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 we evaluate subscriptions for investment in the Fund, manage and operate the Fund, process transactions relative to investments in the Fund, or provide other services to prospective, current and former investors in the Fund, typically we are provided with certain necessary personal information.
We treat this information about prospective, current, and former investors in the Fund in a confidential manner. We access information and provide it to third parties only when providing services to you or the Fund, or where required, necessary, or permitted, in order to comply with state or federal law. We may disclose information under such circumstances to attorneys, accountants, securities professionals (including governmental agencies) and others. We may also share information with affiliates in order to offer or provide you with products or services. (Notwithstanding the foregoing, we may use the names of investors for marketing purposes in the manner provided for in the Abraham Fortress Fund’s Limited Partnership Agreement.)
We do not sell information concerning prospective, current, and former investors to anyone.
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 fulfill 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, telephone number, marital status, age, date of birth, social security number, taxpayer identification number, assets, net worth, income, account balance, investment activity and experience, education and employment history, driver's license and tax return filing, and ownership and management information (for entities, trusts, and estates);
- Information about your transactions with us;
- 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 it 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 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).
Access to and Correction of Information
Generally, upon your written request, we will make information about you available for your review. Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available. If personal information we maintain becomes inaccurate, or if you need to make a change to that information, please contact Abraham Trading Company at (806) 323-8000 so we can update our records.