Privacy Policy

Privacy Policy

WindRose Website Privacy Policy

Effective Date: January 25, 2024

Our Commitment to Your Privacy:

This website privacy policy (this “Privacy Policy”) seeks to help you understand whether and how we collect Personal Information from or about you when you visit this website (the “Website”), and how we may use, share, and retain such information. The term “Personal Information” has the meaning given to it under applicable laws and regulations relating to data protection and privacy (including similar terms such as “personal data”). If you are a California resident, please click here to read our California Privacy Notice.

Personal Information We Collect:

We may collect certain categories of your Personal Information in connection with your use of the Website, including, but not limited to:

  • Information we receive from you directly, including via e-mail or forms submitted via the Website; and
  • Information captured automatically on our Website, including any information captured via “cookies.”

Disclosure of Personal Information:

We do not disclose Personal Information about you to anyone, except: to our affiliates, as permitted or required by law or regulation, or as otherwise described in this Privacy Policy. In the normal course of business, we may disclose the Personal Information listed above to nonaffiliated third party service providers involved in servicing and administering products and services on our behalf. Such service providers include but are not limited to our website administrator, our auditor and legal advisors of the fund.

Information Security:

We consider the protection of Personal Information to be a sound business practice and, to that end, we employ physical, electronic and procedural safeguards to protect your Personal Information in our possession or under our control. However, we cannot guarantee the security of your Personal Information and other information or the appropriateness of the measures we use to safeguard such information. Please keep in mind that no information system can be 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient.

International Visitors:

WindRose may use and disclose your Personal Information outside your country of origin, including in any country in which we conduct business or have a service provider. WindRose is entitled to use your Personal Information for these purposes because one or more of the following legal bases applies:

  • WindRose needs to do so in order to perform its contractual obligations to you (for example, in order to manage your investments and verify the information you provide);
  • WindRose has obtained your specific and informed consent (which may include written consent) unless an exemption provided under applicable law permits the use and disclosure of your Personal Information without your consent;
  • WindRose has legal or regulatory obligations that must be discharged;
  • WindRose may need to do so in order to establish, exercise, or defend its legal rights or for the purpose of legal proceedings; or
  • WindRose’s use of your Personal Information is necessary for our legitimate business interests or the legitimate interests of a third party, provided such interests are not overridden by your rights or interests, including (i) allowing WindRose to effectively and efficiently administer and manage the operation of its business; (ii) maintaining compliance with internal policies and procedures; (iii) monitoring the use of our copyrighted materials; (iv) offering optimal, up-to-date security solutions for mobile devices and IT systems; or (v) for internal research purposes.

If you are located in a jurisdiction which requires us to obtain your consent to collect, use, store, process, and disclose your Personal Information, you understand that by accepting the terms of this Policy you expressly provide your consent to WindRose collecting, using, storing, processing, and disclosing your Personal Information as set out in this Privacy Policy.

Do Not Track Signals:

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.

Your Choices:

Your preferences about how we use your information are important to us and, when possible, we aim to honor them. You may have additional rights under other foreign or domestic laws that may apply to you.  If you have any questions regarding your choices with regarding to our use of your Personal Information, please contact us using the information in the “Contact Us” section below.

Additionally, you have a number of options to manage or limit how we and our vendors use cookies and other online data collection technologies. You may be able to disable cookies or choose the types of cookies you wish to allow. Please refer to your browser settings.  To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.

Third Party Links:

The Website may contain links to other websites operated by organizations not affiliated with WindRose. By accessing other third party websites through our Website, you are consenting to the terms of use and privacy policies of those websites. Please be sure to review third party privacy policies and terms of use to understand how they collect and disclose your information.

Further Information:

We reserve the right to change our privacy policies and this Privacy Policy at any time. The examples contained within this notice are illustrations only and are not intended to be exclusive. 

Contact Us:

Please contact us by emailing us at info@windrose.com or calling 212-887-2195 with any further questions regarding this Privacy Policy.