Duty of Confidentiality
At Dara Capital US, Inc. ("Dara"), we are committed to safeguarding your personal information. U.S. federal law requires us to tell you how Dara collects, shares, and protects your personal information. This notice describes
- The types of personal information we may collect about you
- The purpose for which we use the information collected
- The circumstances in which we may share the information collected
- The steps we take to safeguard the information to protect your privacy
Please read this notice carefully to understand how Dara accomplishes the foregoing.
Why and How Dara Collects Personal Information
We collect personal information about you in order to enable us to provide services to you and conduct our everyday business. We collect this information as follows: (i) from applications and other forms that you submit to us; (ii) in conversations you may have with us; (iii) through your transactions with us; or (iv) in correspondence that you send to us. These sources provide us with information including without limitation your name, address, e-mail address, telephone number, date of birth, Social Security number or other tax identification number, occupation, financial goals, assets and income.
How Dara Safeguards Your Personal Information and Protects your Privacy
Dara is committed to protecting the privacy and confidentiality of your personal information. Only those employees, managers, agents or advisers of Dara who have a professional or business reason to have access to personal information to perform their jobs are authorized to use your personal information. They may need access to your personal information in order to conduct business on your behalf, service you, help you pursue your financial objectives, and to conduct Dara's business. Employees who have access to your personal information are required to maintain and protect the confidentiality of that information and follow established procedures, as set forth in Dara's compliance manual. We maintain physical, electronic and procedural safeguards to protect your personal information and to comply with applicable laws, rules and regulations.
Dara will provide clients with notice of changes in our information sharing practices. If, at any time in the future, Dara finds it necessary to disclose any of your personal information in a way that is inconsistent with Dara's policy, we will give you advance notice of the proposed changes so you will have the opportunity to opt out of such disclosure if possible.
Dara will maintain personally identifiable information about you during the time you are a client, and for the required time thereafter that such records are required to be maintained by U.S. federal and state securities laws. After such required period of record retention, all such information may be destroyed.
Why and How Dara Shares Information with Its Affiliates
We may share your personal information as described above with our affiliates as required or permitted by applicable law. Dara's affiliates includes Dara Capital Ltd. and its directors, officers, and employees. Dara Capital Ltd. is subject to Swiss Secrecy Laws.
We may share with our affiliates your name, contact information and information about your transactions with us so that you can be efficiently serviced and we can conduct our everyday business. We will not, however, use your personal information for marketing purposes.
Why and How Dara Shares Information with Nonaffiliated Third Parties
All of your personal information shall be kept confidential by Dara, unless such personal information is generally known or otherwise publicly available. Dara does not and will not rent or sell your personal information. Furthermore, we will not use your personal information for marketing purposes. However, Dara may share your personal information with companies that we hire to perform services for us, such as vendors that provide computer software maintenance and development, and who need access to your personal nonpublic information in order to provide the services for which they have been contracted. Such nonaffiliated third parties are contractually bound to confidentiality before being provided access to your personal information.
Furthermore, Dara may share your personal information if such sharing is required in connection with the performance of the advisory agreement concluded between you and Dara (including to subadvisors or managers), or to the extent Dara may be required to disclose such information pursuant to law or legal process.
In the event that Dara is requested or required by law, regulation, supervisory authority or other applicable judicial or governmental order to disclose any personal information, Dara will, so far as it is lawful (or otherwise not in breach of any regulation, supervisory authority or other applicable judicial or governmental order) and practical to do so prior to such disclosure, promptly notify you of such requirement with a view to providing you with an opportunity to contest such disclosure or otherwise to agree to the timing and content of such disclosure.
Usage of Google Analytics
October 1, 2014