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Stone Ridge's Commitment to Privacy
Stone Ridge Asset Management LLC (together with its affiliates, “Stone Ridge”) recognizes and respects your privacy. This Privacy Notice describes the types of personal information Stone Ridge obtains, how Stone Ridge uses that information and to whom Stone Ridge discloses it. “Personal information,” as used in this Privacy Notice, includes nonpublic personal information and any data that, either alone or when combined with other information we hold, identifies or could reasonably be linked to an individual covered by this Privacy Notice. If you are an individual investor, this Privacy Notice is relevant to you directly. If you are providing information to Stone Ridge on behalf of other individuals, such as your employees or clients, this Privacy Notice will be relevant to those individuals, and you should transmit this document to such individuals or otherwise advise them of its content.
By accessing and using this website or using our services, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Privacy Notice.
Information Stone Ridge Collects About You
Stone Ridge collects the following categories of personal information about you:
- Information that you provide, which may include your name and address, social security number or tax identification number, date of birth and/or other information;
- Information about transactions and balances in accounts with Stone Ridge;
- Information about transactions and balances in accounts with non-affiliated third parties; and
- Information from consumer reporting agencies, service providers or other sources that may be engaged or consulted in connection with conducting due diligence, know-your-customer, anti-money laundering and other checks required to be performed in relation to admitting new investors.
We may also obtain personal information on you from third parties, such as vendors(e.g., background check providers), advisors and other business partners, and publicly accessible directories and sources. These may include websites; bankruptcy registers; tax authorities; governmental agencies and departments and regulatory authorities; credit reference agencies; sanctions screening databases; and fraud prevention and detection agencies and organizations, including law enforcement.
How Stone Ridge Uses Your Personal Information
Stone Ridge uses your personal information primarily to complete financial transactions that you request or to make you aware of other financial products and services offered by a Stone Ridge affiliated company. Stone Ridge does not sell or share your personal information to third parties for monetary consideration. However, we may disclose IP address or other personal information with third party advertising and marketing vendors in order to support our marketing activities, as described in more detail under the section titled “Cookies” below.
Below are the details of circumstances in which Stone Ridge may disclose personal information:
- Where the processing is necessary for us to perform services we have been contracted to perform or to take steps prior to entering into a contract – for example, to provide information you have requested or to respond to your questions;
- Where necessary for the purposes of StoneRidge’s legitimate business interests, including to operate and facilitate our business and services, communicate with you, undertake business management, planning, statistical analysis, market research and marketing activities, administer and maintain the Company’s records, protect Stone Ridge’s rights and interests, ensure the security of Stone Ridge’s assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services and enforce our terms and conditions;
- Where required by applicable laws and regulations, including laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions; and
- Where the processing is necessary for the establishment, exercise or defense of legal claims.
How Stone Ridge Discloses Your Personal Information
Stone Ridge discloses personal information primarily to complete financial transactions that you request or to make you aware of other financial products and services. Stone Ridge does not sell your personal information to third parties. Below are the details of circumstances in which Stone Ridge may disclose personal information to third parties:
- To service providers (including financial, technical, marketing and professional service providers and consultants) and financial institutions that provide services to the Stone Ridge, who are required protect the confidentiality of your personal information and to use the information only for the purposes for which it is disclosed to them).
- To regulatory, self-regulatory, administrative or law enforcement agencies or other oversight bodies in certain circumstances where we are required to share personal information and other information with respect to your interest in an investment with the relevant regulatory authorities. They, in turn, may exchange this information with other authorities, including tax authorities.
- As authorized, for example, by subscription agreements or organizational documents of an investment and as authorized by you or your designated representatives or other authorized persons.
- In connection with a corporate transaction — for example, to third parties as part of a corporate business transaction, such as a merger, acquisition, joint venture or financing or sale of company assets.
- We also may disclose personal information (1) when disclosure is necessary or appropriate to prevent harm or financial loss or in connection with an investigation of suspected or actual illegal activity, (2) to protect our operations, and (3) to establish and protect the rights, privacy, safety or property of Stone Ridge, our affiliates, you, and others.
Cookies
We may automatically collect certain information about the devices you use to access this website, as well as information on how you interact with this website, through cookies, web server logs, and other similar tracking technologies.
“Cookies” are a feature of web browser software that allows web servers to recognize the computer used to access a website. They are small text files that are stored by a user’s web browser on the user’s hard drive. Cookies can remember what information a user accesses on one website to simplify subsequent interactions with that site by the same user or to use the information to streamline the user’s transactions on related websites. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies last longer and are used to recognize your computer when you return to the website. Cookies are designed to make your online experience easier and more personalized. They can only be read by the server that placed them, and are unable to execute any code or virus. Web server logs are files that store the activity on a certain website.
Information gathered through cookies and web server logs may include information such as the date and time of visits to the website, the pages viewed, time spent at the website and the websites visited just before and just after the website. We use cookies and web server logs to manage your login session, help you move between websites in a smooth and secure manner and to gather information about the browsing activities of users of the website in order to continually improve it and better serve the needs of its users. We do not link cookies to personally identifiable information.
You can change your browser settings to notify you of the cookies being set or updated and to block cookies. Please note that if you have turned off all cookies, some features of the website may not be available to you or otherwise function as intended.
We also may include tracking pixels and web beacons in email messages, newsletters and other electronic communication. They help us to determine whether a message has been opened and to analyze and personalize our interactions with you. Instructions on how to unsubscribe are included in each email.
We use the following categories of cookies on our website. Most web browsers automatically accept cookies. You can, however, change your browser to prevent this or to notify you each time a cookie is set. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.
- Essential cookies: These cookies are necessary for the function of the website and cannot be switched off by us. They do not store any personally identifiable information. While you can set your browser to block or alert you about these cookies, some parts of the website will not work if you do so.
- Performance, functionality and customization cookies: These cookies improve the performance and functionality of the website, but are not essential to its use. Without these cookies, the website and its functions might be more cumbersome to load or navigate, but are still available. The information these cookies collect is aggregated and thus anonymous. This information is solely used for internal purposes in managing the website and improving its functionality. If you do not allow these cookies, we will not be able to monitor the performance of the website, and some of its services may not function properly.
- Analytics cookies: These cookies collect anonymous information that helps us understand how you use our services and to customize the website and our services for you. The functionality of the website is not impacted by the rejection of such cookies. We may use third-party analytics providers such as Hubspot and Google Analytics to collect and analyze usage of the website. You can prevent Google Analytics from using your information by downloading and installing the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout).We also utilize Microsoft Clarity to capture how you use and interact with our website in order to improve and market our products/services. For more information about how Microsoft collects and uses your data, visit the Microsoft’s Privacy Statement.
- Targeting cookies: These cookies record your visit to the website, the pages you have visited and the links you have followed. They recognize you as a previous visitor and track your activity on the website as well as other websites you visit. The functionality of the website is not impacted by the rejection of such cookies. These cookies may be set by our advertising partners and used to build a profile of your interests and show you relevant advertisements on other sites. Targeting cookies do not directly store personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
The sharing of such information may constitute a “sale” or “sharing” of personal information under definitions set forth in certain state laws. Residents of certain states may have the right to opt out of having personal information shared for such purposes by clicking on the “Do Not Sell or Share My Personal Information” link or by contacting us. Please note, if you use different browsers, devices, or services you will need to opt out on each browser or device where you want your choice to apply. You may also be presented with form field to provide your email address or other information so we may add it to an appropriate suppression list.
Sending your Personal Information Internationally
We are based in the United States and the information we collect is governed by U.S. law. By accessing or using our website or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law. Where this is the case, we will take appropriate measures to protect information about you in accordance with this Privacy Notice.
How Stone Ridge Safeguards and Retains Your Personal Information
Stone Ridge maintains physical, electronic, and procedural safeguards reasonably designed to protect the confidentiality of your personal information. Despite these security measures that Stone Ridge has put in place to protect your personal information, no such measures can guarantee security or protect against unauthorized activity. Stone Ridge may retain your personal information for such a period as permitted or required by any applicable laws or regulations and for such a period as may be permitted in accordance with the lawful purposes or legitimate interests outlined above.
California Disclosures
If you reside in California, please review our CCPA Privacy Notice found here, which supplements this Privacy Notice.
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not share personal information with outside parties for their direct marketing.
Keeping You Informed
Stone Ridge reserves the right to modify this Privacy Notice at any time and will keep you informed of further changes as required by law. It is your obligation to review this Privacy Notice from time to time. By using our services and visiting our website, you represent that you read, understand, and accept the terms of this Privacy Notice. Your continued use of our website and services following the posting of changes to terms contained in this notice will mean you understand and accept those changes.
Contact Us
Please contact us if you have any questions, concerns or complaints about this notice or the personal information that we hold about you. You may contact us at info@stoneridgeam.com or call us at (212) 257-4750.