PRIVACY NOTICE

Jaffa Management LLC – Privacy Notice

Last updated May 4, 2023

Introduction

We highly value your privacy, and we are committed to safeguarding your personal data. Jaffa Management LLC (“Jaffa Management”) and the investment accounts or pooled investment vehicles that it advises or manages (each referred to as a “Fund” and collectively as “we” or “us”) are aware of the significance of protecting your privacy. This Privacy Notice outlines our policies regarding the collection, use, storage, sharing, disclosure (collectively, “processing”), and protection of your personal data through this website or other means, including any information you provide when engaging in a transaction with us. This Privacy Notice is being issued in accordance with data privacy laws, such as the EU General Data Protection Regulation 2016/679 (“GDPR”), the US Gramm-Leach-Bliley Act of 1999 as amended, the Cayman Data Protection Law 2017, or any other law relating to privacy or the processing of personal data and any statutory instrument, order, rule or regulation implemented thereunder, that is applicable to Jaffa Management and the Funds (collectively referred to as “Data Protection Law”). For the purpose of this Privacy Notice, “you,” a “user,” or an “investor” refers to any individual user who is also a legal person (each such individual, a “data subject”), as applicable.

California residents should also review our California Privacy Notice.

Collection and use of personal data

On this website, we may collect various categories of personal data including contact information such as names, residential addresses, phone numbers, and email addresses. Additionally, Jaffa Management may also collect sensitive information such as signatures, nationality, tax identification number, date and place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds details or other sensitive information, which may include certain special categories of data contained in relevant materials or documents from users.

We may gather your personal information via various methods, including (i) information given directly to us by you or by someone on your behalf, (ii) data that we acquire in connection with any transactions between you and us, and (iii) recording and monitoring of telephone conversations and electronic communications with you as explained below. In addition, we may obtain your personal information from third parties or other sources, such as our affiliates, our administrator, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

We may use your personal data for various purposes, including managing our relationship with you, communicating with you, conducting analysis of our activities, direct marketing of our products and services, and complying with legal and regulatory requirements, such as anti-money laundering, fraud prevention, tax reporting, and sanctions compliance. We will process your personal data in accordance with applicable Data Protection Law and with your consent, upon your instruction, or for any of the purposes listed above, as well as for any other lawful purpose. Please note that failure to provide personal data may result in us reporting any suspicion of unlawful activity to the relevant supervisory authority or law enforcement agency.

Sharing personal data
We may share your information with our affiliates or third parties for purposes such as facilitating transactions, maintaining your account(s), and responding to legal investigations or court orders. If you instruct us to do so, we will also disclose information about you. We may share your information with our affiliates for direct marketing purposes, including offers of products and services by us or our affiliates. You can prevent this sharing by contacting us at info@jaffacorp.com. However, if you are a new user, we may begin sharing your information with our affiliates for direct marketing purposes after 30 days from the date we sent you this Privacy Notice. Even after you are no longer our user, we may continue to share your information with our affiliates for these purposes. Additionally, we may share information about your experiences with us to our affiliates for their regular business purposes. We do not share your information with non-affiliates for them to market their own services to you.

Monitoring communications

We may monitor and record telephone conversations and electronic communications with you to: (i) gather information about the instructions given, terms of transactions, or other relevant circumstances; (ii) comply with our regulatory obligations; and/or (iii) prevent and detect financial crimes.

Retention of communications and security
We will only keep your personal data for as long as necessary, as required by Data Protection Law. After your investment in a Fund has ended, we will retain your personal data for a minimum of five to seven years or for a longer period if required by applicable law. We may retain your personal data for longer if necessary for marketing purposes or to comply with legal requirements. We periodically review the purpose of personal data we have collected and delete any data that is no longer needed. We take organizational and technical measures to protect your personal information from unauthorized access and use in accordance with Data Protection Law. Our security measures include computer safeguards and secured files and buildings. We will inform you of any significant breaches involving your personal data in accordance with Data Protection Law.

International data transfers
Due to the global reach of our fund management business, personal data may be transferred to countries outside of the European Economic Area (EEA), referred to as "Third Countries," where we conduct business or have service providers. Please note that these Third Countries may not have the same level of data protection as that afforded by the Data Protection Law in the EEA. If such a transfer occurs, we will process the personal data (or ensure that it is processed) in the Third Countries in accordance with Data Protection Law requirements, which may include incorporating appropriate contractual undertakings in legal agreements with our service providers who process personal data on our behalf in such Third Countries.

There may also be situations where we are required to transfer your personal information to our regulators or government agencies in Third Countries, such as in cases where such transfers are necessary for administrative proceedings, including requests for information, examinations, or investigations, or to other relevant parties in Third Countries. These transfers may be necessary to establish, bring, or defend legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.

Your rights under Data Protection Law
Individuals have certain rights under Data Protection Law regarding the processing of their personal data. These rights may include: (i) the right to access their personal data; (ii) the right to request correction of their personal data; (iii) the right to request deletion of their personal data (the "right to be forgotten"); (iv) the right to limit our processing or use of their personal data; (v) the right to object to our processing or use where we rely on our legitimate interests (such as in direct marketing activities); (vi) where relevant, the right to request data portability; (vii) the right to withdraw their consent to processing at any time, where we have obtained such consent; and (viii) the right to file a complaint with a supervisory authority. Please note that the right to be forgotten may not apply to the personal data we hold, given the purposes for which we collect such data, as described above.

You can contact us at any time to limit the sharing of your personal information. If you limit sharing for a jointly held account, your preferences will apply to all account holders. Certain US state laws may provide additional rights to limit sharing.

Nearly all websites use cookies, which do not cause harm to your system. You can typically adjust the types of cookies you accept in your browser settings. We may use cookies to track your usage of our website, allowing us to analyze patterns on an individual or group level. This helps us understand what our visitors want and need, and to develop and improve our website and services accordingly. This website uses Google Analytics cookies, provided by Google, to understand how you interact with the site and create traffic reports. More information on how Google Analytics uses cookies can be found at http://code.google.com/apis/analytics/docs/concepts/gaConceptsCookies.html.

Third-party links
This website may include links to other sites operated by third parties. We are not responsible for their privacy statements. When leaving our website, we encourage you to read the privacy policy of every website you visit.

Who to contact about this Privacy Notice
Please contact Jaffa Management by email at info@Jaffacorp.com or by writing to 136 Kingsland Road, Suite 1118, Clifton, NJ 07014 for any questions about this Privacy Notice or requests with regards to the personal data we hold.

Privacy Notice For California Consumers
This notice is required by the California Consumer Privacy Act (“CCPA”) and is applicable only to California residents. It pertains solely to the collection or use of “personal information” that falls under the CCPA. The following categories of personal information about California consumers have been collected by us in the past 12 months: real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, or other similar personal identifiers, signature, physical characteristics or description, telephone number, education, employment, employment history, bank account number, any other financial information, age, citizenship. We may use the personal information we collect for the following purposes: providing information about our products and services, providing updates, performing services such as account servicing and processing orders and payments, auditing compliance, legal compliance, detecting and protecting against security incidents, fraud, and illegal activity, internal operations, maintaining and improving our services, and short-term, transient use. However, the personal information will not be disclosed to another third party nor used to build a profile about a consumer. The personal information in the categories identified above may be disclosed to service providers, affiliates, business partners, legal or government regulatory authorities as required by applicable law, and in connection with a potential business transfer. We have not sold any personal information we collected (including any information about minors under 16 years of age) to third parties in the past 12 months, and we have shared the categories of personal information we collect only as set forth above. The CCPA grants California consumers certain rights, subject to exceptions and limitations, including the right to request information about the personal information we collect, sell, or disclose, the right to request a list of personal information disclosed to third parties for direct marketing purposes, the right to request the deletion of personal information we collected or maintained, the right to opt-out of the sale of personal information (if any), and the right not to receive discriminatory treatment for exercising privacy rights. You can submit requests regarding your privacy rights under the CCPA to us via phone or email. We may need to verify your identity before processing your request, and you can designate an authorized agent to make requests on your behalf.