Privacy Policy

Prima Capital Advisors LLC (and its subsidiary Prima Europe LTD collectively "Prima") is committed to complying with the applicable data privacy and security requirements in the countries in which it operates. Prima complies with internationally recognized standards of privacy protection, and with various privacy laws globally including, but not limited to, the EU General Data Protection Regulation (GDPR). This Privacy Notice applies when Prima provides investment advice (the "Services") to its clients or to investors in one of its proprietary funds.

Who is Collecting Data

Data will be collected by Prima.

Data We Collect

Prima collects the following categories of personal data:

Contact data: We may collect information about data subjects such as name and contact details (email, phone number, etc.) in order to communicate and facilitate the provision of our services with our clients or potential clients. For example, contact details of individuals who work for or on behalf of the clients will be collected in order to carry out the client’s engagement with Prima.

Professional or employment-related information (e.g. job history, performance evaluations)

Sensitive/protected characteristic information (e.g., age, race, citizenship, gender)

Services data: Personal data may be provided to us by clients to the extent required to perform the Services. Prima may also acquire personal data from a third party at the direction of our client as required to perform services.

Marketing information: We may collect information to respond to inquiries regarding our Services or to provide you with information, reports, or updates.

Website visitor information: when you visit our website, we may collect information about your visit such as your IP address and the pages you visited and when you use our services we may collect information on how you use those services. Please see our Terms of Use for additional information.

Clients and other Third parties who provide personal information to Prima must do so in compliance with applicable data privacy regulations.

Processing of Personal Data

We collect personal data to offer and administer our Services.

The data you provide to us will be processed in accordance with the purposes specified in this notice, namely: To perform the services requested by clients and individuals pursuant to an investment management agreement or subscription agreement (where the processing is necessary for our legitimate business interests in conducting and managing our business) For complying with obligations provided by laws, current regulations and European legislation (e.g. tax regulations) (where processing is based on a legal obligation)

For legitimate business purposes to advise you through e-mail, phone call, video conference or post, in the framework of our ordinary commercial relationship (where the processing is necessary for our legitimate business interests) For marketing purposes. For example, we may use your information to further discuss your interest in the Services and to send you information regarding Prima. If you are located in the EU, we will only send you marketing communications and updates about our services with your prior consent. You can withdraw your consent at any time. If you are not located in the EU, you may opt-out of receiving marketing communications and updates at any time.

For improving Prima’s communications with you. Emails sent to you by Prima may include standard tracking, including open and click activities. Prima may collect information about your activity as you interact with our email messages and related content.

For operating and improving Prima’s website. For example, we may collect and analyze data on your use of our website and process it for the purpose of improving our online experience. Please see our Terms of Use for additional information.

For security purposes. For example, we may use your data to protect Prima and its third parties against security breaches and to prevent fraud and violation of Prima’s applicable agreements (where the processing is necessary for our legitimate business interests).

Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You have the right to object to this processing if you wish.

How data is processed

Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorized Prima employees and third-party processors to have access to your information. Such employees and third-party processors are appropriately designated and trained to process data only according to the instructions we provide them. Storage of Personal Data

We intend to keep your Personal Data accurate and up-to-date. We will delete the information that we hold about you when we no longer need it. We retain your Personal Data for as long as it is required by us for our legitimate purposes, to perform our contractual obligations, or where longer, such longer period as is required or permitted by law or regulatory obligations which apply to us.

We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.

Note that we may retain some limited information about you (even when we know that you have left the organization that you represent) so that we can maintain a continuous relationship with you if and when we are in contact with you again.

We maintain administrative, technical and physical safeguards designed to protect personal data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Disclosure/Sharing of Personal Data

We only share your personal data with your consent or in accordance with this policy. We will not otherwise share or distribute any of the information you provide to us except as described in this Privacy Notice, and we will never sell it.

We share personal data among Prima-controlled affiliates and subsidiaries who act for Prima for the purposes set out in this notice. Prima may share your information with external third parties, such as vendors, consultants and other service providers who are performing certain services on behalf of Prima. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable service contract, and not for any other purpose. Prima requires these third parties to undertake security measures consistent with the protections specified in this notice.

Prima may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

Your Rights

Depending on the laws of the jurisdiction governing the processing of your personal data, you may have certain rights under applicable data protection laws including:

Access: You have the right to access personal information that Prima holds about you.

Rectification: You have the right to ask us to rectify information Prima holds about you if it is inaccurate or not complete.

Erasure: You can request that Prima erase your personal data. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

Restrict Processing: You have the right to ask Prima to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.

Object to processing: Where processing is based on legitimate interests, you have the right to object to PRIMA processing your data. PRIMA will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

Portability: Where processing is based on consent or performance of a contract, you have the right to data portability. PRIMA must allow you to obtain and reuse your personal data for your own purposes in a safe and secure way without this affecting the usability of your data. This right only applies to personal data that you have provided to PRIMA as the Data Controller.

Please contact deyl@primaadvisors.com to request access, rectification, or erasure, or to restrict processing, to object to processing, or to request data portability.

Subject to legal considerations or certain exemptions, we may not always be able to address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Please contact us by email to ensure your request is received in a timely manner.

Automated Decision Making

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

Prima does not make automated decisions using personal data.

Contact Us

Please contact us at Prima with questions, concerns, or complaints:

Requests received via post may be delayed due to limited office access during the Covid-19 pandemic. Please contact us by email to ensure your request is received in a timely manner.

Prima Capital Advisors LLC
2 Overhill Road Ste. 215
Scarsdale, NY 10583

For data subjects located in the EU: if we are not able to satisfactorily resolve your questions, concerns, or complaints, or if you believe that the processing of your personal data infringes on your rights under applicable data protection laws, you have the right, without prejudice to any other administrative or judicial remedies, to lodge a complaint with a supervisory authority, in particular, in the Member State of your habitual residence, place of work or place of the alleged infringement. Contact information for the supervisory authorities may be found here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm