Alua Capital Management LP (“Alua”) recognizes the importance of protecting your privacy and is committed to protecting your personal data.  This privacy policy is provided to you by Alua on behalf of its investment funds, and sets forth Alua’s policies with respect to the collection, sharing and protection of non-public personal information you provide to Alua. These policies apply to individuals and individual retirement accounts only and may be changed at any time, without providing you direct notice.

This privacy policy also explains how investment funds managed or operated by Alua that are organized in the Cayman Islands (each a “Cayman Islands Fund”) collect, use, share, and otherwise process personal data under the Cayman Islands Data Protection Law (as amended, the “Cayman DPL“).  For the purposes of the Cayman DPL, the relevant Cayman Islands Fund is a Data Controller, and for the purposes of this privacy policy, the terms “we“, “us“, “our” includes the Cayman Islands Funds as the context requires.

We collect personal information, such as your address, social security number, assets, transaction and/or income information, for example, when you (i) provide it to us or the Fund’s Administrator in the Subscription Agreement and related documents; (ii) provide it to us in correspondence and conversations with Alua’s representatives; or (iii) make transactions with Alua, such as when you purchase securities from us, tell us where to send money or make a wire transfer. We may also collect your personal information from other sources, such as affiliates. To the extent you provide personal information to service providers to our Funds, we attempt to verify that such service providers maintain their own privacy policies consistent with Alua’s privacy policy.

We may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) solely for our ordinary business purposes, such as to process your transactions, maintain your account(s), respond to court orders and legal investigations or to host this website. Thus, it may be necessary, under anti-money laundering and similar laws, to disclose information about our investors to affiliates and/or non-affiliates in order to accept subscriptions from them. We will also release information about you if you direct us to do so. We do not share your information with non-affiliates for them to market to you. We may disclose your information for our own marketing purposes, such as to offer our products and services to you. We may also disclose information about your transactions and experiences with us to our affiliates for their ordinary business purposes. You do not have the option to limit these types of sharing.

This website may use “cookies,” which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from Alua’s web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of this website. Cookies also help Alua diagnose problems with Alua’s server.

To protect your personal information from unauthorized access and use, we use security measures that comply with federal and other applicable law. These measures include computer safeguards and secured files and buildings. If you have any questions about Alua’s Privacy Policy, please feel free to contact Alua at [email protected].