Privacy Notice
| Facts | WHAT DOES QUANTSTREET CAPITAL DO WITH YOUR PERSONAL INFORMATION? |
|---|---|
| Why? | Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
| What? | The types of personal information we collect and share depend on the product or service you have with us. This information can include:
When you are no longer our customer, we continue to share your information as described in this notice. |
| How? | All financial companies need to share customer personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customer personal information; the reasons QuantStreet Capital chooses to share; and whether you can limit this sharing. |
| Reasons we can share your personal information | Does QuantStreet Capital share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| For our marketing purposes – to offer our products and services to you | Yes | No |
| For joint marketing with other financial companies | Yes | No |
| For our affiliates’ everyday business purposes – information about your transactions and experiences | No | We don’t share |
| For our affiliates’ everyday business purposes – information about your creditworthiness | No | We don’t share |
| For nonaffiliates to market to you | No | We don’t share |
| Questions? | Please call 212-537-3877 or visit quantstreetcapital.com/contact |
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| Who we are | |
|---|---|
| Who is providing this notice? | EBH Capital Management LLC, which uses the name QuantStreet Capital |
| What we do | |
|---|---|
| How does QuantStreet Capital protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. |
| How does QuantStreet Capital collect my personal information? | We collect your personal information, for example, when you
We also collect your information from other companies, such as a custodian when you open an account with the custodian that we manage. |
| Why can’t I limit all sharing? | Federal law gives you the right to limit only
State laws and individual companies may give you additional rights to limit sharing. |
| Definitions | |
|---|---|
| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial companies.
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| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies.
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| Joint marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
|
Full Privacy Policy
Introduction
EBH Capital Management LLC (DBA QuantStreet Capital) (“Company” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy. This Policy explains how we collect, use, maintain, protect, and disclose information from and about you, whether you are visiting this website (“Website”), communicating with us electronically, or receiving investment advisory services from us.
This Policy applies to:
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Information collected through this website and other digital platforms, including email, text, chat, form submissions, and other electronic communications between you and us.
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Information you provide to us in person, by phone, or in writing during the course of your relationship with us as a client or prospective client.
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Information we receive from third parties in connection with the services we provide to you, including from custodians of the accounts we manage on your behalf.
This Privacy Policy is intended to satisfy both the general expectations of website visitors and the specific requirements under federal privacy regulations applicable to investment advisers, including Regulation S-P. Please read this Policy carefully to understand our practices regarding your personal information. If you do not agree with our policies and practices, your choice is not to use our Website or otherwise provide us with personal information. By using this Website, requesting information about QuantStreet, or becoming a client, you consent to the terms of this Privacy Policy. We may update this Policy from time to time (see the Changes to Our Privacy Policy section below). Continued use of our website or services after we make changes constitutes your acceptance of those changes.
Information We Collect About You and How We Collect It
We collect information from and about you both online and offline, including (1) information you provide directly to us, (2) information we receive in the course of providing investment advisory services (such as certain information you provide to the custodian of the account(s) we manage for you), and (3) information collected automatically through your interaction with our Website and digital communications.
The information we collect may include:
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Personal Identifiers: such as your name, postal address, email address, telephone number, employer name and address, or other identifiers by which you may be contacted online or offline.
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Financial and Client Relationship Data: including your financial goals, income, savings, debt, assets and investments, investment preferences, and other personal financial information you provide in connection with becoming or being a client.
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Sensitive Personal Information: such as your Social Security number, date of birth, and account numbers, when relevant to our provision of advisory services.
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Technical and Usage Information: such as your IP address, browser type, operating system, device identifiers, and usage details collected through cookies, web beacons, and other tracking technologies, as explained further below.
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Website Interaction Data: such as personal information and optional comments you provide when filling out forms on our Website (e.g., to request a pitch book, schedule a call, or begin the investment process), records and copies of your correspondence with us (including via chat or email), and search queries conducted through the Website.
We collect this information:
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Directly from you when you submit it through our website, communicate with us, or engage us for advisory services.
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Automatically as you navigate the Website, through standard tracking technologies and analytics tools.
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From third parties such as custodians or service providers, when necessary to manage your account or deliver our services.
This combined approach enables us to fulfill our regulatory obligations under laws such as Regulation S-P, while also improving your experience on our website and tailoring our communications to your needs.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (1) details of your visits to our Website, including traffic data, location data, logs, and other communication data, and the resources that you access and use on the Website; and (2) information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For information about how we respond to web browser “do not track” signals and other mechanisms that enable consumers to exercise choice about behavioral tracking, see the section below called Choices About How We Use and Disclose Your Information.
The information we collect may include “Personal Information,” such as your name, address, and contact information, that can be used to identify you. It may also include other (non-personal) information that we may maintain or associate with your personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to: estimate our audience size and usage patterns; store information about your preferences, allowing us to customize our Website according to your individual interests; speed up your searches; and recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Cookies (or Browser Cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company to gather certain information, such as seeing if you opened an email or counting users who have visited certain pages, and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We collect certain information automatically, but we do not collect Personal Information automatically. However, we may tie automatically-collected information to personal information that you or other sources provide to us.
How We Use Your Information
We may use the information we collect about you or that you provide to us — including Personal Information — for one or more of the following purposes:
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To operate our Website, present its contents to you, and improve its performance and functionality.
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To provide information, products, or services that you request from us, including communications related to your inquiries or account.
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To fulfill the purpose for which you provided the information, such as scheduling a consultation or initiating an investment relationship.
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To manage our business relationship, including carrying out our obligations and enforcing our rights under any contract entered into between you and us (such as billing, account administration, or service delivery).
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To inform you of updates, including changes to our Website, services, terms, or policies.
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To market our services, including contacting you by phone or email about services or offerings that may be of interest to you. If you prefer not to receive such communications, you may opt out by emailing us at hello@quantstreetcapital.com. For more, see the section titled Choices About How We Use and Disclose Your Information.
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To conduct behavioral advertising and remarketing campaigns, including displaying advertisements to you across other websites based on your prior interactions with our Website. This may involve the use of third-party vendors (such as Google) that utilize cookies and similar technologies.
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To comply with legal obligations or respond to lawful requests from regulators, law enforcement, or courts.
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To fulfill any other purpose that we describe when you provide the information or that you consent to.
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For any other lawful business purpose, consistent with applicable laws and regulations.
We may continue to use information about former customers to the extent permitted by law, including for regulatory compliance, recordkeeping, legal defense, and permitted marketing or business analytics purposes.
Text Messaging (SMS) Communications
If you choose to opt in, you agree to receive occasional informational, marketing, or service-related text messages from us at the mobile number you provide. These messages may include responses to inquiries, confirmations of scheduled calls, and updates about services you have engaged or expressed interest in.
By opting in, you certify that you are the account holder or have the account holder’s permission to receive text messages at the number provided. Message frequency will vary based on your interactions with us. Standard message and data rates may apply, depending on your mobile carrier and plan.
You may opt out of receiving text messages at any time by replying “STOP” to any text message. You may also request assistance or more information by replying “HELP” to any text message or by contacting us directly using the contact information below. Consent to receive SMS messages is not a condition of any service we provide.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may now or in the future disclose information you provide to us, including Personal Information:
- to contractors, service providers, analytics services, email and similar platforms from which we send content (e.g., MailChimp and Substack), and other third parties we use to support our business (e.g., a marketing firm that sets up various campaigns, including behavioral and remarketing campaigns to advertise our services);
- to other investment advisers, financial services companies, or similar entities to facilitate joint marketing;
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred;
- to fulfill the purpose for which you provide it (e.g., if you provide information by completing the Website’s Invest With Us form, we may share that information with our custodian to help set up your account);
- for any other purpose disclosed by us when you provide the information;
- for other reasons with your consent;
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- to enforce or apply our Terms of Use (link at bottom of page) and other agreements, including for billing and collection purposes; and
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of QuantStreet Capital, our customers, or others.
We may continue to share information about former customers to the extent permitted by law, including for regulatory compliance, recordkeeping, legal defense, and permitted marketing or business analytics purposes.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Promotional Emails from the Company. If you do not wish to receive marketing emails from us, then you can opt out by emailing hello@quantstreetcapital.com. If we have sent you a promotional email, then you may also send us a return email asking to be omitted from future email distributions or click the unsubscribe option in the email.
- Do Not Track Signals. Your web browser may have a “do not track” or similar feature, which sends a signal to our Website requesting that it not engage in behavioral tracking. This Website does not currently respond to that feature.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI website.
We share nonpublic personal information only as permitted by law (e.g., to service your account, to a nonaffiliated third party that provides services to us, as required by legal or regulatory authorities, etc.), and not in ways that trigger the federal opt-out requirements under Regulation S-P. We do not provide the option to opt out of information sharing in these limited contexts. Any third-party service providers or joint marketing partners who receive personal information do so under agreements that restrict their use of such information solely to providing services to QuantStreet Capital or jointly marketing financial products or services, in compliance with Regulation S-P.
Affiliate Marketing (Regulation S-AM)
QuantStreet Capital does not currently have any affiliates and does not share or use information about your transactions, experiences, or creditworthiness for affiliate marketing purposes. If this changes in the future, and we (or any affiliate) wish to use this type of “eligibility information” to market to you, we will first provide you with a notice and an opportunity to opt out, as required under Regulation S-AM.
Your State Privacy Rights
Certain state laws may provide their residents with additional rights regarding the collection, use, and disclosure of personal information. Residents of the following states—California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia—may have, now or in the future, rights to:
- Confirm whether we process their personal information
- Access and delete certain personal information
- Correct inaccuracies in their personal information, considering the nature of the information and the purposes of processing
- Request a portable copy of their personal information (data portability)
- Opt-out of personal data processing for: targeted advertising (excluding Iowa); sales of personal information; profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah)
- Limit or require consent for the processing of sensitive personal information
The scope of these rights may vary by state and may depend on the type and amount of data collected and how it is used. To submit a request to exercise any of these rights, or to appeal a decision regarding such a request, please contact us at hello@quantstreetcapital.com.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may also submit a request to hello@quantstreetcapital.com. However, we do not currently sell personal data as defined under that statute.
International Users
This Website is intended only for residents of the United States. If you are accessing this Website from outside the United States, please be aware that your information will be processed and stored in the United States and may be subject to United States laws. We do not market to or knowingly collect information from residents of the European Union or United Kingdom.
Accessing and Correcting Your Information
You may send us an email at hello@quantstreetcapital.com to request a copy of, correct, or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Confidentiality and Data Security
We have implemented measures designed to protect your information from accidental loss and from unauthorized access, use, alteration, and disclosure. For example, QuantStreet requires multi-factor authentication to access key systems, prohibits the storage of client information on unsecured devices, maintains an incident response plan, requires secure data disposal procedures, and employs a range of other information security safeguards. Access to client information is role-based: managing members have full access, while other personnel are restricted to information necessary for their responsibilities. Unfortunately, despite the precautions we take, the transmission of information via the internet is not completely secure. As such, we cannot guarantee the security of any Personal Information transmitted to or through our website. Any such transmission is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the website.
Children Under the Age of 18
This Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect Personal Information (defined below) from children under 18. If you are under 18, do not provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn that we have collected or received Personal Information from a child under 18 without verification of parental consent, then we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at hello@quantstreetcapital.com.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. We also send this Privacy Policy annually by email to all clients and more often in the event of material changes that impact how we collect or disclose your information. The date the privacy policy was last revised is identified at the top of the policy. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes. You may request the latest version of this policy at any time by contacting us using the information below.
Contact Information
For questions, comments, concerns, or complaints about this Policy or our privacy practices, please contact us at hello@quantstreetcapital.com or 212-537-3877.