The MetaProp Group of Companies are providing this notice on their behalf, and on behalf of the funds and clients for which they manage assets, to explain their information collection practices and other important information. These measures reflect our commitment to maintaining the privacy of your confidential information.

The MetaProp Group of Companies collects information about actual and prospective Investors or Clients from the following sources:

a) Information received on applications and other forms including Investment fund subscription documents, questionnaires and online registration forms of websites, whether received in writing or electronically. This information may include name, address, telephone number, e-mail address, tax identification number, income and other financial data, investment experience, and possibly personal bank account information.

b) Information about transactions and account history with The MetaProp Group of Companies, including initial and follow-on subscriptions, transfers and withdrawals or redemptions.

c) Information received from third parties such as solicitors, brokers, selling agents, advisers, product sponsors, exchanges, clearing firms and/or their respective service providers.

d) Information from online forms completed and data received when individuals visit a MetaProp Company website (such as internet protocol address, and browser software).

The MetaProp Group of Companies do not disclose personal or financial information collected from individual Investors or Clients, whether prospective, current or former, without authorization or direction of persons from whom the information is collected, except as disclosed below.

The MetaProp Group of Companies may share information with affiliated or non affiliated service providers or other third parties:

a) for them to assist in providing services to Investors or Clients;

b) as part of marketing arrangements designed to jointly offer a product or service;

c) as may be required by regulatory authorities or law enforcement officials;

d) to the extent reasonably necessary to prevent fraud and unauthorized transactions; or

e) as otherwise permitted by law.

Those receiving information under the circumstances described above are not permitted to use such information for any purpose other than to assist the servicing of account(s) by any of The MetaProp Group of Companies, including helping improve the services offered by them, or as permitted by law. Individuals choosing to withhold personal information requested by The MetaProp Group of Companies may not be provided the services offered by them and/or may not be able to gain access to certain areas of websites hosted by them.

The MetaProp Group of Companies restrict access to nonpublic personal information about past, present or prospective individual Investors or Clients to those who need to know that information in order to assist them in providing services. The MetaProp Group of Companies will maintain physical, electronic and procedural safeguards consistent with applicable U.S. and international standards to protect nonpublic personal information. These safeguards may include, but not be limited to, (i) implementation of network firewalls, dedicated guest-only Wi-Fi access and other network security protocols to prevent internal or external cyber intrusions or tampering, (ii) use of document shredding or third party secured disposal services; and (iii) restricted access to MetaProp company offices (e.g., locks, periodic changes to access codes, electronic access cards, etc.).

The MetaProp Group of Companies store and use the information collected in their roles as both “Controllers” (i.e., data users) and “Processors” (i.e., data storage) of that information. They will also utilize third parties as Processors to store and archive information collected (e.g., via cloud-based services offered by Dropbox.com, GSuite and others), for which service agreements are in place to address confidentiality, security and compliance with applicable privacy directives and laws.

Individuals visiting websites hosted by any of The MetaProp Group of Companies are sending information (including nonpublic personal information) to the United States where The MetaProp Group of Companies’ principal offices are located, and that such information may then be transferred within the United States or back out of the United States to other countries outside of their country of residence, depending on the type of information and how it is stored. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in the website user’s country of residence; and that a MetaProp Company’s collection, storage and use of their information will be governed by this privacy policy.

The MetaProp Group of Companies may use cookies on their websites to enhance a visitor’s experience on the site and to make decisions about ways to improve the website. A cookie (or browser cookie) is a small file placed on the hard drive of a computer. It contains information about preferences for using a website that have been established by someone using a browser on that computer. Unless adjustments to a browser’s settings are made so that it will refuse cookies, a website may issue cookies when a user accesses a website, including one sponsored by a MetaProp Company. Cookies are used to store visitors’ preferences, collect information about how and how often visitors use the website, analyze user trends and improve the website.

The MetaProp Group of Companies may disclose the presence of a cookie to third parties to advertise their services. This may take the form of asking advertisers to display ads promoting their services on other websites based on the presence of a cookie. The MetaProp Group of Companies may also contract with third-party advertising networks, including Google, that use cookies, or other tracking technologies to collect certain non-personal information about user activities on their websites and on third-party websites to provide users with targeted advertising based upon their interests. The MetaProp Group of Companies may also use cookies delivered by third parties to track the performance of their advertisements.

If cookies are utilized, The MetaProp Group of Companies will prompt individuals visiting their website(s), typically on the initial visit, to accept the use of cookies on the website. The visitor may refuse to accept the use of cookies when prompted on the site or may refuse to accept by activating the appropriate privacy settings on their browser. Refusal to accept cookies by a visitor to sites sponsored by The MetaProp Group of Companies may prevent or limit access by such visitors to the entire website or the use of certain portions of the website.

Investors or Clients, whether existing, prior or prospective, and others, may contact The MetaProp Group of Companies to request access to information they have collected about them. If they do so, The MetaProp Group of Companies will first verify their identity before sharing any such information. Once verified, they will send a copy of the information collected electronically, unless a different method is specifically requested. If informed that any information collected is incorrect, The MetaProp Group of Companies will take commercially reasonable steps to correct any errors.

Data that is no longer needed by The MetaProp Group of Companies to provide services may be deleted (unless required to be retained by applicable books and records retention regulations or other laws).

Should you have any questions about our Privacy Policy, or to request (i) access to information collected about you, (2) correction of information we have about you, please contact us by email or by regular mail at:

MetaProp
214 West 39th Street, Ste 705,
New York, NY 10018
(646) 504-4482
info@metaprop.com