It is Abraham Trading LP’s policy to maintain the confidential information of investor information. Abraham Trading LP maintains physical (e.g. locked file cabinets), electronic (e.g. logins and passwords), and procedural (e.g. employee training) safeguards over investor information. In addition, the building is locked before 8:00 AM and after 5:00 pm. Anyone attempting to access the inside of the building before or after these normal business hours will need key access or be admitted by someone in the building.
ATC is the “data controller” as defined under European data privacy laws including, but not limited to, the General Data Protection Regulation 2016/679 (“GDPR”). For the purposes of this notice, the GDPR together with other applicable European data privacy laws are referred to as the “Privacy Laws”. This notice describes the basis on which we process your personal information (defined as “personal data” under the Privacy Laws), for what purposes, and your privacy rights under the Privacy Laws.
In the event Abraham Trading LP’s policies change with respect to financial privacy requirements, participants will be informed of the change within a reasonable time.
Abraham Trading LP is committed to safeguarding the personal information that you provide us. This Privacy Statement describes how we handle and protect personal information we collect about individuals, such as you, who apply for or receive our products and services. The provisions of this notice apply to former pool participants as well as our current pool participants.
Why and How We Collect Personal Information
When you subscribe for an interest in one of Abraham Trading LP’s pools, we collect personal information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing investor service.
When you visit our website we may track the amount of time you spend on our site, the parts of our site you visited, and other technical information. We use this information to improve the functionality of our website. Your personal information is collected and maintained by us so we may develop, offer, and deliver products and services to you, process transactions in your account, and fulfil our legal and regulatory requirements. You may also submit personal information directly through our website. The personal information we collect about you includes:
- information you provide to us on applications and other forms, such as your name, address, date of birth, social security number, occupation, assets, and income;
- information about your transactions with us;
- information we may receive from consumer reporting agencies, such as your credit history and creditworthiness, and other entities not affiliated with Abraham Trading LP; and
- information you may be requested to provide to us to verify your identity, such as a passport, or information received from other entities not affiliated with Abraham Trading LP.
- information that is defined in the GDPR as “special categories of personal data including health, disability and religious or ethnicity information” may be requested for purposes required by you such as scheduling meetings or visiting our offices in Texas or Colorado.
How We Protect Personal Information
We limit access to your personal information to those employees who need to know in order to conduct our business, service your account, and help you accomplish your financial objectives. Our employees are required to maintain and protect the confidentiality of your personal information and our employees are instructed as to best practice methodologies for processing and maintaining confidential investor information.
We may share your personal information with our affiliates and funds that we manage for any of the purposes described above. These recipients are not permitted to share your information with other entities, except as described herein or otherwise permitted by the Privacy Laws or other applicable laws. The transfer of personal data from the UK/European Economic Area (“EEA”) to recipients outside the EEA is governed by data transfer agreements, which are in the form of the standard contractual clauses approved by the European Commission. Those clauses are available at the following links:
We maintain physical, electronic, and procedural safeguards to protect your personal information.
We do not rent or sell your name or personal information to anyone. However, Abraham Trading LP reserves the right to disclose personal information when it is necessary to fulfill Abraham Trading LP’s regulatory requirements, protect Abraham Trading LP’s intellectual or physical property, collect or report debts owed to Abraham Trading LP, or exercise any right of law on behalf of Abraham Trading LP.
Disclosure to Non-Affiliated Third Parties
In order to support the financial products and services we provide to you, we may share the personal information described above with third-parties not affiliated with us, including:
- Companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing and marketing services.
- Compliance, accounting, and legal firms that assist Abraham Trading LP in complying with regulatory requirements.
These companies acting on our behalf are required to keep your personal information confidential. Abraham Trading LP obtains assurance that the companies maintain privacy statements of their own. These companies may have access to your personal information but are permitted to use the information solely to provide the specific service or as otherwise permitted by law. Where your personal information is processed by third parties outside the EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law, including when possible the execution of standard contractual clauses (referred to above) if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission) or certified under the EU-US Privacy Shield framework.
- Companies and regulatory authorities as permitted or required by applicable law. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property.
We retain your personal information for a period of at least five years from the date on which the relevant business relationship, for which purpose such personal data was provided, has ended (or, if later, the date on which the last transaction was completed or the last entry to the record was made).