Privacy Policy

Last Updated: January 9, 2020

Your privacy is important to us.  This Privacy Policy describes how Partner Fund Management, L.P., on behalf of itself and the funds it manages (collectively, “PFM” or “we”), collects, uses, discloses, updates, and protects personal information you provide to PFM through its website at www.pfmlp.com and other interactions you undertake with PFM.

This Privacy Policy does not apply to personal information of PFM’s employees, employees’ emergency contacts and dependents on their PFM-provided healthcare plans, job applicants, contractors, or investors in funds managed by PFM, whose data is the subject of separate privacy policy notices. The personal information of PFM business contacts collected in the course of PFM’s business-to-business interactions is excluded from this Privacy Policy, as permitted by the CCPA.

PFM may revise and update this Privacy Policy from time to time without additional notice to you. Any changes PFM may make to this Privacy Policy in the future will be posted on this page. Please review the most recent version of the Privacy Policy by clicking on any “Privacy Policy” link on PFM’s website. When PFM updates this Privacy Policy, the “Last Updated” date above will be revised.

Personal Information Collected

This policy applies to personal information collected from, or which may be submitted to, PFM’s website and other information PFM collects when you undertake third party interactions with PFM. PFM currently does not collect personally identifiable information about visitors to the publicly available, non-password protected areas of the website, such as visitors’ names, tracking information, phone numbers, or email addresses; however, we may collect personal information as described in this Privacy Policy from individuals who access the password protected website.

We also may use data collection devices such as “cookies” on certain pages of the website to help analyze our web page flow, measure effectiveness, and promote trust and safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the website and you may be required to reenter your password more frequently during a session. These cookies do not provide PFM with any data analytics or enable behavioral advertising. PFM may also collect and analyze information such as your IP address, the state or country from which you accessed the websites, files you download, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the websites, and other similar information.

PFM’s website does not currently support “Do Not Track” requests.  Therefore, “Do Not Track” signals sent from your browser or device to our website will not be implemented (i.e., Do Not Track requests will be ignored).

When visitors to the website choose to email PFM using links available on PFM’s website, such senders’ names, email addresses, IP addresses and other personal information may be collected by PFM as part of the process of sending and receiving email. Email and other electronic communications sent or received by PFM are subject to mandatory retention periods, as required by applicable laws and regulations and PFM’s policies to implement such requirements.

PFM engages in business relationships with consultants, advisors, contractors and other persons. The personal information PFM collects in the course of these relationships is excluded from this Privacy Policy, as permitted by the CCPA. In the course of its investment research, PFM may obtain anonymized or aggregated data, which is also excluded from this Privacy Policy, as permitted by the CCPA.

PFM’s Use of Personal Information

PFM uses the information collected from our browser and data collection devices to improve our operations, facilitate the services you request, measure interest, customize your experience and enforce our Terms of Use. PFM does not sell any of the personal information we collect about you to third parties, however, PFM may share personal information it collects with third parties as follows:

  • Affiliates and Subsidiaries. PFM may share your information with our affiliates and subsidiaries to deliver our services, ensure a consistent level of service, enhance our products, services and your customer experience, and for our affiliates’ and subsidiaries’ everyday business purposes.
  • Third-party service providers. We provide access to or share your information with select non-affiliated third parties who perform services on our and/or our affiliates’ behalf, including, but not limited to, administrators, email and document retention service companies, customer relationship management software service providers, IT infrastructure providers, banks, prime brokers, custodians, law firms, compliance consultants, auditors, tax preparers, tax reclaim service providers, fund directors and advisory committee members, counterparties and other service providers. These parties have access to information to help us perform our everyday business purposes, such as to correspond with you, process your transactions, maintain your account(s), send you marketing materials, respond to subpoenas, court orders, regulatory requests and legal investigations, cooperate with legal and regulatory bodies, or make required filings and reports to government authorities. We require non-affiliated service providers to maintain the confidence of your private information. In some instances, these non-affiliates may collect information directly from you. If you provide additional information to a service provider directly, their use of your information is governed by their applicable privacy policy.
  • Law enforcement entities. PFM may disclose personal information to courts, governmental or non-governmental regulators, and to law enforcement when required by a valid subpoena or court order, or as otherwise permitted or required by law.

Data and Network Security

PFM maintains operational policies to help safeguard and provide reasonable security for its data networks. However, no security measures are infallible. Always use caution when transmitting information over the Internet.

Data minimization is a responsibility shared by you and PFM. Please, do not send PFM personal information through the website or via email or other electronic communications unless PFM specifically requests or requires such information.

You are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to anyone. If your password has been compromised, you should contact us immediately for a new password.

California “Shine the Light” Law

Pursuant to California’s “Shine the Light” law, California residents have the right, once per calendar year, to request, free of charge, information about the personal information (if any) disclosed to third parties for direct marketing purposes in the previous calendar year. To PFM’s knowledge, no personal information is shared with third parties for those third parties to use for direct marketing purposes.

CCPA Rights Afforded to California Residents

If you are a California resident whose information is covered by the relevant provisions of the California Consumer Privacy Act (“CCPA”), you may have additional privacy rights.

The additional rights described in this section do not apply to personal information that is exempted from the requirements of the CCPA. The CCPA exempts, among other things, publicly available information, information protected by the U.S. Gramm-Leach-Bliley Act of 1999, and information collected and used in a business-to-business context.

Right to Request Information Collected and Used

California residents may submit a request for the following personal information PFM may have collected over the 12-month period preceding the request:

  • The categories of personal information PFM has collected about you.
  • The categories of sources from which the personal information was collected.
  • The business or commercial purposes for collecting such personal information.
  • The categories of third parties with whom PFM shared the personal information.
  • The specific pieces of personal information PFM collected.

California residents may also submit a request for the following information:

  • The categories of personal information (if any) that PFM has sold about you, the categories of third parties to which PFM has sold that information, and the category or categories of personal information sold to each third party.
  • The categories of personal information that PFM has disclosed for a business purpose.

Right to Request Deletion of Your Information

Please note that the right for your personal information to be deleted (the "right to be forgotten") that applies in some contexts under applicable law is not likely to be applicable to most, if not all, of the personal data you provide to us, given the specific nature of the purposes for which we use personal data, as described in this Privacy Policy.

We will consider all requests and provide our response within the time-period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation except where retention is permitted by the CCPA (e.g., to comply with federal, state or local laws; exercise or defend legal claims; perform a contract between you and PFM; maintain the functionality or security of PFM systems; or comply with or exercise rights provided by law).. We may request you provide us with information necessary to confirm your identity before responding to your request.

How to Exercise Your Rights

To exercise the rights above, contact us at +1 (415) 281-1000 or use the contact details set out at the end of this Privacy Notice.

How PFM will Verify an Information Request

PFM’s verification process varies depending on the nature of your request. If PFM is unable to verify your identity with the degree of certainty required, PFM will not be able to satisfy the request.

If a request is received via email, PFM will contact you to confirm receipt of your request. PFM may also contact you to request additional information necessary to verify your request.

How PFM will Handle a Request

PFM’s goal is to respond to any verifiable consumer request within forty-five (45) days of its receipt of such request, but in certain cases, additional time might be required. If your request will take longer to fulfill, PFM will inform you. Please contact PFM’s Chief Compliance Officer at the email address below with any questions about this Privacy Policy.

PFM expects to respond to verified requests free of charge, but in certain situations, you may be required to pay a reasonable fee to cover the administrative costs of providing the information.

Children’s Privacy

Our services and websites are not intended for persons under the age of 18 and persons under the age of 18 are not eligible to use our website or our services. If we become aware that we have collected personal data from a person under the age of 18, we will take reasonable steps to delete such information as soon as possible and will not sell that information to third parties.

How to Contact PFM about Your Privacy

If you have questions about this Privacy Policy, please feel free to contact PFM at compliance@pfmlp.com. To assert your privacy rights, you may also call PFM’s Chief Compliance Officer at +1 (415) 281-1000.

Partner Fund Management, L.P., Partner Investment Management, L.P. and Partner Advisory Services, L.P. are investment advisers registered with the U.S. Securities and Exchange Commission; its SEC File Number is 801-69012 and CRD Number is 146747. Partner Investment Management L.P., Partner Advisory Services, L.P. are “relying advisers” and file a single Form ADV with Partner Fund Management, L.P.