Pharo is committed to protecting your privacy and maintaining the confidentiality and security of your personal information.

Pharo Global Advisors Limited (the “Investment Manager”) and Pharo Management LLC, Pharo Management (UK) LLP and Pharo Management (HK) Limited (each, an “Investment Advisor”, collectively, the “Investment Advisors”, and together with the Investment Manager, “Pharo Management”) are committed to protecting your privacy and maintaining the confidentiality and security of your personal information.  Any personal information processed by Pharo Management is jointly controlled by the Investment Manager and the Investment Advisors and each of the Investment Manager and Investment Advisors is the data controller of your personal information. 

Where your details are provided to Pharo Management as a consequence of your investment in Pharo Macro Fund, Ltd., Pharo Trading Fund, Ltd., Pharo Gaia Fund, Ltd., or Pharo Africa Fund, Ltd. (each, a “Fund”; collectively, the “Funds”), then the Investment Manager and Investment Advisors, acting as data controllers, may themselves (or through a third party such as Citco Fund Services (Curacao) B.V. (the “Administrator”) acting in its capacity as the Fund’s administrator) process your personal information or that of your directors, officers, employees and/or beneficial owners.

Pharo Management’s European Union (“EU”) representative is Pharo Management (UK) LLP and its data protection contact is Shauntaine Lim, who may be contacted at privacy@pharo.com.

This policy (the “EU Privacy Policy”) explains the manner in which Pharo Management collects, utilizes and maintains nonpublic personal information about Applicants or investors (“Investors”) based in the EU or the European Economic Area (“EEA”), as required under  the General Data Protection Regulation (EU) 2016/679 (“GDPR”).  This EU Privacy Policy only applies to products and services provided by Pharo Management to individuals (including regarding investments in the Fund) and which are used for personal, family, or household purposes (not business purposes).

Collection of Investor Information

Pharo Management collects personal information about Investors in the Fund, such as Investors’ names, contact details and financial information, from the following sources:

  1. Subscription forms, investor questionnaires, account forms, and other information provided by the Investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, employment information, and financial and investment qualifications;
  2. Transactions within the Fund, including account balances, subscription amounts, redemptions and fees;
  3. Other interactions with Pharo Management (for example, discussions with our staff); and
  4. Verification services and consumer reporting agencies, including an Investor’s creditworthiness or credit history. (Pharo Management generally does not use these services.).

Why we use Investors’ personal information

Your personal data may be processed by Pharo Management or the Administrator (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

  1. to facilitate the opening of your account with the Fund and the management and administration of your share holdings in the Fund on an on-going basis (the “Services”) which are necessary for the performance of the Fund’s obligations to you, including without limitation the processing of redemptions, transfers and additional subscription requests and the payment of distributions, if any;
  2. in order to carry out anti-money laundering checks and related actions which Pharo Management, the Fund or Administrator considers appropriate to meet any legal obligations imposed on them relating to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with the Pharo Management’s, the Fund’s and the Administrator's anti-money laundering procedures;
  3. to comply with their legal obligations and, in particular, to report tax-related information to tax authorities;
  4. to monitor and record calls and electronic communications for (i) processing and verifying instructions, (ii) investigation and fraud prevention purposes, (iii) crime detection, prevention, investigation and prosecution, and (iv) enforcing or defending Pharo Management, the Fund, Administrator or their affiliates, themselves or through third parties to whom they delegate such responsibilities or rights in order to comply with any legal obligation imposed on them, or where the processing is in the public interest;
  5. to disclose information to other third parties such as service providers of Pharo Management, the Fund or Administrator, auditors, regulatory authorities and technology providers in order to comply with any legal obligation imposed on Pharo Management, the Fund or Administrator or in order to pursue the legitimate interests of Pharo Management, the Fund and the Administrator;
  6. to monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of Pharo Management, the Fund and the Administration to improve their delivery of services;
  7. to update and maintain records and fee calculations;
  8. to retain AML and other records of individuals to assist with the subsequent screening of them by the Administrator including in relation to other funds or clients of the Administrator in pursuance of the Administrator's and its clients' legitimate interests;
  9. to pursue the Fund’s legitimate interests, namely its direct marketing to selected professional investors;;

and which are necessary to comply with Pharo Management’s, the Fund’s or the Administrator’s legal obligations and/or which are necessary for Pharo Management’s, the Fund’s or the Administrator's legitimate interests indicated above and/or the processing is in the public interest.

Disclosure of Nonpublic Personal Information

Pharo Management may share nonpublic personal information about Investors or potential Investors with affiliates, as permitted by law.  Pharo Management does not disclose nonpublic personal information about Investors or potential Investors to nonaffiliated third parties, except as permitted by law (for example, Pharo Management may share personal information with service providers, the Administrator and their affiliates, and other third party service providers in order to process the data for the above mentioned purposes).  Such service providers are contractually restricted from using Investor information in any manner other than as mentioned above.

Pharo Management may share nonpublic personal information, without an Investor’s consent, with affiliated and nonaffiliated parties in the following situations, among others:

  1. To respond to a court order, judicial process or regulatory inquiry;
  2. In connection with a proposed or actual sale, merger, or transfer of all or a portion of its business;
  3. To protect or defend against fraud, unauthorized transactions (such as money laundering), lawsuits, claims or other liabilities;
  4. To service providers of the Fund in connection with the administration and operations of the Fund, which may include brokers, attorneys, accountants, auditors, administrators or other professionals;
  5. To assist Pharo Management in offering Pharo affiliated products and services to Investors; and
  6. To process or complete transactions requested by an Investor.

Countries having access to Investors’ personal information

Pharo Management’s servers, storing and keeping Investor information secure, are located in countries which have an adequate level of protection or with which we have signed agreements incorporating the Standard Contract Clauses.

Pharo Management also has a number of personnel and service providers who will have access to your personal information and which are located in other countries which have an adequate level of protection or with which we have signed agreements incorporating the Standard Contract Clauses.

The disclosure of personal information to the third parties described above may involve the transfer of data to Hong Kong, the USA, Curacao, the Cayman Islands and other jurisdictions outside the EEA. Such countries may not have the same data protection laws as your jurisdiction.  Pharo Management has authorized the Administrator as the Fund’s agent to put in place Standard Contractual Clauses with relevant parties to whom personal data will be transferred.  Please contact the Administrator for copies of the Standard Contractual Clauses that have been entered into on behalf of Pharo Management and the Fund.

Collecting Investor Information Legally

Pharo Management is able legally to collect and use your personal information either because:

  1. you have given your consent for Pharo Management to do so as explained at the end of this EU Privacy Policy; and/or
  2. collecting and using your personal information is necessary for Pharo Management to:
    1. enable the Fund to function; or
    2. carry out its legitimate business interests in processing any requests or orders made by an Investor and complying with applicable law.

Retention of Investor Information

Pharo Management, the Fund and the Administrator will retain your personal information for as long as required for them to perform the Services or perform investigations in relation to the Services and in order to enable them to comply with their legal obligations and exercise their legal rights.

Your Rights

You have the right to:

  1. be informed about the personal information Pharo Management collects from you and uses, which this EU Privacy Policy seeks to do;
  2. obtain confirmation from Pharo Management that your personal information is being collected and used by Pharo Management and to access the personal information held by Pharo Management;
  3. have your personal information corrected if it is inaccurate or incomplete at any time;
  4. erasure, or the right to be forgotten, which means you can request deletion or removal of any personal information Pharo Management holds about you at any time, subject to Pharo Management’s legal obligations;
  5. block or suppress Pharo Management collecting and using your personal information, which means Pharo Management can continue to store such personal information but cannot further collect or use it in any way;
  6. obtain and reuse any personal information Pharo Management holds about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from Pharo Management to another place notified by you to Pharo Management in a safe and secure way without hindrance to the usability of your personal information; and
  7. object to Pharo Management collecting or using your personal information where this is based on:
    1. a legitimate interest or the performance of a task in the public interest; or
    2. direct marketing.

To make any requests as listed above, please contact Pharo Management at privacy@pharo.com.

Pharo Management will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where the request is more complex.

Withdrawal of Your Consent

You can tell Pharo Management to stop collecting and using your personal information at any time by emailing Pharo Management at privacy@pharo.com.

Where Pharo Management, the Fund or the Administrator requires your personal information to comply with AML or other legal requirements, failure to provide this information may mean that you will be unable to be accepted as an Investor in the Fund.

Former Customers and Investors

This same EU Privacy Policy applies to former Investors in the EU and the EEA.

Protection of Investor Information

Pharo Management maintains appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards that comply with the GDPR to protect customer information, including:

  1. the pseudonymization and encryption of your personal information where appropriate;
  1. ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  2. ensuring Pharo Management can restore access to personal information in a timely manner if a physical or technical incident occurs; and
  3. regular testing, assessment and evaluation of the effectiveness of its technical and organizational measures to ensure your personal information is secure.

Pharo Management restricts access to the personal and account information of Investors to those employees who need to know that information in the course of their job responsibilities.  Pharo Management will destroy, erase or make unreadable data, computer files and documents containing nonpublic personal information prior to disposal.

Job Applicants

Where you are an applicant for an employment position/ opening (“Applicants”) at Pharo Management (such as through https://www.pharo.com/careers/) each of the Investment Manager and Investment Advisors shall be data controllers with regard to your personal information. All relevant elements of this Privacy Policy shall apply to Applicants equally as it applies to Investors, including but not limited to, collection of information, disclosure of personal information, lawful collection of personal information, your rights, protection of personal information etc.

Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

  • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

In some instances, we may retain your information to consider you for other roles and future opportunities with us which may be of interest to you. If you do not want us to retain your information, or want us to update it at any stage, please contact us at privacy@pharo.com.

Further Information

This EU Privacy Policy replaces all previous disclosures we may have provided you about our information practices in the EU.  Pharo Management reserves the right to change this Privacy Policy at any time.  The examples contained within this EU Privacy Policy are illustrations and are not intended to be exclusive.  This Privacy Policy complies with the GDPR regarding privacy.  You may have additional rights under other foreign or domestic laws that may apply to you.  If you have any questions about this EU Privacy Policy, please call us at 44-207-591-8800.

Making a Complaint

If you would like to make a complaint about the way Pharo Management has collected or used your personal information, please contact us at privacy@pharo.com.

You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by Pharo Management or its service providers infringes the GDPR.