Last Updated: July 27, 2023
Personal Information We Collect
We only collect, use, store and disclose your personal information where we have a lawful basis to do so. We, including parties acting on our behalf or our affiliates behalf (such as our service providers), collect, use and disclose (for the purposes described below) several types of personal information, including:
We collect contact information, such as name, email, address, phone number and title, if you or your representative provide us with this information in connection with prospective services or if you work with us as a service provider or vendor to our business. We also collect contact information from those who register for or attend our sponsored events. We use this information to communicate with such persons and conduct our business relationships.
Information Collected Through Technology.
We may collect information needed for our operations, such as bank account information to process vendor invoices and payments, transaction history and signatures. We also collect personal information to determine the appropriate investment strategy or strategies for our clients and prospective clients or as otherwise appropriate to pursue our investment strategies.
Professional and Education Information.
We may collect information needed for our operations, such as background or educational information, references, emergency contact information, information to identify conflicts of interest and similar information as needed to comply with our policies and procedures.
Other Electronic Network Activity Information.
We maintain various security measures to protect our technology infrastructure. We monitor those who connect to our guest internet network or otherwise interact with our in-office technology infrastructure, such as by collecting browsing history, IP address or other unique identifier and information about the devices connected to our network.
Audio and Visual Information.
We collect audio and visual recordings of our hosted events to support our marketing efforts. We maintain security measures to protect our premises, including video cameras, and to facilitate our operations, we may also collect audio recordings from those who contact us.
Physical Security and Biometric Information.
We maintain various physical, technical and administrative security measures to protect our premises and operations, which capture personal information. These include badges to enter the building and access certain parts of the premises, health checks as may be recommended by public health authorities and sign‐in processes for guests.
If you have provided us with non-personally identifiable information, including anonymous information and aggregate data, we may use such non-personally identifiable information to understand better how visitors use the Site. We may use this anonymous data and disclose it to our service providers for lawful business purposes, including to improve the Site and promote our business.
If you engage us for Investment Services, we, including parties acting on our behalf or our affiliates behalf (such as our service providers), also collect, use and disclose (and have done so for the preceding 12 months):
- Information you provide us or that your financial representative provides us on forms used in connection with your investments, in other electronic or written communications and during telephone or in person meetings (such information may include identifiers such as your name, residential and business addresses, citizenship, birthdate, email address, telephone numbers, household income and net worth, investment qualification and education background, sensitive personal information including your social security number or taxpayer identification number, passport information, driver’s license, information on your tax forms, and other information necessary for us to market our Investment Services to you or comply with laws and regulations that apply to our operations);
- Information about the amounts you have invested with us, such as your initial investment, current account balances and any subscriptions or withdrawals;
- Information about any bank account used to transfer funds between your investment with us and your bank, including information provided for wire transfers; and
- Information we receive from other parties, including information from referral sources, and information that is generated by our service providers, such as administrators, accountants, bankers and custodians, to service our investors and accounts (such as trade confirmations, account statements, tax information reports, transaction records, confirmations of contributions and withdrawals and similar information).
Sources of Personal Information
Much of the information referenced above will have been provided by you, but some may come from other sources, such as your representatives (including your broker-dealer or custodian), your business contact at Churchill, automated sources (as described above) or a mutual referral contact.
If you provide personal information about any person other than yourself, you must ensure they understand how their personal information will be used and that they have given their permission for you to disclose their personal information.
Use of Your Personal Information
- To evaluate and effect investment transactions and contracts, manage the Investment Services we provide you and help maintain the administration, safety, security and integrity of our business and assets;
- To comply with any applicable compliance, legal and regulatory obligations, lawful requests and legal processes (such as to respond to subpoenas and requests during government investigations) as we believe appropriate, and to comply with the compliance obligations required by our service providers;
- To communicate with you about investments, our other services and products, and updates regarding our firm;
- To improve the services provided to you, as well as understand your interests and personalize your experiences with us;
- For marketing and promotional communications (as permitted by law and to the extent you do not opt out of receiving such promotional communications); and
- On occasion, we may ask for your consent to use your personal information for purpose(s) we explain at that time.
If you do not provide requested information in connection with our operations and Investment Services, we may be unable in some circumstances to comply with our obligations or pursue a relationship with you for Investment Services, and we will tell you about the implications of that decision at that time.
Who Receives Personal Information
- Service providers and contractors that act on our behalf and help us with our operations (for example, administrators, solicitors or companies that assist us with hosting, analytics, database management services, marketing services, processing transactions, generating financial reports, data processing, tax filings, technology services and maintaining books and records), provided, that these third parties may use your personal information only as authorized by their contracts with us;
- Our professional advisors, such as lawyers, bankers, accountants, auditors, brokers and insurers in the course of the professional services that they render to us;
- Another company, in the case of a proposed or actual merger, or acquisition or sale of all or part of our business;
- Any third party to which you direct us to disclose your personal information or which you consent to the disclosure of your personal information.
Our Site and Investment Services are not directed to, and we do not knowingly collect personal information from anyone under the age of 16, except as noted below in “Notice for Churchill Job Applicants, Employees and Contractors.” If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us at 877-937-7110.
Do Not Track Signals.
Our Site is not designed to respond to “do not track” signals received from browsers.
Global Privacy Control
Our Site does not send any tracking technologies or cookies and, therefore, does not use Global Privacy Control.
International Data Transfers
We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred outside of your state, province, or country to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Except as otherwise permitted or required by applicable law or regulation, we will retain your personal information if deemed necessary for business purposes, including but not limited to satisfying any legal, accounting, or reporting obligations, or as may be necessary to resolve disputes. We consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means. We specify additional retention reasons for certain records, which may include your personal information, in our policies and procedures.
We maintain physical, electronic and procedural safeguards to guard your personal information and the integrity and security of our databases. We have procedures in place for the disposal and protection against unauthorized access or use of your information. Except as described above, access to non-public personal information is restricted to our personnel who need to know such information. If we disclose your personal information, it is made available for limited purposes and under controlled circumstances.
Your California Privacy Rights
If you are a California resident, you may have certain rights if your personal information is protected by applicable California law, including the following rights (subject to certain exceptions and limitations):
Right to Know. You have the right to request (a) the categories and specific pieces of personal information we collect and disclose; (b) the categories of sources from which we have collected your personal information; (c) the categories of third parties to whom your personal information was shared or disclosed for a business purpose; and (d) the business purposes for such collection and disclosure of your personal information.
Right to Request. You have the right to request a list of the personal information (if any) disclosed to third parties for direct marketing purposes in the prior 12 months.
Right to Delete. You have the right to access and then delete your personal information that we have collected from you or maintained about you (except to the extent we are permitted or required by law to retain any record).
Right to Correct Inaccurate Information. If we maintain inaccurate information about you, you have the right to request correction of that inaccurate personal information, taking into account the nature of the personal information and the purposes of the personal information processing. We will use commercially reasonable efforts to correct this information.
Right to Limit. We do not use or disclose sensitive personal information for purposes other than those permitted by CCPA regulations section 7027(m).
Right to Opt-Out. You have the right to opt-out of the sale or sharing of personal information for cross-context behavioral advertising. However, we do not sell or share any personal information for cross-context behavioral advertising.
California residents also have the right to not be discriminated against for exercising any of the rights described above. If you are a California resident and wish to exercise these rights, please contact our Chief Compliance Officer at 877-937-7110 or email at email@example.com. There are circumstances where we are not required to comply with consumer requests, and we will let you know if one of those situations applies.
We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please contact firstname.lastname@example.org.
To help protect your privacy and maintain security, we will verify your identity before granting access to your personal information or complying with your request. If you request to access or delete your personal information, we will verify your identity by comparing information we have on file against information you may provide us. If you designate an authorized agent to make a request to access or delete your personal information on your behalf, we may require you to (1) provide the authorized agent written permission to do so, and (2) verify your own identity directly with us (as described above).
We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
Notice for Churchill Job Applicants, Employees and Contractors
This Notice for Churchill Job Applicants, Employees and Contractors describes how we collect, use, store and disclose, personal information we obtain from California-resident job applicants, current and former employees, owners of Churchill and contractors, during and after their working relationship with us (“Employees and Contractors”). This Notice for Churchill Job Applicants, Employees and Contractors applies only to Employees’ and Contractors’ personal information that is not exempted from the CCPA and applies only while we are a “business” as defined under the CCPA.
Employees and Contractors may exercise their California privacy rights by following the process described above and may ask us questions using the above contact information. Our data retention policy described above also applies to Employees and Contractors personal information.
Personal Information We Collect From Employees and Contractors
We may collect the following types of personal information from Employees and Contractors:
- Identifiers, such as name, email address, physical address, telephone number, business contact information, and device identifiers;
- Records about Employees and Contractors, such as financial information (including financial account number used for payroll), background check information (where permitted or required by law), and physical characteristics or other descriptions;
- Protected class and demographic information, such as age (including birthdates), gender and veteran or military status;
- Commercial information, such as records of business transactions, salary and wage information, payroll and benefits data;
- Internet or other electronic network activity information, such as information relating to Employees and Contractors use of or interactions with our networks, systems, devices, email, applications and platforms, including browsing history, search history, and other interactions;
- Non-precise geolocation data, such as Employees’ and Contractors’ location as derived from using our network equipment;
- Audio, visual, or other sensory information, such as photographs, security camera footage in the public areas of our facilities, and recordings of calls and video conferences;
- Professional or employment-related information, such as job title, organization, professional licenses, credentials, professional affiliations, professional experience, references, performance and other evaluation information, disciplinary information, resumes, interview notes, human resource records, payroll or other professional information;
- Physical security and biometric information, including badge identifiers to enter the building and access certain parts of the premises and health checks, as may be recommended by public health authorities;
- Education information;
- Inferences drawn from any of the information we collect about Employees’ and Contractors’ preferences and behavior; and
- Sensitive personal information, such as social security number, driver’s license number, or passport number; account log-in information; racial or ethnic origin (if the Employee or Contractor voluntarily provides it); content of mail, email, and text messages where we are not the intended recipient (such as messages that we monitor for compliance and security purposes); political contribution information (as required for our compliance with applicable law); information about Employees’ and Contractors’ health; medical or health insurance information, including insurance policy number (and information about insurance beneficiaries); and information relating to sexual orientation, if a Employee or Contractor voluntarily provides it.
Sources of Employees’ and Contractors’ Personal Information
We collect personal information about Employees and Contractors through job applications and the recruitment process, either directly from them, or from our employees, agents or third parties (e.g., employment agencies, background check agencies or credit reference agencies).
We also collect personal information automatically when Employees and Contractors use our technology infrastructure, and through other interactions with us and our service providers prior to, during, or after their engagement with us (such as if an employee registers for benefits through one of our service providers).
Use of Employees’ and Contractors’ Personal Information
- In connection with an employment or contractor application, such as to assess the application, interview, and any test results for suitability for positions or projects; communicating with Employees and Contractors concerning position openings or their applications; conducting pre-engagement veriﬁcation and screening; oﬀering positions, in our discretion; notifying Employees and Contractors of engagement opportunities (including from our affiliates); and dealing with any inquiry, challenge, or request for feedback received in relation to our recruitment and engagement decisions;
- For human resources management, such as administering payroll and beneﬁts (including leaves of absence and government-related programs); logistics; planning and managing travel and other reimbursable expenses; development and training; absence monitoring; timekeeping; performance appraisals; disciplinary and grievance processes; administration of termination of employment or engagement; assessing qualiﬁcations and eligibility for a particular role or project; equal employment opportunity monitoring; background checks and reference checks; and compliance programs;
- For our internal business purposes, such as managing operations and workforce engagement; enforcing our policies and rules; managing our business assets (including with respect to oﬃce locations and emergency planning); maintaining records of our operations; IT administration of our technologies, network, and intranet; analyzing and managing meeting or conferencing information (including, but not limited to, recording content, which may include voice and/or images); and providing insights into interactions with people Employees and Contractors network with;
- For our internal research and business improvement purposes;
- For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our affiliates, personnel, and customers; for the establishment, exercise or defense of legal claims; protecting personnel safety (including managing spread of communicable diseases), property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity;
- In connection with a corporate transaction, such as if we acquire, some or all of our assets are acquired by another entity; and
- For marketing or promotional purposes, including externally promoting our business (for example, we may publicly disclose the names and work contact information of certain of our representatives or post pictures of current or past personnel who attend our events).
We do not use or disclose sensitive personal information for purposes other than those permitted by CCPA Regulations §7027(m). We only process information about criminal convictions if legally required or permitted to do so, which includes, but is not limited to, the performance of any applicable background checks. We may use anonymized, de-identiﬁed, or aggregated Employee and Contractor information for any purpose permitted by law.
If an Employee or Contractor fails to provide certain personal information when requested, we may not be able to provide essential benefits to those persons (such as paying the Employee or Contractor or providing other benefits), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
We do not employ or contract with children, and we don’t knowingly collect personal information from children under the age of 16, except where they are listed as beneficiaries of a health insurance plan, may visit our office (to visit parents or attend an event) or other administrative purpose related to our relationship with an adult employee or other personnel. If we find out that a child under the age of 16 has given us personal information, except for the aforementioned administrative purposes, we will take steps to delete that information.
Information We Disclose