THC Global Privacy Policy

Regulators, including the U.S. Securities and Exchange Commission, have regulations emphasizing the obligations of financial institutions to protect the privacy of individuals’ nonpublic personal information. Tensai Holding Company LLC (“THC” or “the Firm”) takes our clients’ and investors’ privacy seriously. Please read this notice carefully to understand how we collect, share, and protect your personal information.

We do not disclose nonpublic personal information about past, current, or prospective clients or investors without their prior authorization to third parties, except as described below.

Personal Information We Collect

We collect personal information about you in connection with providing advisory services. This information includes your social security number and may also include details like:

  • Assets
  • Investment experience
  • Transaction history
  • Income
  • Bank account information
  • Wire transfer instructions

 

How We Collect This Information

We collect information through various means, such as when you provide us with contact information, enter into an investment advisory contract with us, purchase securities from us (e.g., interests in a fund), specify where to send money, or make a wire transfer. We may also obtain personal information from other sources, such as our affiliates or non-affiliated companies.

How We Use This Information

All financial companies share customer information to conduct their business. We use the personal information we collect from you for everyday business purposes, including:

  • Providing advisory services
  • Opening accounts
  • Processing transactions
  • Marketing products and services
  • Responding to court orders, regulatory requests, and legal investigations

 

Disclosure to Others

We may share your personal information with our affiliates and firms that assist us in servicing your account and need such information, like brokers or fund administrators. We may also disclose information to service providers and financial institutions through joint marketing arrangements (e.g., agreements between nonaffiliated financial companies to market financial products or services). We require third-party service providers and financial institutions to protect your confidentiality and use the information only for the intended purposes. These practices align with Federal privacy and related laws. Generally, you cannot limit our use of your personal information under these laws.

How We Protect Your Personal Information

To safeguard your personal information from unauthorized access and use, we implement security measures that comply with Federal law, including computer safeguards and secure files and buildings.

Contact Information

If you have questions regarding this Privacy Notice, please contact us at ir@tensai-holding.com.

Cayman Islands, EU, and UK Privacy Notice

The Cayman Islands Data Protection Law, 2017 (“DPL”), the European Union’s General Data Protection Regulation (EU) 2016/679 (“EU GDPR”), and the UK GDPR, as outlined in the Data Protection Act 2018, collectively referred to as “Applicable Data Protection Laws,” govern the use of personal data by Cayman Islands investment funds managed by THC. THC recognizes the importance of protecting the privacy of investors and asks you to read this Privacy Notice carefully to understand how we collect, share, and protect the personal information of investors in our Cayman Islands funds.

Personal Information We Collect and How It’s Collected

We, our service providers, and THC affiliates may process the following types of personal data in connection with providing advisory services:

  • Personal data provided by you: Name, address, contact information, birthdate, gender, nationality, photograph, signature, occupational history, job title, income, assets, financial information, bank and brokerage details, investment experience, tax residency, and tax identification.
  • Personal data collected or generated by us: Information related to emails, correspondence, call recordings, and website usage data.
  • Personal data obtained from other sources: Information from Know Your Client (KYC) / anti-money laundering (AML) and client due diligence procedures, public websites, public information, and advisors or intermediaries.

 

How We Use This Information

All financial companies share customer information to conduct their business. We use personal information for our everyday business purposes, including:

  • Performance of a Contract
  • Processing your subscription documents to invest in the Fund.
  • Managing and administering your holdings in the Fund.
  • Circulating periodic reports related to the Fund.
  • Compliance with Legal Obligations:
  • Identifying prospective, current, and past investors for AML, CTF, FATCA, and CRS compliance.
  • Sharing information with relevant tax authorities as legally required.
  • Legitimate Interests:
  • Carrying out the Fund’s ordinary business activities.
  • Ensuring compliance with legal obligations and industry standards.
  • Recording and storing correspondence, emails, and phone calls.

 

Personal Data Recipients

We may disclose your personal data to:

  • Affiliates and third-party service providers involved in managing the Fund.
  • The Fund’s professional advisors, bankers, brokers, auditors, and IT providers.
  • Competent authorities (e.g., tax authorities, regulators, courts, law enforcement) as required by applicable law.

 

International Transfers

Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection as under the Applicable Data Protection Laws. We will ensure your data is secure and confidential, even when transferred to different jurisdictions.

Personal Data Security

We take appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or damage.

Personal Data Retention

The retention period for your personal data varies depending on legal obligations and the purposes for which we are using it.

Data Subject Rights

You have several legal rights regarding your personal data, including:

  • Access to the personal data that the Fund holds about you.
  • Rectification of inaccurate or incomplete personal data.
  • Erasure of personal data in certain circumstances.
  • Objecting to or restricting processing in specific situations.
  • Lodging a complaint with a data protection regulator.
  • For more information on your personal data rights under the DPL, EU GDPR, or UK GDPR, you can contact the UK Information Commissioner’s Office at ico.org.uk or the Cayman Islands Ombudsman at ombudsman.ky.

 

Contact Us

If you have questions about the collection, use, disclosure, transfer, or processing of your personal data, or want to exercise your rights, please contact us at ir@tensai-holding.com.

©2024 Tensai Holding Company. All rights reserved.