability for, and provide you information about, Drumlin’s products or services;
- Process your subscription or investment in Drumlin sponsored investment vehicles;
- Fulfill any contract between you and Drumlin;
- Administer the Site and ensure that the Site is effectively presented for you;
- Respond to any enquiry or complaint raised by you; and
- To meet legal, regulatory, and compliance requirements.
Drumlin may also combine any information that you provide with the information received from other sources. The combined information may be used for the purposes set out above.
Where you give us consent:
- For Drumlin to notify you about Drumlin marketing materials.
- On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
Where you can opt out:
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes.
You can unsubscribe or opt out of Drumlin emails at any time by clicking the unsubscribe link in email correspondence, or by contacting us directly at info@drumlincapital.com
2. THIRD PARTIES
We treat the security and method of processing your personal information very seriously, and we will never sell your personal information. However, Drumlin may share your personal information with any member of the Drumlin group of companies for the purposes set out above.
Drumlin may share your personal information with the selected third parties, including:
- Business partners, suppliers and sub-contractors for the performance of any contract Drumlin enters into with them or you;
- Marketing providers that assist with the delivery of information to you;
- Analytics providers that assist in the improvement of the Site; and
- Administrators and directors of Drumlin sponsored investment vehicles in connection with your subscription or investment in such funds.
Drumlin may also share your personal information with third parties in the following circumstances:
- If Drumlin sells or buys any business or assets, it may be necessary to share your personal information with the prospective seller or buyer;
- If Drumlin is acquired by a third party, the personal information held by Drumlin will be one of the transferred assets; or
- If there is a duty to share your personal information in order to fulfil any applicable legal, regulatory or self-regulatory requirement.
3. SECURITY OF YOUR INFORMATION
Drumlin is committed to protecting information that you provide. Physical, electronic and procedural safeguards are used to protect your information against unauthorized access, disclosure or loss. Authorized access to personal information is limited to only those employees, contractors, and agents with a need to know, and is subject to strict confidentiality obligations.
4. STORAGE OF YOUR INFORMATION
The information that Drumlin collects from you may be transferred to, and stored at, various destinations, and may also be processed by Drumlin or Drumlin’s suppliers for the purposes set out above. By submitting your personal information to Drumlin, you agree to this transfer, storing or processing. Drumlin will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with the Notice.
5. YOUR RIGHTS
You have the right to access information held about you and to request that such information is not used for any particular purpose. You can exercise these rights by writing to:
Drumlin Capital Management, LLC
301 Riverside Avenue
Westport, CT 06880
6. CHANGES TO THIS NOTICE
Any changes Drumlin may make to this Notice will be posted on the Site. Please check back frequently to see any updates or changes to this Notice.
Adopted March 1, 2021
