PRIVACY
POLICY

At Copernicus Capital Management, LLC (“Copernicus“), your privacy is very important to us. Below are (1) our Website Privacy Policy, which explains Copernicus’ practices pertaining to the collection of information on our public website, and (2) our general Privacy Policy, which explains how we safeguard the confidential information provided to us by our current, prospective and former clients and investors.

These policies are effective as of July 2016. We may make changes to these policies in the future.

COPERNICUS CAPITAL MANAGEMENT, LLC WEBSITE PRIVACY POLICY

What Information We Collect

This policy applies to information collected from, or which may be submitted to, the Copernicus website. Currently, we do not collect any personally identifiable information about visitors to the publicly available areas of our website, including any visitors’ names, addresses, phone numbers, social security numbers or email addresses. At times, visitors to our website may choose to email Copernicus using the contact link available on our website; in such instances, a visitor’s email address may be collected as part of the process of sending the email to us in order to enable us to reply to those emails.

Our website may use “cookies” technology, through which small amounts of data are sent to your computer from our web server and stored on your computer’s hard drive. This data anonymously identifies you as a unique user when visiting our website, and helps us in the ongoing maintenance of our website. This technology does not provide us with any information about your name, address phone number or email address, or any other personally identifiable information.

How We Use Information We May Collect

We do not share any information collected from the publicly available areas of our website with any parties outside of our company. Copernicus reserves the right to disclose any such information we do collect when required by a valid subpoena or court order, or as otherwise permitted or required by law. In the event that a visitor submits his or her email address or any other personally identifiable information to us through our website while requesting information or sending an email to someone at Copernicus, other than as described above, we do not use such information for any other purpose, and will not disclose such information to any outside party.

Other Third Party Websites

Our website may contain links to websites controlled and maintained by third parties. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained in them, or the manner in which any information collected on such sites is used. This Website Privacy Policy does not govern the use of information collected on third party websites.

COPERNICUS CAPITAL MANAGEMENT, LLC PRIVACY POLICY

Copernicus Capital Management, LLC (“Copernicus”) may collect nonpublic information to process and administer our fund’s and its investors’ business (together “our Clients”) and to ensure that we are satisfying their financial needs. This may include:

  • Information provided to Copernicus, such as on applications, questionnaires, contracts, or other forms;

  • Transactions, account balances, account history, and transactions with us, affiliates or third parties; and

  • Information provided by our fund’s investors and their representatives.

  • Information from visits to our website such as site visitorship data, and online data collection devices known as “cookies.”

Sharing of nonpublic information:

Copernicus does not share nonpublic information about its customers with anyone except:

  • As permitted or required by law including

    • in connection with anti-money laundering and similar matters,

    • if we believe it is required to do so by applicable law, rule, regulation, subpoena or court order, or

    • if we believe it is in the best interests of our clients in light of applicable laws, rules and regulations;

  • Affiliated Copernicus companies and their employees and other relevant third parties including but not limited to brokers, banks, and their agents who need to know this information in order to perform services on our Clients’ behalf;

  • Other financial institutions with whom we have a relationship, which may include banks, attorneys, trustees, third-party administrators, registered broker/dealers, auditors, regulators, and transfer agents, in order to service our Client accounts.

Copernicus reserves the right to change this privacy notice, and to apply changes to information previously collected, as permitted by law. Copernicus will inform investors of any changes as required by law.