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Legal and Regulatory Disclosures

WEBSITE TERMS OF USE

Updated July 2022

By accessing or using our website, located at www.tudorfunds.com, (the “Site”), you hereby accept and agree to comply with the following terms and conditions (the “Terms and Conditions”). Your access to or use of the Site constitutes your acceptance of the Terms and Conditions and is a binding agreement between you and Tudor Investment Corporation, Tudor Group Holdings LLC, Tudor Capital Europe LLP, Tudor Capital Australia Pty. Ltd, Tudor Capital Singapore Pte. Ltd. and their affiliates (collectively, “Tudor”, “we”, or “us”). The Terms and Conditions govern your access and use of the Site, which includes any information, data, tools, products, services and other content (together, “Content”) available on or through the Site.

To contact us, please email Ir-operations-team@tudor.com.

These Terms and Conditions may be updated by us at any time. Every time you wish to use the Site, please check these terms to ensure you understand the Terms and Conditions that apply at that time. Your continued use of the Site after any such modifications constitutes your acceptance of the Terms and Conditions as modified. If you do not agree to receive these legal notices and to abide by these Terms and Conditions for any reason you agree that your sole and exclusive remedy is to discontinue accessing and using the Site.

These Terms and Conditions refer to the following additional terms, which also apply to your use of the Site.

Nothing contained in these Terms and Conditions is intended to modify or amend any other written agreement you may have with us that is currently in effect (“Other Agreements”). In the event of any inconsistency between these Terms and Conditions and any Other Agreements, the Other Agreements will govern.

PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THE SITE. EACH TIME YOU USE THE SITE, YOUR USE INDICATES YOUR FULL ACCEPTANCE OF AND AGREEMENT TO ABIDE BY THESE TERMS AND CONDITIONS IN ITS THEN CURRENT FORM, INCLUDING ANY MODIFICATIONS POSTED. IF YOU DO NOT ACCEPT THE TERMS AND CONDITIONS, DO NOT USE THE SITE.

  1. Tudor grants you a limited right to use the Site. Your right to use the Site is subject to your agreement to abide by these Terms and Conditions in their entirety, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of the Site. At any time and for any reason we may revoke your right to use all or any portion of the Site. You agree not to violate or attempt to violate the security of the Site or to use the Site for any illegal purposes.
  2. Intellectual Property. You acknowledge that the Site is protected by one or more copyrights, patents, database rights, trademarks, service marks, trade dress, trade secrets and/or other intellectual property and proprietary rights that are owned by Tudor and/or third parties. All content included on the Site, such as text, graphics, logos, images, articles and other materials, and any combination thereof, are the property of Tudor and/or third parties. The content appearing on the Site includes copyrighted works that are protected under the copyright laws of the U.S. and other countries and under various international treaties. You agree to abide by all applicable copyright and other laws in regard to the Contents of the Site. “TUDOR” and other names and indicia of Tudor and its products and/or services are exclusive trademarks and service marks of Tudor, and are registered in various jurisdictions. Other product and company names appearing on the Site may be trademarks of their respective owners, who may or may not be affiliated with Tudor. Nothing contained on the Site should be construed as granting, by implication, estoppel or otherwise, any license or right to use any content or trademark displayed on the Site without the written permission of Tudor or such other third party that may own the content or trademark displayed on the Site.
  3. Restrictions on Use. You may not: (i) decompose, decompile, reverse engineer, disassemble or otherwise deconstruct all or any portion of the Site; (ii) publish, broadcast, retransmit, reproduce, repackage, frame, commercially exploit, create any derivative of or otherwise redistribute all or any portion of the Site except as explicitly permitted in these Terms and Conditions; or (iii) remove any copyright, trademark or other proprietary notice or legend contained on (or printed from) the Site. Notwithstanding the foregoing, you may: (i) print copies of any accessible portion of the Site only for your own personal use or that of your directors, trustees, employees, representatives, agents, and financial, legal or tax advisors, and others with whom you share investment decisions and who need to know such information (“Representatives”); (ii) disclose information on the Site to Representatives and (iii) if you are a consultant or investment advisor or are otherwise acting as a representative of one or more clients or prospective clients of Tudor, you may disclose information you obtain from the Site to your clients and otherwise utilize or present such information or derivations thereof to your clients in your capacity as such, provided that any person to whom disclosure of any such information is made is advised by you of its confidential nature.
  4. Representations and Warranties. You represent and warrant that: (i) you have full authority and all rights necessary to enter into and fully perform all of your obligations pursuant to these Terms and Conditions; (ii) you have not and you will not enter into any agreement or perform any act which might contravene the purposes and/or effects of these Terms and Conditions; (iii) you will not delete any Content on the Site; (iv) in respect of a US investor, you are, or the company or organization on whose behalf you will be accessing the Site, as applicable, is (a) an “accredited investor” within the meaning of Regulation D promulgated under the U.S. Securities Act of 1933 as amended, (b) either (I) a “qualified purchaser” (as defined in Section 2(a)(51) of the U.S. Investment Company Act of 1940 as amended (the “Investment Company Act”)), or (II) a “knowledgeable employee” (as defined in the regulations under the Investment Company Act) of the Trading Advisor, and (c) a “qualified eligible person” (as defined in the regulations under the U.S. Commodity Exchange Act as amended); (v) in respect of a person accessing the Site in the UK, you are an investment professional or a high net worth company or entity pursuant to the UK Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 and a professional client or eligible counterparty for the purposes of the UK Financial Conduct Authority (“FCA”) Conduct of Business Sourcebook (collectively, an “Exempt Person”); and (vi) you are otherwise eligible to make an investment in the relevant investment vehicle in accordance with the terms of the relevant offering document and applicable law.
  5. Password-Protected Areas. The portions of the Site which are password-protected may be accessed only by users who have been issued passwords by an authorized representative of Tudor. Such passwords will only be issued to current investors in an investment fund sponsored or managed by Tudor, or to certain eligible prospective investors, each of whom acknowledges and agrees that password-protected portions of the Site may contain performance information for the investment funds sponsored or managed by Tudor.
  6. No Offer or Advice. All Content (i) is provided for general, informational purposes only; (ii) does not constitute an offer or solicitation to buy or sell any securities, financial instruments, other services or make or hold any investments; and (iii) may not be used or relied upon in connection with any offer or sale of any such securities, financial instruments, other services or investments. An offer or solicitation will be made only through a final private placement memorandum, subscription agreement and other related documents with respect to a particular investment opportunity, and will be subject to the terms and conditions contained in such documents, including the qualifications necessary to become an investor. Although the Site may include investment-related information, nothing on the Site is a recommendation that you purchase, sell or hold any security or other investment, or that you pursue any investment style or strategy. We do not give any advice or make any representations through the Site as to whether any security or investment is suitable to you or will be profitable. The investments and strategies discussed hereon may not be suitable for all investors, and are not obligations of or guaranteed by Tudor. Nothing on the Site is intended to be, and you should not consider anything on the Site to be, investment, accounting, tax or legal advice. If you would like investment, accounting, tax or legal advice, you should consult with your own financial advisors, accountants or legal advisors regarding your individual circumstances and needs. Decisions based on use of the Site are the sole responsibility of the user, and you agree that Tudor is not liable for any action you take or decision you make in reliance thereon. For investors in the UK, the information on this Site is issued by us only to and/or is directed only at persons who are Exempt Persons and is therefore exempt from the UK Financial promotion restriction on the communication of invitations or inducements to participate in unregulated collective investment schemes. To the extent that any funds or products are referred to on this Site, they are available only to such persons and other persons should not act or rely on the information available on this Site. Tudor provides investment advice and solicits investment advisory services only in those states and countries where it is registered or where it is exempt from such registration.
  7. Past Performance. Any performance data or comments expressed on this Site or in the Content are an indication of past performance. Investments described or referred to on the Site are included solely as examples of Tudor investments and are for illustrative purposes only. There can be no assurance that such investments are or will be profitable (or that any Tudor investments will have similar properties to any such investments made at other firms). Such investments are not representative of all Tudor investments and are not to be considered a complete list of all investments made by Tudor. THE PAST PERFORMANCE OF ANY FUND IS NOT INDICATIVE OF FUTURE PERFORMANCE, and no representation is being made that any investment or transaction will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided.
  8. Forward-Looking Statements. The Site contains forward-looking statements, which reflect our current views with respect to, among other things, the operations and performance of our businesses. You can identify these forward-looking statements by the use of words such as “outlook,” “believe,” “expect,” “potential,” “continue,” “may,” “should,” “seek,” “approximately,” “predict,” “intend,” “will,” “plan,” “estimate,” “anticipate” or the negative version of these words or other comparable words. Forward-looking statements are subject to various risks and uncertainties, speak only as of the date on which they are made and are subject to change. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from those indicated in these statements. Forward-looking statements are not guarantees of the underlying expected actions or future performance and future results may differ significantly from those anticipated by the forward-looking statements. We undertake no obligation to publicly update or review any forward-looking statement, whether as a result of new information, future developments or otherwise.
  9. Risks in relying on the Content. Any Content that is dated speaks only as of the date indicated. We make reasonable efforts to provide accurate Content on the Site, but at times we may not promptly update or correct the Site even if we are aware that it is inaccurate, outdated or otherwise inappropriate, whether as a result of new information, future developments or otherwise. While we believe that the information on the Site is reliable, we make no representations or warranties, whether express or implied, that the content on the Site is accurate, complete or up to date. You agree that we may change all or any portion of the Site at any time without notice to you and that we are not liable for any action you take or decision you make in reliance on any Content. Further, we do not endorse the opinions of, or warrant the accuracy of facts or other Content contributed by, any third party.
  10. Confidentiality of Content. All information and Content available through any restricted areas of the Site are confidential and proprietary to us. This includes all investment information and results, offering materials, financial statements and other information provided through the Site. You undertake to treat any such information and Content on the Site as secret and confidential and will not disclose such information and Content on the Site to any third party except as expressly set forth in these Terms and Conditions or permitted by us in writing.
  11. Confidentiality of Password. You are solely responsible for maintaining the confidentiality and security of your password. You may not disclose your password to any third party and accept full responsibility for any use of your password. We have the right to disable any user password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with these Terms and Conditions. You must notify Tudor immediately of any actual or suspected loss, theft or unauthorized use of your password. We are not obligated to inquire as to the authority or propriety of any use of or action taken under your password and will not be responsible for any loss to you that arises from such use or action or from your failure to comply with these provisions.
  12. Technological problems with the Site. All or any portion of the Site may not be available and may not function properly at any time. Tudor makes reasonable efforts to avoid technological problems, but at any time the Site may have and may cause technological problems such as viruses and other damaging computer programming routines or engines. You are responsible for configuring your information technology, computer programmes and platform to access the Site. You should use your own virus protection software. You agree that Tudor is not liable for any damage or injury caused by the performance or failure of performance of all or any portion of the Site or any defects, delays or errors in or resulting from your use of the Site. You must not misuse the Site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Site, the server on which the Site is stored or any server, computer or database connected to the Site. You must not attack the Site via a denial-of-service attack or a distributed denial-of service attack. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the Site will cease immediately.
  13. Third Party Content. Tudor does not review or monitor the Content of and is not responsible for any third party website content nor any Content on the Site that is produced by users, publishers, and other third parties not controlled by Tudor. You acknowledge that such content is the sole responsibility of the third party person or organization that created it, and we assume no responsibility for any third-party content or information. If you access any third party website through the Site or otherwise, you do so at your own risk, and Tudor makes no warranties, express, statutory, or implied, with respect to such third party content or information. Hyperlinks to or from the Site do not necessarily constitute third party endorsement, sponsorship, representation or warranty or affiliation of, with or by Tudor with respect to any such linked websites or the content, products or services contained or accessible through such websites or their operators. We have no control over the contents of those websites. These Terms and Conditions do not govern your use of any site or service other than the Site. You should review applicable terms and policies of any linked third party content, information or websites. TUDOR DISCLAIMS RESPONSIBILITY FOR THE PRIVACY POLICIES AND CUSTOMER INFORMATION PRACTICES OF THIRD PARTY WEBSITES HYPERLINKED FROM THE SITE. If you link other websites to the Site, you may not imply or suggest that Tudor has endorsed or is affiliated with such websites, and you may not display the Site as “framed” within another website. Tudor reserves the right to terminate any link or linking program at any time. Similarly, links or copies of third party articles regarding Tudor, its affiliates or its portfolio companies have generally been prepared without the input of Tudor and are provided for convenience purposes only. By inclusion on the Site, Tudor does not represent or warrant the accuracy of such information or take responsibility for its content.
  14. Monitoring and recording activity on the Site. Tudor may: (i) monitor and record activity on the Site in accordance with applicable law and/or our Cookies Policy); (ii) investigate any complaint or reported violation of our policies; (iii) report any activity that we suspect may violate any law or regulation to regulators, law enforcement officials or other persons or entities Page 6 of 8 Updated: July 2022 that we deem appropriate; or (iv) issue warnings, suspend or terminate use of the Site, deny access to all or part of the Site or take any other action that we deem appropriate.
  15. Rules about linking to the Site. You must not establish a link to our Site for any reason and including doing so in such a way as to suggest any form of association, approval or endorsement on our part where none exists.
  16. Privacy Policy. Your privacy is important to us. All personal nonpublic information that we gather from you will be governed by our Investor Privacy Notice (as amended from time to time).
  17. Disclaimer of warranty. The Site, including all Content, services and information are provided “as is” and “as available.” Tudor disclaims all representations and warranties, express or implied, of any kind with respect to the Site and the Content including warranties of merchantability, fitness for a particular purpose and non-infringement of intellectual property and proprietary rights. Without limiting our general disclaimer, Tudor does not warrant the availability, reliability, accuracy, completeness or timeliness of the Site or the Content. Tudor does not warrant that any part of the Site will operate uninterrupted or error-free or that defects will be corrected. You have certain statutory rights under the applicable laws of the United Kingdom. Nothing in these Terms and Conditions is intended to affect these statutory rights.
  18. Limitation of liability.
    1. Except as otherwise provided under clauses 19.2 and 19.3, if we breach these Terms and Conditions, we will only be liable for losses which are a reasonably foreseeable consequence of that breach, up to an amount equivalent to £1,000. Losses are foreseeable where they could be contemplated by you and us at the time of you agreeing to these Terms and Conditions. Except as otherwise provided under clauses 19.2 and 19.3, in no event will the liability of Tudor or its officers, directors, partners, managers, members, employees, agents, distributors and licensees (collectively, “Tudor Personnel”) include losses related to any business of yours such as lost data, lost profits or business interruption however caused arising out of these Terms and Conditions, the Site, the Content, the inability to use the Site, or transactions entered into through the Site. Except as otherwise provided under clauses 19.2 and 19.3, this disclaimer of liability applies to any and all damages or injury, including those caused by any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communication line failure, theft, destruction or unauthorized access to, alteration of or use of any asset, whether for breach of contract, tortious behavior, negligence or under any other cause of action.
    2. You have certain statutory rights under the applicable laws of the United Kingdom. Nothing in these Terms and Conditions is intended to affect these statutory rights.
    3. We do not exclude or limit in any way our liability to you where it would be unlawful to do so or in the case of Tudor Capital Europe LLP’s liability to its customers, under the regulatory system in the United Kingdom.
  19. Indemnification. You agree to indemnify, defend and hold harmless Tudor and all Tudor Personnel from and against any and all suits, losses, claims, demands, liabilities, damages, costs and expenses (including reasonable attorneys’ fees) that arise from or relate to your misuse of the Site in material violation of these Terms and Conditions.
  20. International Use. Because this Site may be accessible internationally, you agree to comply with all local laws, rules, and regulations including, without limitation, all laws, rules, and regulations in effect in the country in which you reside and the country from which you access the Site. The information on this Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or would subject Tudor to any registration requirement within such jurisdiction or country.\
  21. Governing Law.
    1. You agree that any dispute arising out of or relating to your use of the Site or relating to these Terms and Conditions shall be governed and construed in accordance with: (i) if you are resident anywhere in the world other than in the UK, the laws of the United States and the State of New York, without giving effect to conflicts-of-law thereof; or (ii) if you are resident in the United Kingdom, relevant United Kingdom law will apply to these Terms and Conditions.
    2. If you are resident anywhere in the world other than in the United Kingdom, you agree to submit to the personal jurisdiction of the state and federal courts located in New York County, New York, with respect to any legal proceedings arising out of or relating to your use of the Site or relating to these Terms and Conditions and waive any objection to the propriety or convenience of venue in such courts. If you are resident in the UK, the relevant courts of the United Kingdom will have exclusive jurisdiction with respect to any legal proceedings arising out of or relating to your use of the Site or relating to these Terms and Conditions.
    3. As a consumer, you will benefit from any mandatory provisions of the law of the country in which you are resident. Nothing in these Terms and Conditions affects your rights as a consumer to rely on such mandatory provisions of local law.
  22. Suspension or withdrawal. We do not guarantee that the Site, or any Content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of the Site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.
  23. Termination. Notwithstanding anything in these Terms and Conditions or on the Site, Tudor reserves the right, without notice and in its sole discretion, to terminate your license to use the Site, and to block or prevent your future access to and use of the Site or any other Site operated by Tudor. Where possible, we will try to give you reasonable notice of any termination.
  24. Complete Agreement. These Terms and Conditions, our Privacy Notice and Cookies Notice constitute the entire agreement between you and Tudor relating to the Site, and supersede any Page 8 of 8 Updated: July 2022 prior agreements or understandings, written or oral, not incorporated. Certain restricted areas of the Site may require you to agree to supplemental terms and conditions. These Terms and Conditions are not intended to modify or amend Other Agreements you may have with Tudor regarding other matters, and in the event of any inconsistency between these Terms and Conditions and any Other Agreements, the Other Agreements will govern.
  25. Miscellaneous. If a portion of these Terms and Conditions is determined to be unlawful, void or unenforceable, it will not affect the enforceability of the remaining provisions and the remaining provisions will continue in effect. If any unlawful and/or unenforceable provision would be lawful or unenforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect. Headings used in these Terms and Conditions are for reference purposes only and in no way define or limit the scope of the section.

Privacy Notice for Investors

Updated November 2024

The Tudor Group (comprised of a number of companies under common control, including but not limited to Tudor Investment Corporation, Tudor Capital Europe LLP, Tudor Capital (DIFC) Limited, Tudor Capital Singapore Pte. Ltd., Tudor Capital Australia Pty Ltd, and their affiliated companies) and the Tudor Funds (collectively, “Tudor”, “Tudor Group” “we” or “us”) are committed to respecting your privacy.

About this Privacy Notice

This privacy notice applies if you are a client of Tudor, an investor1 in any fund or account managed or advised by Tudor (a “Tudor Fund”), or a member, partner, shareholder, beneficial owner, officer, director, employee or other representative of any client of Tudor or of any investor in any Tudor Fund, including any prospective client or investor (“you”) whose personal data Tudor collects and controls in the conduct of its business and engagement with you. For information about other aspects of Tudor’s approach to personal data, please contact us by using the details set out in the “Contacting Us” section below.

The privacy notice sets out:

  • the basis on which any personal data that you provide to us, that we create, or that we obtain about you from other sources, in connection with the services that we provide to you or your engagement with Tudor (the “Services”), will be used, disclosed and processed by us;
  • the purposes for which we will collect, use, disclose and/or process such data;
  • your privacy rights under applicable privacy laws from time to time in force, including, where applicable, under the General Data Protection Regulation (the “GDPR”), the Cayman Islands Data Protection Act (2021 Revision), the DIFC Data Protection Law 2020, DFIC Law No.5 of 2020 (as amended by the DIFC Laws Amendment Law, DIFC Law No.2 of 2022), Singapore’s Personal Data Protection Act 2012, California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020), the UK GDPR and Data Protection Act 2018 (together, the “Privacy Laws”); and
  • how we protect your personal data.

For the purposes of relevant Privacy Laws, the relevant Tudor company or Tudor Fund with which you are dealing with, as applicable, is the controller in respect of the personal data you provide to us and is responsible for this privacy notice. This means that we are responsible for deciding how we hold, disclose and use your personal data and for ensuring that we use your personal data in compliance with the relevant Privacy Laws.

Maintaining your privacy is important to us and we hold ourselves to high standards in the safekeeping and use of your personal data. We have developed policies designed to protect the confidentiality and privacy of data relating to you, while allowing the needs of investors and clients to be served. Please take the time to read and understand this privacy notice.

Where required, the Tudor Group companies have each designated Tudor Capital France S.A.S. to act as their representative in the European Union, and Tudor Capital Europe LLP to act as their representative in the UK, for the purposes of Article 27 of the GDPR and UK GDPR respectively. They can be contacted using the details in the “Contacting Us” section below.

Personal Data that We Collect About You

We will collect, use, disclose and process your personal data in connection with any person’s existing or proposed appointment or engagement of Tudor or existing or proposed investment in a Tudor Fund (each such person, a “Tudor Investor”) including without limitation your name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, correspondence records, passport number, bank account details, source of funds details and details relating to your investment activity. This information may come from sources such as application or subscription documents or other forms or material completed or supplied by actual or prospective Tudor Investors (by mail, email or a secure web portal), other written, electronic or verbal correspondence which relate to transactions by or on behalf of a Tudor Investor, as well as financial information relating to any such person’s investment in a Tudor Fund or any portfolio investments, such as capital account balance, contributions, income allocations and distributions. We will also collect personal data provided by you in calls, which may be recorded by us, as required by applicable laws, special categories of personal data (as this and similar terms are defined in the Privacy Laws) where provided by you, with your consent and as required by you, such as disability information or religious data for purposes such as scheduling of meetings or access to Tudor or Tudor Group premises, and information collected automatically on our website (please refer to our Cookie Notice). Our website does not respond to Do Not Track Signals.

Uses of Your Personal Data

We collect and use your personal data to fulfill our contractual obligations, our statutory and regulatory obligations and/or the legitimate interests of Tudor and for other purposes for which Tudor has a lawful basis under the Privacy Laws, including:

(i) where this is necessary for the performance of our rights and obligations under the subscription agreement and/or the constitutional and operational documents of the Tudor Funds;

(ii) to discharge our anti-money laundering obligations, to verify the identity of our customers (and, if applicable, their beneficial owners), for the prevention of fraud, for regulatory or tax reporting purposes or in response to legal requests or requests from regulatory authorities (e.g., where this is necessary for compliance with a legal obligation to which we are subject);

(iii) for purposes of reporting to, or communicating with, Tudor Investors concerning their investment in Tudor Funds or the appointment or engagement of Tudor consistent with our obligations to such Tudor Investors;

(iv) in connection with our investment activities, including investment due diligence or investment monitoring activities or in response to “know your customer” requirements of brokers, counterparties, exchanges or regulatory bodies;

(v) in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving Tudor, Tudor Funds or Tudor Investors; and/or

(vi) for other legitimate business interests including but not limited to, for marketing purposes, quality control, business and statistical analysis or tracking fees and costs, customer service, training and related purposes (i.e., where this is for the purposes of the legitimate interests of us or a third party and such legitimate interests are not overridden by your interests, fundamental rights or freedoms and provided that we are acting in a fair, transparent and accountable manner and have taken appropriate steps to prevent such activity having any unwarranted impact on you and also noting your right to, object to such uses in certain circumstances,). If you have provided special categories of personal data to us to enable us to respond to certain requests by you such as access requests or scheduling of meetings or similar requirements, we do so with your consent.

Should we wish to use your personal data for any purpose that requires your consent, we will contact you.

Disclosure of Your Information to Third Parties

We will disclose your personal data internally to employees, officers, active partners, members and interns as well as consultants, temporary workers, contractors, agents and other service providers acting for or on behalf of our affiliates, including international offices (“Authorised Individuals”) where it is necessary to fulfill the purposes for which it was collected, as set forth above. As a result, your personal data will be transferred to locations outside of the locations in which our offices are located (including locations outside of the European Economic Area (“EEA”), United Kingdom, DIFC, Singapore or the Cayman Islands) as well as within those locations for the purposes described above.

We will take steps to ensure that your personal data is accessed only by Authorised Individuals that have a need to do so for the purposes described in this notice and that the Authorised Individuals use your personal data in accordance with Privacy Laws.

We will also disclose your personal data outside of the Tudor Group for the following purposes:

  • to service providers (e.g., attorneys, auditors, accountants, tax advisers, insurers, fund administrators, custodians, depositaries, distribution managers, brokerage firms, event organizers or other agents, advisers or service providers of any Tudor Fund or Tudor Investor). As is common in the industry, non-affiliated third party companies may from time to time be used to provide certain services, such as administration services, tax compliance services, reporting, account statements and other information, organizing events, conducting research on client satisfaction and gathering shareholder proxies. These companies may have access to your personal data but are permitted to use the information solely to provide the specific service or as otherwise permitted by law;
  • managers, general partners or investment advisers or administrators, or any of their respective agents or representatives or any affiliate of any of the foregoing. For example, we will disclose personal data to a prospective portfolio fund of any Tudor Fund or Tudor Investor in order to respond to the anti-money laundering enquiries of such portfolio fund;
  • if we sell any of our business or assets, in which case we will disclose your personal data to the prospective buyer for due diligence purposes, subject to appropriate safeguards;
  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
  • to third party agents or contractors (for example, the providers of our electronic data storage services) for the purposes of providing services to us. These third parties will be subject to confidentiality requirements and they must agree to only use your personal data as described in this privacy notice; and / or
  • to the extent required by law (for example, if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights).

International Transfers of Personal Data

The personal data that we collect from you may be transferred to, and stored at, a destination outside your home country and may also be processed by Authorised Individuals operating outside of your home country who work for our affiliates or for one of our service providers.

Where we transfer your personal data outside the jurisdiction or area in which it was collected, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us under the applicable Privacy Laws. This can be done in a number of ways, for instance:

  • the country that we send the data to might be assessed by the European Commission or the Ombudsman in the Cayman Islands as having an adequate level of protection for personal data, see European Commission: Adequacy of the protection of personal data in non-EU countries;
  • The recipient might have signed up to a contract based on “standard contractual clauses” approved by the European Commission and/or the United Kingdom, obliging them to protect your personal data. For further details, see European Commission: Standard Contractual Clauses for the transfer of personal data to third countries. To the extend personal data subject to certain Privacy Laws (for example, the DIFC Data Protection Law) is being transferred, the UK and EU "standard contractual clauses" may be amended, or alternative clauses used, as required to comply with the applicable Privacy Law(s);
  • the recipient has agreed to be bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is, at least, comparable to that under the applicable Privacy Laws; or
  • where we use third-party service providers based in the US, we will transfer data to them if they are part of the EU-US Data Privacy Framework (or any future scheme which requires them to provide similar protection to personal information transferred between Europe and the US, as and when this is approved by the US and the EU). This only applies to transfers of personal data from the EEA, UK and Switzerland. For further details, see  Data Privacy Framework and European Commission: EU-US Data Transfers.

In other circumstances, the law may permit us to otherwise transfer your personal data outside the jurisdiction or area in which it was collected. In all cases, however, we will use commercially reasonable efforts to ensure that any transfer of your personal data is consistent with the Privacy Laws or other applicable laws.

You can obtain more details of the protection given to your personal data when it is transferred as set forth above by contacting us in accordance with the “Contacting Us” section below.

Confidentiality and Security

We do not disclose your non-public personal data to other financial firms or non-affiliates other than as specifically set forth herein. Internally, Tudor restricts access to non-public personal data about Tudor Investors to those personnel who need to know that information in order to offer and provide products or services to you or to otherwise manage your relationship and/or account(s) with Tudor. In addition, Tudor uses technical, physical, electronic and procedural safeguards to protect your non-public personal information.

Retention of Personal Data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

  • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.
  • the establishment, exercise or defence of Tudor’s rights, which will require us to store your personal data as archives;
  • the amount, nature, and sensitivity of the personal data; and
  • the potential risk of harm from unauthorised use or disclosure of your personal data.

Recording and Monitoring of Telephone Calls and Other Communications

Tudor may record telephone lines and monitor voice and electronic communications for regulatory purposes. Emails and other electronic communications will be stored and retained in secure email vaults for legal or regulatory purposes.

EEA, United Kingdom, DIFC, Singapore, California and Cayman Islands Data Subjects: Your Rights

It is important that the personal information we hold about you is accurate. We ask that you keep us informed if your personal information changes during the course of your relationship with us.

If you are in the EEA, United Kingdom, DIFC, Singapore, California, or your personal data is collected by or on behalf of a Cayman Islands Tudor Fund, you have a number of legal rights in relation to the personal data that we hold under the Privacy Laws applicable to you. These rights may include:

  • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
  • the right to withdraw any consent given to our processing of your personal data at any time (where applicable). Please note, however, that we will still be entitled to process your personal data if we have a valid lawful basis and / or legitimate reason (other than consent) for doing so;
  • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
  • the right to request that we rectify your personal data if it is inaccurate or incomplete;
  • the right to request that we erase your personal data in certain circumstances. Please note that there will be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
  • the right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there will be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and / or to refuse that request; and
  • the right to lodge a complaint with the data protection regulators (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contacting Us” section below.

California Consumers

Whilst the categories of personal data we collect, the sources of that personal data, the business and commercial purposes for which we collect it, who we disclose it to, and how long we retain it, are set out in the sections above, California law requires that we use certain categories specific to California law:

  • A. Identifiers
    • Examples: Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
    • Collected? ✔
  • B. Personal information categories listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e)
    • Examples: Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
    • Collected? ✔
  • C. Protected classification characteristics under California or federal law
    • Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
    • Collected? ✔
  • D. Commercial information
    • Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
    • Collected? ✔
  • E. Biometric information
    • Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
    • Collected? ✘
  • F. Internet or other similar network activity
    • Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
    • Collected? ✔
  • G. Geolocation data
    • Examples: Physical location or movements.
    • Collected? ✘
  • H. Sensory data
    • Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
    • Collected? ✘
  • I. Professional or employment-related information
    • Examples: Current or past job history or performance evaluations.
    • Collected? ✔
  • J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
    • Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
    • Collected? ✘
  • K. Inferences drawn from other personal information
    • Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
    • Collected? ✘
  • L. Sensitive personal information
    • Examples: Social security, driver’s license, state identification card, or passport number; user name, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; contents of consumer’s mail, email, and text messages unless we are the intended recipient of the communication; processing of biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.
    • Collected? ✔

In the preceding 12 months, we have collected and used personal data in the manner described above and we may have disclosed to the categories of third parties listed under “Disclosure of your information to third parties” above, for the purposes there provided, all of the categories of personal data as described above. We will not discriminate against you for exercising data subject consumer rights.

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal data is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not share personal data with outside parties for their direct marketing.

You must provide us with enough information that we can verify your identity and that you are a California resident. If you designate an authorized agent to make an access or deletion request on your behalf, we may require the agent to show written authorization from you and require you to verify your identity with us.

We have not “sold” personal data as defined by the CCPA. For this purpose, “sold” or “sale” means the disclosure of personal data for monetary or other valuable consideration but does not include, for example, the transfer of personal data as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

We have not “shared” personal data as defined by the CCPA. For this purpose, “share”, “shared” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, your personal data in writing or by electronic or other means, to third parties for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions in which no money is exchanged.

We do not use personal data for automated decision-making or data profiling.

Supervisory Authorities

You can find out more information about your rights by contacting the applicable supervisory authority below:

Contacting Us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to the Tudor Group Data Privacy Team:

  • Tudor Investment Corporation
    200 Elm Street, Stamford, CT 06902
    Telephone: 1.203.863.8677
    Toll-Free: 1.888.31.TUDOR (888.318.8367)
    Email: dataprivacy@tudor.com
     
  • Tudor Capital Australia Pty Ltd
    c/o DLA Piper Australia
    Level 22
    1 Martin Place Sydney NSW 2000 Australia
    Telephone: 61.2.9080.69062
    Email: dataprivacy@tudor.com
     
  • Tudor Capital Europe LLP
    10 New Burlington Street
    London W1S 3BE United Kingdom
    Telephone: 44.207.518.5151
    Email: dataprivacy@tudor.com
     
  • Tudor Capital (DIFC) Limited
    Unit GD-GB-00-15-BC-43, Level 15
    Gate Building
    DIFC, Dubai
    United Arab Emirates
    Email: dataprivacy@tudor.com
     
  • Tudor Capital Singapore Pte. Ltd.
    9 Straits View Marina One, West Tower, +08-10
    Singapore 018937
    Telephone: 65.6932.6270
    Email: dataprivacy@tudor.com
    DPO Main Contact: Dmitry Grosman

Changes to this Privacy Notice

Tudor may change this privacy notice from time to time by posting an updated version on www.tudorfunds.com. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

1 The terms "investors" and "you" include existing, prospective and former invesors, whether a natural person or entity, in any investment vehicle for which a member of Tudor acts or acted as investment adviser, trading manager, trading advisor, trustee, investment manager, general partner or in a similar capacity.

Cookie Notice

Updated July 2022

Background

This site www.tudorfunds.com (the “Site”) uses Cookies (as defined below) and similar technologies in order to distinguish you from other users. By using Cookies, we are able to provide you with a better experience and to improve this Site by better understanding how you use it. Please read this Website Cookie Notice carefully and ensure that you understand it. Your acceptance of this Website Cookie Notice is deemed to occur when you continue to use this Site. If you do not agree to this Website Cookie Notice, please stop using this Site immediately. What are cookies? “Cookies” are small data files that many internet sites automatically download to a user's computer, phone or tablet. They are primarily used in helping sites recognise a user that has visited the site previously such as simplifying the logging on process for registered users. They can store account and password information. For more information about Cookies, including how to manage and delete them, please go to ICO Cookies.

What Cookies do we use?

The sole purpose of any Cookies that are utilised on the Site are those that are necessary for the secure and efficient operation of the Site.

Here is how we use Cookies:

  • Where strictly necessary. These Cookies and other technologies are essential for us to provide you with the services required as part of our business relationship with you, and to comply with our legal obligations such as our security obligations under applicable data protection laws. These Cookies are necessary for certain features of our Site to work, and enables us to distinguish users and enables you to use its services and features.
  • For functionality. These Cookies and similar technologies remember choices a Site user makes. We use these Cookies to improve user experience.
  • For performance and analytics. These Cookies and similar technologies collect information on how visitors use our Site and enables us to improve how the Site operates, to help us understand how visitors arrive at and browse our Site to identify areas for improvement such as navigation, user experience, and marketing campaigns.

The following are the Cookies which we use on www.tudorfunds.com:

  1. ASPXFORMSAUTH – This is a session cookie that is used when a user logs in to our investor portal. This Cookie is generated at the time of login to ensure the user remain logged in as they browse the Site pages as well as auditing activity and security controls. This Cookie is deleted when the user closes the browser, when the user explicitly logs out, or visits any page after 20 minutes of inactivity and is logged out automatically, whichever is first.
  2. ReturnUrl - This is a session Cookie that is used when a user logs in to our investor portal. This Cookie is generated during the first step of log in (before showing disclaimer or forced password update) and is removed when the user closes the browser, presses agree (if no forced password) or presses “OK” after updating their password/security question.
  3. ASP.NET_SessionId: This is a session Cookie to maintain the state of the session for the user while they are browsing the site from page to page. This Cookie is also deleted once the browser session is closed entirely.
  4. PopupDisclaimerAgree - This Cookie is added when the user agrees to the pre-login site disclaimer banner/popup. This Cookie expires by default after 90.
  5. AutomaticUserGUID: This Cookie is created, IF and when the site user checks the Remember Me option on the login screen. This Cookie is to facilitate the remember me functionality. This Cookie expires after 90 days, or when the user logs in another time with the remember me unchecked, whichever is first.
  6. AutomaticUserToken: This Cookie is created, IF and when the site user checks the Remember My Device option on the MFA screen. This cookie expires by default after 90 days.

What choices do you have?

To make full use of our Site, your computer or mobile device will need to accept Cookies, as our Site will not function properly without them. In addition, Cookies are required in order to provide you with personalised features on our Site.

Contact us

If you have any concerns or questions about how we use cookies on our site, you can contact us at dataprivacy@tudor.com

Tudor Capital Europe LLP Regulatory Disclosures

Tudor Capital Europe LLP is part of the Tudor Group, which includes Tudor Investment Corporation and its affiliates ("Tudor"), and is authorized and regulated by the Financial Conduct Authority. Tudor Capital Europe LLP acts as a sub-investment adviser to Tudor Investment Corporation for certain of the funds and accounts under Tudor’s management.