Privacy Policy
Rio Grande Advisors Inc. ("Rio Grande," "we," "us," or "our") is committed to protecting the privacy and confidentiality of personal information entrusted to us. This Privacy Policy describes how we collect, use, protect, and disclose personal information.
Rio Grande is an investment adviser relying on the private fund adviser exemption under Section 203(m) of the Investment Advisers Act of 1940 and is an Exempt Reporting Adviser with the U.S. Securities and Exchange Commission ("SEC"). Although we are not registered as an investment adviser, we are subject to applicable federal and state privacy and anti-fraud laws.
1. Scope of This Policy
This Privacy Policy applies to investors in private funds advised by Rio Grande, prospective investors, website visitors, business contacts, and other individuals who provide personal information to us. This Policy does not apply to information collected by third parties that we do not control.
2. Information We Collect
Information You Provide Directly: We may collect personal information such as name, address, email address, telephone number, date of birth, tax identification number, citizenship and residency information, financial information, investment experience, bank account information, and identity verification documentation.
This information is typically collected through: Subscription documents, investor questionnaires, due diligence materials, direct communications, and website inquiry forms.
Information Collected Automatically: When you visit our website, we may collect IP address, browser type, device information, pages visited, referring URLs, and date and time of access. We may use cookies or similar tracking technologies for website functionality and analytics. You may adjust your browser settings to refuse cookies; however, certain website features may not function properly.
3. How We Use Personal Information
We use personal information to evaluate eligibility to invest in private funds, comply with regulatory requirements (including AML/KYC obligations), process subscriptions, maintain investor records, communicate with investors, provide investor reporting, prevent fraud, improve website functionality, and comply with legal obligations. We do not sell personal information.
4. Disclosure of Information
We may share personal information only as necessary and appropriate with fund administrators, custodians, auditors, legal counsel, tax advisors, regulatory authorities, third-party service providers, and affiliated investment vehicles. We require service providers to maintain appropriate safeguards and confidentiality protections. We may disclose information if required by law, subpoena, court order, or regulatory request.
5. Confidentiality and Security
We maintain physical, electronic, and procedural safeguards designed to protect personal information, including restricted access to sensitive data, secure data storage systems, encryption where appropriate, vendor due diligence procedures, and internal policies governing data access. Despite these safeguards, no data transmission over the internet can be guaranteed to be completely secure.
6. Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Policy, to comply with legal and regulatory requirements, and to maintain required books and records under applicable securities laws.
7. Identity Theft Protection
Rio Grande maintains policies reasonably designed to detect, prevent, and mitigate identity theft and fraudulent activity where applicable.
8. International Transfers
Because Rio Grande operates across jurisdictions, personal information may be processed or stored in the United States or other jurisdictions. By providing information to us, you consent to such transfer and processing.
9. Your Rights
Depending on applicable law, you may have rights to request access to, correction of, or deletion of personal information we maintain about you, as well as information regarding data sharing practices. To exercise any such rights, please contact us using the information below.
10. Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors.
11. Changes to This Policy
We may update this Privacy Policy periodically. Any changes will be posted on this page with a revised effective date.
12. Contact Information
If you have any questions regarding this Privacy Policy, please contact Rio Grande Advisors Inc., Coral Gables, Florida — info@riograndeadvisors.com