Revised February 2023
This Privacy Notice explains how The Baupost Group, L.LC. (“Baupost” or “we” or “our”) processes personal information.
Current, prospective, and former natural person investors enjoy certain protections under the Gramm-Leach-Bliley Act (“GLBA”), and such protections are addressed in our investor privacy notice. Likewise, personal data related to current, prospective and former Baupost employees is governed under applicable employee privacy notices, including our Supplemental Job Applicant and Intern Privacy Statement for California Residents. This Privacy Notice applies to natural persons not covered by the investor privacy notice or the employee privacy notices.
Information We May Collect
We collect and process personal information about individuals through and in connection with our services. These individuals may include investor representatives (e.g., attorneys, accountants), business contacts, beneficiaries, visitors to our website, individuals who contact us, and others. The amount and type of information that we gather depends on the nature of your interaction with us. We may process personal information of commercial contacts and third-party vendors, including identifiers such as names, addresses and other contact information, and commercial information including financial details as appropriate. Additionally, for visitors to our offices, we may collect a record of names, contact details, COVID-19 related confirmations, and necessary safety and security information, such as visual information collected through CCTV. We collect such information directly from you or, in the case of vendors and other commercial contacts, from your employer, references, or other third parties with whom we interact.
We may also collect information from interactions with our website through the placement of cookies. Some browsers may have “do not track” settings, but we do not honor such browser settings.
For trust beneficiaries or individuals investing in our funds through third parties, we may collect personal information from those trusts or third parties, or other sources for purposes such as anti-money laundering compliance, sanctions screening, or other due diligence. Such information may include identifiers, commercial information, and other information as required by law. We may collect information that is considered “sensitive” under some laws including the California Consumer Privacy Act (“CCPA”), such as social security number or other government identifiers. When we do so, we use such information only for lawful purposes in compliance with the CCPA, such as to resist malicious, deceptive, fraudulent or illegal actions.
How We May Use Personal Information
We may process personal information for any lawful purpose, including where this is necessary:
- for the performance of our rights and obligations under contracts and our constitutional and operational documents, such as for accounting and administration purposes and to provide our investment products and services;
- for compliance with legal or regulatory obligations to which we are subject, such as compliance with anti-money laundering requirements and/or regulatory or judicial requests;
- for our legitimate business interests, such as in connection with the investigation and assertion of our legal interests, to analyze our performance, where required or allowed by an investor, to communicate with our investors, to manage accounts, and/or
- with your consent or at your request.
How We May Share and Disclose Information
We do not sell, and have not sold, personal information, and we do not share personal information for purposes of cross-context behavioral advertising. We may share personal information with service providers retained to perform services on our behalf. These service providers are not authorized by us to use or disclose the information except as reasonably necessary to perform those services or to comply with legal requirements. We also may disclose information (1) if we are required to do so by law, (2) in response to a request from law enforcement or other government agencies, (3) when disclosure is necessary or appropriate to prevent harm or financial loss or in connection with an investigation of suspected or actual illegal activity, (4) to protect our operations, (5) to establish and protect the rights, privacy, safety or property of Baupost, our affiliates, you, and others; and (6) in the event we sell or transfer all or a portion of our business or assets.
Retention of Personal Information
We retain personal information for the time necessary to achieve the purposes outlined in this Privacy Notice, taking into account statute of limitation periods and records retention requirements under applicable law.
Data Subject Rights
Individuals in certain jurisdictions may have certain data subject rights. We will honor those rights as appropriate under applicable law and will review and respond to other requests with respect to personal information. The potentially applicable rights vary by jurisdiction and include rights to access, examine, and correct information, data portability, restrict the use of information, withdraw consent given to the processing of information (where applicable), receive information regarding certain entities to whom we disclose personal information, and to lodge a complaint with an applicable data protection regulator.
In order to exercise any of these rights, please submit a request using the contact information provided below. In the request, please make clear your identity, what personal information is involved, and your request. For your protection, we may need to verify your identity and the identity of any agent purporting to act on your behalf before doing so. We will respond in a reasonably prompt manner, consistent with applicable law.
We do not and will not discriminate against anyone who exercises any of the abovementioned rights.
How We Protect Personal Information
We maintain physical, administrative, technical, and physical safeguards designed to protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of the personal information; nonetheless, no method of data storage or transmission is completely secure, and we do not guarantee the security of data.
When used in this notice, the term “personal information” means information that, alone or in combination with other information, relates to an identified or reasonably identifiable individual. The term “services” refers collectively to websites owned and operated by us and our investment services.
Updates to this Privacy Notice
We may change this Privacy Notice from time to time at our sole discretion and encourage visitors to review this page for any updates to our Privacy Notice.
If you have any questions or concerns about this Privacy Notice or our personal information handling practices, please contact us by calling toll-free at 866-216-8300 or by emailing email@example.com.