Data Privacy Policy

International Value Advisers (“IVA”) is committed to safeguarding the privacy and confidentiality of the Personal Information you have entrusted to us. This policy outlines the Personal Information we will collect, how we will use it, and who may access it. For purposes of this Policy, Personal Information means information about an identifiable individual. It includes information that you have provided to us or was collected by us from other sources.  It may include, for example, your name, address, contact information and other information we receive about you.

Personal Information that we collect and how it is collected

• information that you provide to us (including your name, email address, other contact details, and the entity with which you are affiliated, if applicable), such as when you use the contact form on our website, provide a business card to an IVA employee, or interact with IVA in a business relationship or potential business relationship;
• information about you (including your name and business contact information) that is made available to us by others, such as when you are identified as a contact person by an entity with which we do business; and
• if you contact us, we will typically keep a record of that correspondence.

Purposes for collecting your Personal Information

We will process your Personal Information only to the extent applicable law provides a lawful basis for us to do so. Your information allows us to achieve a legitimate interest which is not overridden by your interests or your fundamental rights or freedoms. Our legitimate interests will be ensuring that we provide relevant, high quality, and appropriate services related to an investment fund that we manage (the “Fund”).

When we collect your Personal Information, we may use it for the following purposes:

• to provide you with updates and information regarding a Fund by mail, phone or post. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you;
• to administer our services, including to carry out our obligations arising from any agreements entered into between you and us, or to notify you about changes to our services and products;
• to comply with our regulatory requirements, speak with our regulators or defend or prosecute claims as applicable which may include disclosing your Personal Information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings, or investigations by such parties anywhere in the world. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
• to conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us.

Sharing your Personal Information

We will only use or disclose your Personal Information for the purpose(s) it was collected and as otherwise identified in this Data Privacy Policy.

We may use other companies to provide services on our behalf such as data processing and marketing.  Such companies will be given only the Personal Information needed to perform those services and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. We ensure that these companies are held to the same standards of confidentiality by which we are governed.

Retention of your Personal Information

Our retention periods for personal data are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When

Personal Information is no longer needed we securely destroy the data.

Maintaining the accuracy of your Personal Information

We are committed to maintaining the accuracy of your Personal Information and ensuring that it is complete and up-to-date. If you discover inaccuracies in our records, or your Personal Information changes, please notify us immediately so that we can make the necessary changes. Failure to notify us of changes to your Personal Information may negatively impact the way we communicate or provide services to you.

Safeguarding your Personal Information

We use physical, electronic, and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control.  We have agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.

Changes to this Data Privacy Policy

From time to time, we may make changes to this Data Privacy Policy. Please contact us to answer any questions you may have about our Privacy Policy. 

Your Rights

If you have any questions in relation to our use of your Personal Information, you should first contact us using information in the Contact Us section below. Under certain conditions you may have the following rights in relation to your Personal Information:

• access to your Personal Information
• amend and rectify any inaccuracies in your Personal Information
• restrict the use of your Personal Information
• request that your Personal Information be erased
• object to the processing of your Personal Information

You also have a right to lodge a complaint with a supervisory authority, in particular the Member State of your residence, place of work, or place of alleged misconduct.

Contact Us

If you have any questions or concerns about our privacy practices, the privacy of your Personal

Information or you want to change your privacy preferences, please let us know by contacting:

Shanda Scibilia
International Value Advisers
717 Fifth Ave., 10^th Floor
New York, NY  10022
+1 212-584-3580
[email protected]

 

To manage your email preferences, please contact:

Joan Hull
International Value Advisers
717 Fifth Ave., 10^th Floor
New York, NY  10022
+1 212-616-4152
[email protected]