Notices

CLONED FIRM WARNING

Please be aware that fraudsters are using multiple* false Brevan Howard names to carry out financial services. These firms are not Brevan Howard companies and the fraudsters have not been authorised to use the Brevan Howard name.

You should be especially wary if you have been cold called or experienced aggressive sales tactics.

Be aware that scammers may give out other false details or mix these with some correct details of Brevan Howard. They may change contact details over time to new email addresses, telephone numbers or physical addresses.

If you have provided monies to this fraudulent firm, please contact your local financial regulator who will provide guidance on how to report the scam and possibly recover the proceeds.

*Cloned Brevan Howard entities.

1. Brevan Howard CFD LTD
2. WinnGroups
3. https://www.ucnmedfd.com/ (the “website”)
4. Brevan Howard (Hong Kong) Co., Ltd.
5. Born Howard (Hong Kong) Limited
6. Born Howard (Hong Kong) Co,. Ltd.
7. Born Howard Wealth Management
8. Born Howard
9. Born Howard Securities
10. Born Howard Group
11. Born Howard Securities (China) Co., Ltd
12. Bowen Howard (Hong Kong) Limited
13. Bowen Howard Securities
14. Born Howard Investment and Research
15. 博恩霍华德
16. 博恩霍华德（香港）有限公司
17. 博恩霍华德集团
18. 博恩霍华德证券(中国)有限公司
19. 博恩霍华德证券

Market Soundings

The Market Abuse Regulation (MAR), which became effective on 3 July 2016, introduced new market soundings (or “pre-marketing”) safe harbours to the offence of unlawfully disclosing inside information.

Market soundings are the communication of information, prior to the announcement of a transaction, in order to gauge the interest of potential investors in a possible transaction and the conditions relating to it such as its potential size or pricing, to one or more potential investors.

Should you wish to discuss market soundings with Brevan Howard, please email [email protected].

MIFIDPRU8 Disclosure

BHAM’s latest MIFIDPRU8 Disclosure document can be found here.

Brevan Howard Asset Management LLP and Brevan Howard Asset Management Services Limited: Modern Slavery Transparency Statement 2023/2024

The Modern Slavery Act 2015 (the “Act”) seeks to address the role of businesses in preventing modern slavery from occurring in their supply chains and organisations. This statement (the “Statement”) constitutes the modern slavery statement for Brevan Howard Asset Management LLP (“BHAM”) and Brevan Howard Asset Management Services Limited (“BHAMSL”) (together the “BH Entities”) to set out the steps that the BH Entities took during the financial year ending 31 March 2024 to ensure that modern slavery is not taking place in its business or supply chain.
BH Entities’ Business and Risk Profile
BHAM is regulated by the Financial Conduct Authority (“FCA”) and its sole business is to provide asset management services to the investment funds it is appointed to manage. BHAM does this in line with its regulatory obligations and to the highest professional standard.
The BH Entities have non-UK affiliates in Jersey, Geneva, Lisbon, New York, Austin, Paris, Hong Kong, Cayman, Singapore, Chicago, Dubai and Abu Dhabi; none of which conduct business in the UK. BHAMSL is a corporate member of BHAM and provides services directly to BHAM. The financial year-end of both BHAM and BHAMSL is 31 March 2024.
As a supplier of asset management services, Brevan Howard operates in a sector which is at relatively low risk of modern slavery occurring. Furthermore, the majority of the countries in which the BH Entities’ wider group operates are not ranked as high risk by the Global Slavery Index, and we do not have an extensive supply-chain. However, the BH Entities remain alert to the risk, as shown by its ongoing commitment to combatting modern slavery.
Steps taken to combat modern slavery
It is the policy of the BH Entities to ensure its business and supply chains are free from modern slavery and human trafficking.
The BH Entities’ HR Department carries out thorough checks in line with best practice and regulatory requirements before we employ a new member of staff and all of the BH Entities’ staff are subject to a range of protective policies, including:
- Bullying and Harassment Policy
- Equal Opportunities Policy
- Grievance Procedure
- Whistleblowing Policy
- Health and Safety Policy and Procedures

The BH Entities only deal with suppliers of goods and services they believe to be reputable and carry out risk-based due diligence on its suppliers.

Action taken – 2023/2024

The BH Entities conducted a risk-based review of their suppliers. The main criteria used to evaluate suppliers included the origin of manufacture, the nature of services provided and the location where services are provided from. Where appropriate, the BH Entities undertook checks to confirm if identified suppliers have been named on international watch lists or have negative press associated with their business which may be relevant. The suppliers within scope of this review were able to demonstrate knowledge of the Act and their resulting obligations.

Modern slavery checks have been incorporated into the onboarding process for suppliers within scope of the Act, to confirm whether these suppliers have been named on international watch lists or associated with negative press and to ensure that they can demonstrate knowledge of the Act and their resulting obligations.

Ongoing Commitment

The BH Entities will continue to monitor potential risk areas identified in their supply chains.

The BH Entities expect their suppliers to adopt the same standards they meet themselves and will not deal with any organisation that they believe may be connected with slavery in any way.

The BH Entities’ senior managers who are responsible for sourcing goods and services are aware of the need to be vigilant regarding the risk of modern slavery.

BHAM is also subject to the wider Responsible Investment Policy in relation to its investment management activities.

Progress

The BH Entities will review the steps taken so far to identify any gaps and consider the effectiveness of its approach and to evaluate whether any aspect can be improved.

Furthermore, the BH Entities encourage employees to report any potential instances of modern slavery to management or externally through the Whistleblowing Policy.

Approval Procedure and Publication

This Statement will be reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. This Statement has been reviewed and approved by Board of Partners of BHAM and the Board of Directors of BHAMSL on 26 September 2024.

Signed by:

Craig Adams, Board Member,

on behalf of the Members of Brevan Howard Asset Management LLP.

Date: 26 September 2024

Amina Adam, Director,

on behalf of Brevan Howard Asset Management Services Limited.

Date: 26 September 2024

UK Stewardship Code

FCA Conduct of Business Rule 2.2.3R requires FCA authorised firms to either disclose their compliance or explain their non-compliance with the principles set out in the UK Financial Reporting Council’s Stewardship Code (the “Code”). Brevan Howard Investment Management Limited (“BHIM” or “the Firm”) is authorised and regulated by the FCA in the United Kingdom and therefore subject to the Code.

BHIM manages assets across a number of global diversified hedge fund and UCITS strategies, but does not take an activist shareholder approach. Accordingly, whilst the Firm supports the Code as a mechanism to promote best practice in the institutional shareholder conduct of UK listed companies, the Firm does not consider the Code or its principles to be appropriate for the funds’ investment strategies. BHIM actively endorses hedge fund industry best practice and is a founding member of the Standards Board for Alternative Investments (formerly called the Hedge Fund Standards Board), a body which promotes hedge fund best practice in relation to disclosure, valuation, risk management and fund governance.

Brevan Howard Asset Management Services Limited: Gender Pay Reports

2024: This is Brevan Howard’s 2024 gender pay report as required under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017. Our data is based on employees of our UK employing entity, Brevan Howard Asset Management Services Limited (BHAMSL), as at a snapshot date of 5 April 2024.

2023: This is Brevan Howard’s first gender pay report as required under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017. Our data is based on employees of our UK employing entity, Brevan Howard Asset Management Services Limited (BHAMSL), as at a snapshot date of 5 April 2023.

Investor Education and Protection

Financial Industry Regulatory Authority, Inc. (“FINRA”) Rule 2267 requires Brevan Howard US LLC to provide its customers with the following information:

The FINRA BrokerCheck Hotline Number is: (800) 289-9999.

FINRA’s website address is: http://www.finra.org/.

An investor brochure that includes information describing FINRA BrokerCheck may be obtained from FINRA by contacting FINRA at the above telephone number or accessing FINRA’s website at http://www.finra.org/.

The Geneva Branch of Brevan Howard Investment Products Limited (“BHIPL Geneva”) is authorised by the Swiss Financial Market Supervisory Authority (“FINMA”) as an asset manager of collective assets. BHIPL Geneva’s clients have the possibility of initiating mediation proceedings before the ombudsman to which it is affiliated.

Regulation (EU) No 1286/2014 – PRIIPs Regulation

Key Information Documents as prescribed by EU regulation for BH Macro Limited are located here.

Brevan Howard Privacy Notice

This privacy notice describes how Brevan Howard collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and our website as well as your rights in relation to this information and how you can contact us in order to exercise your rights.

In this privacy notice when we refer to Brevan Howard or “we”/”us”/”our”, we mean Brevan Howard Investment Management Limited (“BHIM”) and the other relevant Brevan Howard group entities. BHIM’s contact address is 82 Baker Street, London, W1U 6AE and we are authorised and regulated in the UK by the Financial Conduct Authority.

We are a data controller in respect of your personal data for the purposes of applicable data protection law, such as the European Union’s General Data Protection Regulation 2016/679 and national implementing legislation, UK GDPR (which is the retained EU law version of the General Data Protection Regulation), the UK Data Protection Act 2018, the Swiss Data Protection Act, the Cayman Islands Data Protection Act (As Revised), the Data Protection (Jersey) Law 2018, Dubai International Financial Centre (“DIFC”) Data Protection Law No.5 of 2020, Abu Dhabi Global Market (“ADGM”) Data Protection Regulations 2021, the Personal Data Protection Act 2012 of Singapore (in which case, we are an ‘organisation’ for purposes of such law) and Israeli Protection of Privacy Law 1981, together with all laws and regulations supplementing, amending or replacing the same.

We may revise this privacy notice at any time by amending this page. You are expected to check this page from time to time to take note of any changes we make, as they are binding on you.
In this privacy notice, “personal data” or “personal information” is any information that can be used to identify you or that we can link to you and which we have in our possession or control.

The personal information that we collect and where we get it from

We will process personal data that you give to us including when you email us or contact us through various channels as follows:

Accessing our website: In accessing our website, especially through the password protected investor login portal, the information that you provide may include your full name, title, telephone number, geographical location, email address and content, date and time of your email correspondence and information about your employer or your business.
Contacting our Investor Relations, Marketing or other teams: When contacting us to obtain information about our funds or our firm, we are required to obtain certain personal data as outlined above to meet regulatory obligations in relation to client classification and know your customer requirements. We store this information in our Client Relationship Management system.

How we use the information we collect

We may do the following with your personal data:

use it to engage in marketing and business development activity in accordance with applicable law in relation to our funds and services. This may include sending you monthly newsletters, updated DDQ documents, monthly risk reports, marketing communications and other information in relation to the Brevan Howard funds that may be of interest to you
to comply with legal and regulatory obligations that we have to discharge
record and monitor your use of our websites or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports
use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our websites and our business
use it to look into any complaints or queries you may have, and
use it to prevent and respond to actual or potential fraud or illegal activities.

Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.

Grounds for using your personal data

We rely on the following legal grounds to process your personal data, namely:

Consent – we may (but usually do not) need your consent to use your personal data. You can withdraw your consent by contacting us (see below).
Performance of a contract – we may need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you.
Legitimate interest – we may use your personal data for our legitimate interests, some examples of which are given above.
Compliance with law or regulation – we may use your personal data as necessary to comply with applicable law/regulation.

The data protection laws in jurisdictions such as Israel do not recognise all of the above legal grounds to process personal data and for these jurisdictions, we process your personal data based on your consent or as may be required by applicable laws.

You are not required by law to provide your personal data, or to agree to all the terms of this privacy notice. Where we need to collect your personal data by law, under the terms of a contract we have with you or based on our legitimate interest, and you choose not to give us the personal data, it may delay or prevent us from meeting our obligations and providing our services to you.

How we share information with third parties

We may share your personal data to other members of the Brevan Howard group for the purposes described above. We will take steps to ensure that the personal data is accessed only by group employees that have a need to do so for the purposes described in this privacy notice.

We may also share your personal data with third parties outside the firm. These groups or individuals may include:

Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal data for the purposes described in this privacy notice in accordance with applicable law. This may include, but is not limited to, IT and communications service providers.
Third parties relevant to the regulated services that we provide. This may include, but is not limited to, counterparties to transactions or litigation, regulators, authorities, governmental institutions and stock exchanges.
If we sell any of our business or assets or we are acquired by a third party, we may disclose your personal data to the prospective buyer for due diligence purposes.
To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal data in order to comply with any legal obligation.

Categories of personal data we disclose: in the preceding 12 months, the only category of personal data we have disclosed are Identifiers and Professional or employment-related information.

Categories of personal data we sell: in the preceding 12 months, we have not sold any personal data for business purposes.

International transfers of personal data

The personal data that we collect from you may be transferred to, and stored at, a destination outside of the jurisdiction in which it was originally collected (“Relevant Location”). It may also be stored and processed by other companies and/or third parties in other countries, which may include destinations outside of the Relevant Location.

Jurisdictions outside the Relevant Location to which your personal data may be transferred include the EU, EEA, UK and USA; countries where Brevan Howard is incorporated (as listed on our website), where your or our representatives are located and/or where a financial instrument you trade is listed or traded.

Where your personal data is transferred outside of the Relevant Location, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the Relevant Location. This can be done in a number of ways, for instance, as applicable:

the country that we send the data to might be approved by the data protection authority in the Relevant Location as offering an adequate level of protection for your personal data; or
the recipient might have signed up to a contract based on “model contractual clauses” approved by the data protection authority in the Relevant Location, obliging them to protect your personal data to a standard comparable to that of the Relevant Location.

In other circumstances the law may permit us to otherwise transfer your personal data outside the Relevant Location. In all cases, however, we will ensure that any transfer of your personal data is compliant with the relevant data protection law.

You can obtain more details about the protection given to your personal data when it is transferred outside the Relevant Location (including a copy of the relevant contractual clauses entered into with recipients of your personal data, if any) by contacting us using the details set out below.

Keeping your information and information security

How long we hold your personal data for will vary and will depend principally on:

the purpose for which we are using your personal data – we will need to keep the information for as long as is necessary for the relevant purpose, and
legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

We take reasonable security measures to protect against unauthorised access to, or unauthorised alteration, disclosure or destruction of personal data. Such measures include the following:

We protect our systems and networks from the Internet with Firewall systems.
We employ intrusion detection software and monitor for unauthorised access.
We maintain and selectively review activity logs, to prevent unauthorized activities from occurring within our computing environment.
We use encryption technology to protect certain sensitive information that is transmitted over the Internet.
We control access to your information inside our company by limiting employee access to systems and data based on business requirements.
We build information security into our systems and networks by following our information security policies, procedures and standards. These documents are based on internationally respected security standards, applicable laws and regulations, and industry-based 'best practices'.
We provide information security awareness courses and materials to our employees to ensure they apply our information security standards in the course of their work.

Your choices and rights

You have a number of legal rights in relation to the personal data. These rights may (depending on where your personal data is located) include:

Obtaining information regarding the processing of your personal data and access to the personal data which we hold about you.
Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal data.
Requesting that we correct your personal data if it is inaccurate or incomplete.
Requesting that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are obliged under regulation to retain it.
Objecting to processing for direct marketing purposes.
Objecting to, and requesting that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally or regulatory entitled to refuse that request.
Objecting to, and requesting that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally or regulatory entitled to refuse that request.
To object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
To not be discriminated against by us when exercising your rights.
Withdrawing your consent where we obtained your consent to process your information (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal), although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
Lodging a complaint with the relevant data protection authority (details of which are provided below), if you think that any of your rights have been infringed by us.
We can, on request, tell you which data protection authority is relevant to the processing of your personal data.

You can exercise your rights in line with applicable law in the relevant location by contacting us using the details set out below. However, please note that these rights are conditional and are not always absolute rights.

Making a privacy complaint

You can contact us using the contact details at the end of this privacy notice if you have any concerns about how we have handled your personal data or to exercise your rights in line with applicable law in the Relevant Location. However, please note that these rights are conditional and are not always absolute rights. If you are not satisfied with the manner in which we have dealt with your complaint, you may contact the relevant data protection authority in your jurisdiction. These may include (but are not limited to):

UK: by contacting the Information Commissioner’s Office at ico.org.uk.

EU: by contacting the relevant data protection authority in the applicable EU Member State. For more information, please search the website at edpb.europa.eu

Cayman Islands: by contacting the Cayman Islands’ Ombudsman. For more information, please search their website at ombudsman.ky

Jersey: by contacting the Jersey Office of the Information Commissioner. For more information, please search their website at www.jerseyoic.org

DIFC: by contacting the DIFC Commissioner of Data Protection. For more information, please search their website at difc.ae/data-protection

ADGM: by contacting the ADGM Office of Data Protection. For more information, please search their website at adgm.com

Singapore: by contacting the Personal Data Protection Commission. For more information, please search their website at https://www.pdpc.gov.sg/

Switzerland: by contacting the Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch/edoeb/en/home

Israel: by contacting the Israeli Protection of Privacy Authority. For information, please search their website at https://www.gov.il/he/departments/the_privacy_protection_authority/govil-landing-page

Contacting us

If you would like further information on the collection, use, disclosure or processing of your personal data or the exercise of any of the rights listed above, please contact us at [email protected].

Annex

California Consumer Privacy Act 2018

This Annex shall apply to the personal data of individuals residing in California ensuring compliance with the California Consumer Privacy Act 2018.

Definitions

“CCPA” means the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. and its implementing regulations.

“Sensitive Personal Information” means personal information that reveals (a) consumer’s Social Security or other state identification number; (b) a consumer’s account log-in, 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; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) consumer’s genetic data. In addition, “sensitive personal information” includes processing of biometric information for purposes of identifying a consumer; personal information collected and analysed concerning a consumer’s health, and personal information collected and analysed concerning a consumer’s sex life or sexual orientation.

“Service Provider” has the same meaning as set forth in the CCPA, which in general means a for-profit legal entity to whom we disclose Personal Information for processing on our behalf for a “business purpose” (as defined in the CCPA) pursuant to a written contract.

“Third-Party Business” means any third party unaffiliated with us to whom we disclose personal data, including clients or partners who advertise, market and sponsor their goods and services, consumer data suppliers and resellers, data enrichment providers and aggregators, social media and social networking services, advertisers, and any other businesses that assist us with our Services.

Special notification for California residents — your California privacy rights

California residents have the following rights under the CCPA:

The right to know the ways in which we collect, use, share, disclose, and otherwise process your personal data;
the right to know the categories of personal data we have collected about you;
the right to know the categories of sources from which personal data is collected, sold or shared, and to whom;
the right to know our business or commercial purpose for collecting, selling, or sharing your personal data;
the right to know the categories of third parties to whom we disclose your personal data;
the right to know the specific pieces of your personal data that we hold;
the right to request the deletion of your personal data, subject to several exceptions;
the right to request that we limit the use and disclosure of Sensitive Personal Information collected about you;
the right to request that we correct inaccurate personal data that we have about you; the right to opt out of the sale of your personal data; and
the right not to be unlawfully discriminated against for exercising these rights.

We will not discriminate against you for exercising your rights under the CCPA. We may take reasonable steps to verify your identity before fulfilling your request to know or delete. For example, we may seek to establish your identity by matching information that you submit alongside your request with information that we have on our records. We may also ask for supplemental information as needed to establish your identity. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so. You may send your request for access to that personal data or request deletion by email to [email protected].

California's “Shine the Light” law, California Civil Code §1798.83, gives California customers the right to prevent our disclosure of their personal data to third parties for those third parties’ direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business' practices related to disclosing personal data to third parties for the third parties' direct marketing purposes. Please submit such requests using the contact information above.

Exercising your rights under the CCPA

California privacy rights requests must include the reference “Request for California Privacy Information” in the subject line, and in the body of the message, and must include an email address or mailing address that we may use for the response. We reserve the right not to respond to requests submitted other than as specified above.

You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your personal data from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:

Complete the transaction for which we collected the personal data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfil the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech rights, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.

Responding to California residents

We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Fund Privacy Notice

This privacy notice relates to the fund entities listed in the Annex (each a “Fund”).

About this privacy notice

The Fund is a data controller in respect of your personal data for the purposes of applicable data protection law, such as the European Union’s General Data Protection Regulation 2016/679 and national implementing legislation, UK GDPR (which is the retained EU law version of the General Data Protection Regulation), the UK Data Protection Act 2018, the Swiss Data Protection Act, the Cayman Islands Data Protection Act (As Revised), the Data Protection (Jersey) Law 2018, Dubai International Financial Centre (“DIFC”) Data Protection Law No.5 of 2020, Abu Dhabi Global Market (“ADGM”) Data Protection Regulations 2021, the Personal Data Protection Act 2012 of Singapore (in which case, we are an ‘organisation’ for purposes of such law), the California Consumer Privacy Act 2018 and Israeli Protection of Privacy Law 1981 together with all laws and regulations supplementing, amending or replacing the same. The Fund is responsible for ensuring that it uses your personal data in compliance with data protection law.

The relevant administrator of the Fund is a data processor (or ‘data intermediary’, as the case may be) in respect of your personal data for the purposes of data protection law and will generally process personal data provided to it in connection with an investment in the Fund in accordance with the Fund’s instructions, and the Fund will generally act as the data controller (or the ‘organisation’, as the case may be) of any such personal data.

This privacy notice applies to you if (i) you are an applicant for shares in the Fund, (ii) your personal data has been provided to the Fund in connection with an application for shares in the Fund by another person (such as where you are a director, partner, trustee, employee, agent or direct or indirect owner of an applicant) or (iii) the Fund otherwise uses your personal data. This privacy notice sets out the basis on which personal data about you will be processed by the Fund, as well as your rights in relation to the processing of your personal data and how you can contact us in order to exercise your rights. Please take the time to read and understand this privacy notice.

Personal data that the Fund might use

The Fund might process the following personal data about you:

(a) Information provided to the Fund by you or (if different) the applicant: This might include your name and address (including proofs of name and address), contact details, date of birth, gender, nationality, photograph, signature, occupational history, job title, income, assets, other financial information, bank details, investment history, tax residency and tax identification information. Such information might be provided in an application form or in other documents (as part of an application process or at other times), face-to-face, by telephone, by email or otherwise.

(b) Information that the Fund collects or generates: This might include information relating to your (or an applicant’s) investment in the Fund, emails (and related data), call recordings and website usage data.

(c) Information that the Fund obtains from other sources: This might include information obtained for the purpose of the Fund’s know-your-client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-person checks, sanctions checks, among other things), information from public websites and other public sources and information received from the applicant’s advisers or from intermediaries.

Uses of your personal data

Your personal data may be stored and processed by the Fund for the following purposes:

(a) Assessing and processing applications for shares in the Fund and other share dealings, including performing know-your-client procedures, issuing and redeeming shares, receiving payments from and making payments to the applicant, calculating net asset value, and overseeing these processes.

(b) General business administration, including communicating with investors, communicating with service providers and counterparties, accountancy and audit services, risk monitoring, the administration of IT systems and monitoring and improving products.

(c) Compliance with legal and regulatory obligations and industry standards, including know-your-client procedures, the automatic exchange of tax information and legal judgments.

(d) In respect of information shared with the Brevan Howard Capital Management L.P. acting by its sole general partner Brevan Howard Capital Management Limited (the “Manager”) and its affiliates, their business activities relating to the Fund, such as investor relations, discussions with the Fund’s service providers and counterparties, decision-making in relation to the Fund, and business strategy, development and marketing.

The Fund is entitled to process your personal data in these ways for the following reasons:

(a) If you are the applicant, you may enter into an investment contract with the Fund and some processing will be necessary for the performance of that contract, or will be done at your request prior to entering into that contract.

(b) Processing may be necessary to discharge a relevant legal or regulatory obligation.

(c) The processing will, in all cases, be necessary for the legitimate business interests of the Fund, the Manager, the Fund’s administrator or another person, such as:

(i) carrying out the ordinary or reasonable business activities of the Fund, the Manager, the Fund’s administrator or other persons, or other activities previously disclosed to the Fund’s investors or referred to in this privacy notice;

(ii) ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud;

(iii) establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and

(iv) ensuring the security of information systems.

(d) In respect of any processing of sensitive personal data falling within special categories, such as any personal data relating to the political opinions of a politically exposed person, the processing will be subject to additional safeguards.

The data protection laws in jurisdictions such as Israel do not recognise all of the above legal grounds to process personal data and for these jurisdictions, the Fund processes your personal data based on your consent or as may be required by applicable laws.

Disclosure of your personal data to third parties

The Fund may from time to time, in accordance with the purposes described above, disclose your personal data to other parties, including (a) the Manager and its affiliates, (b) the Fund’s administrator and its affiliates, (c) professional advisers such as law firms and accountancy firms, (d) other service providers of the Fund, the Manager and the Fund’s administrator, including technology service providers, (e) counterparties, (f) courts and regulatory, tax and governmental authorities, and (g) prospective buyers of the Brevan Howard business for due diligence purposes. Some of these persons will process your personal data in accordance with the Fund’s instructions and others will themselves be responsible for their use of your personal data. These persons may be permitted to further disclose the personal data to other parties.

International transfers of personal data

The personal data that the Fund collects from you may be transferred to, and stored at, a destination outside of the jurisdiction in which it was originally collected (“Relevant Location”). It may also be stored and processed by other companies and/or third parties in other countries, which may include destinations outside of the Relevant Location.

Where your personal data is transferred outside of the Relevant Location, the Fund will ensure that it is protected in a manner that is consistent with how your personal data will be protected by the Fund in the Relevant Location. This can be done in a number of ways, for instance, as applicable:

the country that the Fund sends the data to might be approved by the data protection authority in the Relevant Location as offering an adequate level of protection for your personal data; or
the recipient might have signed up to a contract based on “model contractual clauses” approved by the data protection authority in the Relevant Location, obliging them to protect your personal data to a standard comparable to that of the Relevant Location.

In other circumstances the law may permit the Fund to otherwise transfer your personal data outside the Relevant Location. In all cases, however, the Fund will ensure that any transfer of your personal data is compliant with the relevant data protection law.

Necessity of personal data for an investment in the Fund

The provision of certain personal data is necessary for shares in the Fund to be issued to any applicant and for compliance by the Fund and its service providers with certain legal and regulatory obligations. Accordingly, if certain personal data is not provided when requested, an application for shares might not be accepted or shares might be compulsorily redeemed.

Keeping your information and information security

How long the Fund holds your personal data for will vary. The retention period will be determined by various criteria, including the purposes for which the Fund is using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which the Fund has to keep your personal data).
We take reasonable security measures to protect against unauthorised access to, or unauthorised alteration, disclosure or destruction of personal data. Such measures include the following:

• We protect our systems and networks from the Internet with Firewall systems.
• We employ intrusion detection software and monitor for unauthorized access.
• We maintain and selectively review activity logs, to prevent unauthorized activities from occurring within our computing environment.
• We use encryption technology to protect certain sensitive information that is transmitted over the Internet.
• We control access to your information inside our company by limiting employee access to systems and data based on business requirements.
• We build information security into our systems and networks by following our information security policies, procedures and standards. These documents are based on internationally respected security standards, applicable laws and regulations, and industry-based 'best practices'.
• We provide information security awareness courses and materials to our employees to ensure they apply our information security standards in the course of their work.

Your rights

You have a number of legal rights in relation to the personal data that the Fund holds about you. These rights may (depending on where your personal data is located) include the following:

(a) The right to obtain information regarding the processing of your personal data and access to the personal data that the Fund holds about you.

(b) In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and the right to request that the Fund transmits that 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 the Fund.

(d) The right to request that the Fund erases your personal data in certain circumstances. Please note that there may be circumstances where you ask the Fund to erase your personal data but the Fund is legally entitled to retain it.

(e) The right to object to, and the right to request that the Fund restricts, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask the Fund to restrict, its processing of your personal data but the Fund is legally entitled to continue processing your personal data or to refuse that request.

(f) The right to object to processing for direct marketing purposes.

(g) To object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.

(h) The right to withdraw your consent where we obtained your consent to process your information (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal).

(i) To not be discriminated against by the Fund when exercising your rights.

(j) The right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by the Fund.

Making a privacy complaint

You can contact the Fund using the contact details at the bottom of this privacy notice if you have any concerns about how the Fund has handled your personal data. If you are not satisfied with the manner in which the Fund has dealt with your complaint, you may contact the relevant data protection authority in your jurisdiction. These may include (but are not limited to):