TERMS AND CONDITIONS

July 2022

By accessing or using our website, located at www.tudor.com (the “Site”), you hereby accept and agree to comply with the following terms and conditions (the “Terms and Conditions”). Your access to or use of the Site constitutes your acceptance of the Terms and Conditions and is a binding agreement between you and Tudor Investment Corporation, Tudor Group Holdings LLC, Tudor Capital Europe LLP, Tudor Capital Australia Pty. Ltd, Tudor Capital Singapore Pte. Ltd. and their affiliates (collectively, “Tudor”, “we”, or “us”). The Terms and Conditions govern your access and use of the Site, which includes any information, data, tools, products, services and other content (together, “Content”) available on or through the Site.

To contact us, please email info@tudor.com.

These Terms and Conditions may be updated by us at any time. Every time you wish to use the Site, please check these terms to ensure you understand the Terms and Conditions that apply at that time. Your continued use of the Site after any such modifications constitutes your acceptance of the Terms and Conditions as modified. If you do not agree to receive these legal notices and to abide by these Terms and Conditions for any reason you agree that your sole and exclusive remedy is to discontinue accessing and using the Site.

These Terms and Conditions refer to the following additional terms, which also apply to your use of the Site:

  • Privacy Notice

Nothing contained in these Terms and Conditions is intended to modify or amend any other written agreement you may have with us that is currently in effect (“Other Agreements”). In the event of any inconsistency between these Terms and Conditions and any Other Agreements, the Other Agreements will govern.

PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THE SITE. EACH TIME YOU USE THE SITE, YOUR USE INDICATES YOUR FULL ACCEPTANCE OF AND AGREEMENT TO ABIDE BY THESE TERMS AND CONDITIONS IN ITS THEN CURRENT FORM, INCLUDING ANY MODIFICATIONS POSTED. IF YOU DO NOT ACCEPT THE TERMS AND CONDITIONS, DO NOT USE THE SITE

1. Tudor grants you a limited right to use the Site. Your right to use the Site is subject to your agreement to abide by these Terms and Conditions in their entirety, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of the Site. At any time and for any reason we may revoke your right to use all or any portion of the Site. You agree not to violate or attempt to violate the security of the Site or to use the Site for any illegal purposes.

2. Intellectual Property. You acknowledge that the Site is protected by one or more copyrights, patents, database rights, trademarks, service marks, trade dress, trade secrets and/or other intellectual property and proprietary rights that are owned by Tudor and/or third parties. All content included on the Site, such as text, graphics, logos, images, articles and other materials, and any combination thereof, are the property of Tudor and/or third parties. The content appearing on the Site includes copyrighted works that are protected under the copyright laws of the U.S. and other countries and under various international treaties. You agree to abide by all applicable copyright and other laws in regard to the Contents of the Site. “TUDOR” and other names and indicia of Tudor and its products and/or services are exclusive trademarks and service marks of Tudor, and are registered in various jurisdictions. Other product and company names appearing on the Site may be trademarks of their respective owners, who may or may not be affiliated with Tudor. Nothing contained on the Site should be construed as granting, by implication, estoppel or otherwise, any license or right to use any content or trademark displayed on the Site without the written permission of Tudor or such other third party that may own the content or trademark displayed on the Site.

3. Restrictions on UseYou may not: (i) decompose, decompile, reverse engineer, disassemble or otherwise deconstruct all or any portion of the Site; (ii) publish, broadcast, retransmit, reproduce, repackage, frame, commercially exploit, create any derivative of or otherwise redistribute all or any portion of the Site except as explicitly permitted in these Terms and Conditions; or (iii) remove any copyright, trademark or other proprietary notice or legend contained on (or printed from) the Site. Our prior permission is required for (i) any commercial use of materials on this Site; (ii) making more than minimal copies of Site materials; and (iii) copying large portions of the Site, such as by bots, robots or spiders that “harvest” the Site (other than for the purpose of appropriately analyzing and indexing the Site for the purpose of providing an Internet search service, Internet directory service, or Internet content directory). If you seek permission for such use of the Site, please contact us at info@tudor.com.  Any unauthorized use of the images may violate copyright laws, trademark laws, the laws of privacy and publicity and communications regulations and statutes.

4. Representations and Warranties.  You represent and warrant that: (i) you have full authority and all rights necessary to enter into and fully perform all of your obligations pursuant to these Terms and Conditions; (ii) you have not and you will not enter into any agreement or perform any act which might contravene the purposes and/or effects of these Terms and Conditions; (iii) you will not delete any Content on the Site.

5. No offer of employment.  The Site does not constitute an offer or promise of employment with respect to any employment position described on the Site. Without notice, Tudor may eliminate, modify or change any aspects of any employment position described on the Site. This Site does not provide binding employment offers or any terms or conditions of employment. Any employment offer that may ensue as a result of your submission of information to Tudor shall be solely in accordance with the specific terms of such employment offer, not the terms of the Site.

6. No Offer or Advice.  All Content (i) is provided for general, informational purposes only; (ii) does not constitute an offer or solicitation to buy or sell any securities, financial instruments, other services or make or hold any investments; and (iii) may not be used or relied upon in connection with any offer or sale of any such securities, financial instruments, other services or investments. An offer or solicitation will be made only through a final private placement memorandum, subscription agreement and other related documents with respect to a particular investment opportunity, and will be subject to the terms and conditions contained in such documents, including the qualifications necessary to become an investor. Although the Site may include investment-related information, nothing on the Site is a recommendation that you purchase, sell or hold any security or other investment, or that you pursue any investment style or strategy. We do not give any advice or make any representations through the Site as to whether any security or investment is suitable to you or will be profitable. The investments and strategies discussed hereon may not be suitable for all investors, and are not obligations of or guaranteed by Tudor. Nothing on the Site is intended to be, and you should not consider anything on the Site to be, investment, accounting, tax or legal advice. If you would like investment, accounting, tax or legal advice, you should consult with your own financial advisors, accountants or legal advisors regarding your individual circumstances and needs. Decisions based on use of the Site are the sole responsibility of the user, and you agree that Tudor is not liable for any action you take or decision you make in reliance thereon. For investors in the UK, the information on this Site is issued by us only to and/or is directed only at persons who are Exempt Persons and is therefore exempt from the UK Financial promotion restriction on the communication of invitations or inducements to participate in unregulated collective investment schemes. To the extent that any funds or products are referred to on this Site, they are available only to such persons and other persons should not act or rely on the information available on this Site.

Tudor provides investment advice and solicits investment advisory services only in those states and countries where it is registered or where it is exempt from such registration.

7. Past Performance. Any performance data or comments expressed on this Site or in the Content are an indication of past performance. Investments described or referred to on the Site are included solely as examples of Tudor investments and are for illustrative purposes only. There can be no assurance that such investments are or will be profitable (or that any Tudor investments will have similar properties to any such investments made at other firms). Such investments are not representative of all Tudor investments and are not to be considered a complete list of all investments made by Tudor. THE PAST PERFORMANCE OF ANY FUND IS NOT INDICATIVE OF FUTURE PERFORMANCE, and no representation is being made that any investment or transaction will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided.

8. Forward-Looking Statements. The Site contains forward-looking statements, which reflect our current views with respect to, among other things, the operations and performance of our businesses. You can identify these forward-looking statements by the use of words such as “outlook,” “believe,” “expect,” “potential,” “continue,” “may,” “should,” “seek,” “approximately,” “predict,” “intend,” “will,” “plan,” “estimate,” “anticipate” or the negative version of these words or other comparable words. Forward-looking statements are subject to various risks and uncertainties, speak only as of the date on which they are made and are subject to change. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from those indicated in these statements. Forward-looking statements are not guarantees of the underlying expected actions or future performance and future results may differ significantly from those anticipated by the forward-looking statements. We undertake no obligation to publicly update or review any forward-looking statement, whether as a result of new information, future developments or otherwise.

9. Risks in relying on the Content. Any Content that is dated speaks only as of the date indicated. We make reasonable efforts to provide accurate Content on the Site, but at times we may not promptly update or correct the Site even if we are aware that it is inaccurate, outdated or otherwise inappropriate, whether as a result of new information, future developments or otherwise. While we believe that the information on the Site is reliable, we make no representations or warranties, whether express or implied, that the content on the Site is accurate, complete or up to date. You agree that we may change all or any portion of the Site at any time without notice to you and that we are not liable for any action you take or decision you make in reliance on any Content. Further, we do not endorse the opinions of, or warrant the accuracy of facts or other Content contributed by, any third party.

10. Confidentiality of Content. All information and Content available through any restricted areas of the Site are confidential and proprietary to us. This includes all investment information and results, offering materials, financial statements and other information provided through the Site. You undertake to treat any such information and Content on the Site as secret and confidential and will not disclose such information and Content on the Site to any third party except as expressly set forth in these Terms and Conditions or permitted by us in writing.

11. Technological problems with the Site. All or any portion of the Site may not be available and may not function properly at any time. Tudor makes reasonable efforts to avoid technological problems, but at any time the Site may have and may cause technological problems such as viruses and other damaging computer programming routines or engines. You are responsible for configuring your information technology, computer programmes and platform to access the Site. You should use your own virus protection software. You agree that Tudor is not liable for any damage or injury caused by the performance or failure of performance of all or any portion of the Site or any defects, delays or errors in or resulting from your use of the Site.

You must not misuse the Site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Site, the server on which the Site is stored or any server, computer or database connected to the Site. You must not attack the Site via a denial-of-service attack or a distributed denial-of service attack. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the Site will cease immediately.

12Third Party Content. Tudor does not review or monitor the Content of and is not responsible for any third party website content nor any Content on the Site that is produced by users, publishers, and other third parties not controlled by Tudor. You acknowledge that such content is the sole responsibility of the third party person or organization that created it, and we assume no responsibility for any third-party content or information. If you access any third party website through the Site or otherwise, you do so at your own risk, and Tudor makes no warranties, express, statutory, or implied, with respect to such third party content or information. Hyperlinks to or from the Site do not necessarily constitute third party endorsement, sponsorship, representation or warranty or affiliation of, with or by Tudor with respect to any such linked websites or the content, products or services contained or accessible through such websites or their operators. We have no control over the contents of those websites. These Terms and Conditions do not govern your use of any site or service other than the Site. You should review applicable terms and policies of any linked third party content, information or websites. TUDOR DISCLAIMS RESPONSIBILITY FOR THE PRIVACY POLICIES AND CUSTOMER INFORMATION PRACTICES OF THIRD-PARTYWEBSITES HYPERLINKED FROM THE SITE. If you link other websites to the Site, you may not imply or suggest that Tudor has endorsed or is affiliated with such websites, and you may not display the Site as “framed” within another website. Tudor reserves the right to terminate any link or linking program at any time. Similarly, links or copies of third party articles regarding Tudor, its affiliates or its portfolio companies have generally been prepared without the input of Tudor and are provided for convenience purposes only. By inclusion on the Site, Tudor does not represent or warrant the accuracy of such information or take responsibility for its content.

13Monitoring and recording activity on the Site. Tudor may: (i) monitor and record activity on the Site in accordance with applicable law and/or our Cookies Policy); (ii) investigate any complaint or reported violation of our policies; (iii) report any activity that we suspect may violate any law or regulation to regulators, law enforcement officials or other persons or entities that we deem appropriate; or (iv) issue warnings, suspend or terminate use of the Site, deny access to all or part of the Site or take any other action that we deem appropriate.

14. Rules about linking to the Site. You must not establish a link to our Site for any reason and including doing so in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

15Privacy Policy. Your privacy is important to us. All personal nonpublic information that we gather from you will be governed by our Privacy Notice (as amended from time to time).

16Disclaimer of warranty. The Site, including all Content, services and information are provided “as is” and “as available.” Tudor disclaims all representations and warranties, express or implied, of any kind with respect to the Site and the Content including warranties of merchantability, fitness for a particular purpose and non-infringement of intellectual property and proprietary rights. Without limiting our general disclaimer, Tudor does not warrant the availability, reliability, accuracy, completeness or timeliness of the Site or the Content. Tudor does not warrant that any part of the Site will operate uninterrupted or error-free or that defects will be corrected. You have certain statutory rights under the applicable laws of the United Kingdom. Nothing in these Terms and Conditions is intended to affect these statutory rights.

17Limitation of liability.

17.1. Except as otherwise provided under clauses 17.2 and 17.3, if we breach these Terms and Conditions, we will only be liable for losses which are a reasonably foreseeable consequence of that breach, up to an amount equivalent to £1,000. Losses are foreseeable where they could be contemplated by you and us at the time of you agreeing to these Terms and Conditions. Except as otherwise provided under clauses 17.2 and 17.3, in no event will the liability of Tudor or its officers, directors, partners, managers, members, employees, agents, distributors and licensees (collectively, “Tudor Personnel”) include losses related to any business of yours such as lost data, lost profits or business interruption however caused arising out of these Terms and Conditions, the Site, the Content, the inability to use the Site, or transactions entered into through the Site. Except as otherwise provided under clauses 17.2 and 17.3, this disclaimer of liability applies to any and all damages or injury, including those caused by any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communication line failure, theft, destruction or unauthorized access to, alteration of or use of any asset, whether for breach of contract, tortious behavior, negligence or under any other cause of action.

17.2. You have certain statutory rights under the applicable laws of the United Kingdom. Nothing in these Terms and Conditions is intended to affect these statutory rights.

17.3. We do not exclude or limit in any way our liability to you where it would be unlawful to do so or in the case of Tudor Capital Europe LLP’s liability to its customers, under the regulatory system in the United Kingdom.

18Indemnification. You agree to indemnify, defend and hold harmless Tudor and all Tudor Personnel from and against any and all suits, losses, claims, demands, liabilities, damages, costs and expenses (including reasonable attorneys’ fees) that arise from or relate to your misuse of the Site in material violation of these Terms and Conditions.

19. International Use. Because this Site may be accessible internationally, you agree to comply with all local laws, rules, and regulations including, without limitation, all laws, rules, and regulations in effect in the country in which you reside and the country from which you access the Site. The information on this Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or would subject Tudor to any registration requirement within such jurisdiction or country.

20Governing Law.

20.1. You agree that any dispute arising out of or relating to your use of the Site or relating to these Terms and Conditions shall be governed and construed in accordance with: (i) if you are resident anywhere in the world other than in the UK, the laws of the United States and the State of New York, without giving effect to conflicts-of-law thereof; or (ii) if you are resident in the United Kingdom, relevant United Kingdom law will apply to these Terms and Conditions.

20.2. If you are resident anywhere in the world other than in the United Kingdom, you agree to submit to the personal jurisdiction of the state and federal courts located in New York County, New York, with respect to any legal proceedings arising out of or relating to your use of the Site or relating to these Terms and Conditions and waive any objection to the propriety or convenience of venue in such courts. If you are resident in the UK, the relevant courts of the United Kingdom will have exclusive jurisdiction with respect to any legal proceedings arising out of or relating to your use of the Site or relating to these Terms and Conditions.

20.3. As a consumer, you will benefit from any mandatory provisions of the law of the country in which you are resident. Nothing in these Terms and Conditions affects your rights as a consumer to rely on such mandatory provisions of local law.

21. Suspension or withdrawal. We do not guarantee that the Site, or any Content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of the Site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.

22. Termination. Notwithstanding anything in these Terms and Conditions or on the Site, Tudor reserves the right, without notice and in its sole discretion, to terminate your license to use the Site, and to block or prevent your future access to and use of the Site or any other Site operated by Tudor. Where possible, we will try to give you reasonable notice of any termination.

23. Complete Agreement. These Terms and Conditions, our Privacy Notice and Cookies Notice constitute the entire agreement between you and Tudor relating to the Site, and supersede any prior agreements or understandings, written or oral, not incorporated. Certain restricted areas of the Site may require you to agree to supplemental terms and conditions. These Terms and Conditions are not intended to modify or amend Other Agreements you may have with Tudor regarding other matters, and in the event of any inconsistency between these Terms and Conditions and any Other Agreements, the Other Agreements will govern.

24. Miscellaneous. If a portion of these Terms and Conditions is determined to be unlawful, void or unenforceable, it will not affect the enforceability of the remaining provisions and the remaining provisions will continue in effect.  If any unlawful and/or unenforceable provision would be lawful or unenforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect. Headings used in these Terms and Conditions are for reference purposes only and in no way define or limit the scope of the section.

PRIVACY

September 2023

The Tudor Group (comprised of a number of companies under common control, including but not limited to Tudor Investment Corporation (“TIC”), Tudor Capital Europe LLP (“TCE”), Tudor Capital Australia Pty Ltd (“TCA”), Tudor Capital Singapore Pte. Ltd. (“TCS”), Tudor Capital France S.A.S (“TCF”), their affiliated companies (collectively, “Tudor”, “our”, “we” or “us”) are committed to respecting your privacy and will only collect and use your personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under applicable Privacy Laws.

About this privacy notice

This privacy notice describes how Tudor collects, uses and discloses the information you provide to us and the information we collect in the course of operating our business and our website.

This privacy notice applies to all natural persons whose personal data Tudor handles and who are not covered by either our Investor Privacy Notice or our Employee Privacy Notice and: (i) have had contact with Tudor for business purposes, either on their own account or on behalf of third parties; (ii) are employed by or otherwise associated with Tudor’s suppliers, vendors or professional advisors; (iii) individuals who are involved in transactions or potential transactions which are evaluated or conducted by Tudor or its sub-advisors; (iv) individuals that have had contact with Tudor during a recruitment process, and (v) individuals who have opted to receive communications from Tudor. It does not apply to your use of Tudor’s financial services, including any investments. Users of our financial services should refer to our Investor Privacy Notice.

The privacy notice sets out:

  • the basis on which any personal data that you provide to us, will be collected, used, disclosed and processed by us;
  • the purposes for which we will process such data;
  • your privacy rights under applicable privacy laws from time to time in force, including, where applicable, under the General Data Protection Regulation (the “GDPR”), the Cayman Islands Data Protection Act (2021 Revision), Singapore’s Personal Data Protection Act 2012, California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020), the UK GDPR and Data Protection Act 2018 (together, the “Privacy Laws”); and
  • how we protect your personal data.

Maintaining your privacy is important to us and we hold ourselves to high standards in the safekeeping and use of your personal data. Please take the time to read and understand this privacy notice, together with any other privacy notice we will provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information. This privacy notice does not form part of any contract of employment or other contract to provide services.

For the purposes of relevant Privacy Laws, the relevant Tudor company with which you are dealing with, as applicable, is the controller in respect of your personal data and so responsible for this privacy notice. This means that we are responsible for deciding how we hold, disclose and use your personal data and for ensuring that we use your personal data in compliance with the relevant Privacy Laws.

Where required, the Tudor Group companies have each designated Tudor Capital France S.A.S. to act as their representative in the European Union, and Tudor Capital Europe LLP to act as their representative in the UK, for the purposes of Article 27 of the GDPR and UK GDPR respectively. They can be contacted using the details in the “Contacting Us” section below.

Data protection principles

We will comply with the Privacy Laws. If you are located in the UK, Europe or other equivalent jurisdiction, this says that the personal data we hold about you must be:

  1. used lawfully, fairly and in a transparent way;
  2. collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  3. relevant to the purposes we have told you about and limited only to those purposes;
  4. accurate and to the extent appropriate, kept up to date;
  5. kept only as long as necessary for the purposes we have told you about; and
  6. kept securely.

Personal data that we collect about you

“Personal data” is any information that can be used to identify you or that we can link to you and which we have in our possession or control. It does not include anonymous data.

From time to time, we will collect, use, disclose and process your personal data in order to manage our relationship with you effectively, lawfully and appropriately. The personal data will be collected as follows:

  • When you contact us with queries or respond to our communications the personal data you provide will include your full name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.
  • If you are a prospective or current service provider of Tudor, you will provide us with personal data when you or the company you represent becomes a service provider. We will also collect information you have allowed to be publicly available.
  • When you are involved in a transaction or potential transaction with Tudor, you will provide us with personal data which includes, but is not limited to: your business and personal contact details, professional opinions and results of due diligence that is carried out.
  • When you apply for a role with us (directly or via a recruitment agency or via a recommendation), depending on which office you apply to, you will need to provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, remuneration details, photograph, passport details, driving licence details, marital status, home address (including proof) and home telephone number, mobile telephone number, immigration status and evidence about your entitlement to work in the location of the vacancy and other details set out in your application. We will also collect information you have allowed to be publicly available.
  • Visitors to Tudor’s offices (CCTV, access key card, guest book, dietary preferences for meetings/events etc.).
  • People Tudor does business with, excluding investors (KYC/DD/AML activities etc.).
  • Information collected automatically on our website - For information about how we use cookies and similar technologies, refer to our Cookie Notice. Our website does not respond to Do Not Track Signals.

Please note, you are under no obligation to provide us with personal data when applying for a role with us. However, if you do not prove/provide certain information when requested, we will not be able to process your application for employment properly or at all.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for you if this information is not provided.

There are more sensitive types of personal information which require a higher level of protection under certain applicable laws. We do not collect such more sensitive information about you except for information about religious beliefs in the context of dietary requirements, and, where applicable, health information in the event that you require special assistance or we have to give you first aid on site for events and meetings that you voluntarily provide to us. Nor do we collect any information about criminal convictions and offences unless revealed by due diligence conducted to comply with a legal obligation or given to us in connection with our role, or potential role, as financial adviser in connection with a transaction, in order to comply with a legal obligation.

Legal basis for processing your personal data

Your personal data will be collected, used, stored, disclosed and/or processed by us in the following ways:

  • use it as part of our business relationship;
  • where you have applied for a position with us directly or through a recruitment agency, to review and process your job application;
  • making a decision about your recruitment or appointment;
  • to comply with legal and regulatory obligations that we, or one or more of our affiliates have to discharge;
  • use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  • record and monitor your use of our websites or our other online services for our business purposes which will include analysis of usage, measurement of site performance and generation of marketing reports;
  • use it for our legitimate business interests, such as performing transactions, undertaking business research and analysis, managing the operation of our websites and our business;
  • processing, evaluating, and communicating with you about your job application and communicate with you about other jobs that will interest you;
  • use it to look into any complaints or queries you will have;
  • in the event that we sell or buy, or one or more of our affiliates sells or buys, any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if we or our assets, or one or more of our affiliates or our affiliates assets’ are acquired by a third party, in which case personal data held by it about its clients may be one of the transferred assets;
  • in order to enforce or apply our terms of use and other agreements or to protect our rights, our customers or others; or
  • use it to prevent and respond to actual or potential fraud or illegal activities.

Also, we will collate, process and disclose any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.

We rely on the following legal grounds to process your personal data, namely:

  • Consent – we will (but usually do not) need your consent to use your personal data. You can withdraw your consent at any time by contacting us (see below).
  • Performance of a contract – we will need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you.
  • Legitimate interest – we will use your personal data for our legitimate interests, some examples of which are given above.
  • Compliance with law or regulation – we will use your personal data as necessary to comply with applicable law/regulation.

Disclosure of your information to third parties

We will disclose your personal data internally and with employees, agents or contractors of our affiliates, including international offices (“Authorised Individuals”) where it is necessary to fulfil the purpose for which it was collected. As a result, your personal data will be transferred to locations outside of the locations in which our offices are located (including locations outside the UK, EU/EEA and Singapore) as well as within those locations for the purposes described above.

We will take steps to ensure that the personal data is accessed only by Authorised Individuals that have a need to do so for the purposes described in this notice and that the Authorised Individuals use your personal data in accordance with Privacy Laws.

We will also disclose your personal data to third parties outside of our corporate group for the following purposes:

  • to third party agents and contractors for the purposes of providing services to us, including, IT and communications providers, law firms, accountants and auditors and recruitment agencies. These third parties will be subject to confidentiality and data protection requirements and they will only use your personal data as described in this privacy notice;
  • to third parties relevant to the investment management services that we provide. This will include, but is not limited to, counterparties, current investors regulators, authorities, governmental institutions and stock exchanges;
  •  to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation; and
  • in order to establish, exercise or defend our legal rights.

International transfers of personal data

The personal data that we collect from you will be transferred to, and stored at, a destination outside your home country. It will also be collected, used, disclosed and processed by individuals operating outside of your home country who work for us, our affiliates or for one of our suppliers.

Where we transfer your personal data outside of the jurisdiction or area in which it was collected, we will ensure that it is protected and transferred in a manner consistent with applicable Privacy Laws. This can be done by implementing one of the following appropriate safeguards:

  1. The country that we send the data to is approved by the European Commission as offering an adequate level of protection. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  2. The recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  3. We will enter into a data transfer agreement with the recipient.
  4. Where we use third-party service providers based in the US, we will transfer data to them if they are part of the EU-US Data Privacy Framework (or any future scheme which requires them to provide similar protection to personal information transferred between the Europe and the US, as and when this is approved by the US and the EU). For further details, see the Data Privacy Framework website and European Commission: EU-US Data Transfers.

In other circumstances, the law will permit us to otherwise transfer your personal data outside the jurisdiction or area in which it was collected. In all cases, however, any transfer of your personal data will be compliant with applicable Privacy Laws.

You can obtain more details about the protection given to your personal data when it is transferred outside your home country by contacting us using the details below.

Personal data security

We will ensure that the personal data that we hold is subject to appropriate security measures.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Retention of personal data

We will only hold your personal data for as long as is necessary to fulfil the purposes for which we collected it. The retention period will be determined by the following criteria:

  • the purposes for which we process your personal data;
  • the establishment, exercise or defence of Tudor’s rights, which will require us to store your personal data as archives;
  • the amount, nature, and sensitivity of the personal data;
  • the potential risk of harm from unauthorised use or disclosure of your personal data; and
  • legal obligations – laws or regulation will set a minimum period for which we have to keep your personal data

Job Applications

If you are unsuccessful, we will retain within our internal and/or external HR database your CV, or job application and any related ancillary documentation (for example, interview notes) for 12 months unless, following an unsuccessful application, you specifically consent to us holding it for longer for the purpose of contacting you in the event that any similar jobs / roles become available, from time to time, or we are required to do so for compliance with applicable laws or regulations.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and we shall issue a new privacy notice which sets down how we will collect, use, disclose and process your personal data and your rights in relation to this, including the periods for which your personal data will be held.

Change of purpose

To the extent required by relevant Privacy Laws, we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 Please note that we will if necessary process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes and will only do so if we have a lawful basis and in accordance with Privacy Laws

Your rights

It is important that the personal information we hold about you is accurate. We ask that you keep us informed if your personal information changes during the course of your relationship with us.

You will have a number of legal rights in relation to the personal data that we hold about you and you can exercise your rights by contacting us using the details set out below. Under certain circumstances, and depending on applicable Privacy Laws, these rights will include:

  • obtaining information regarding the processing of your personal data and access to the personal data which we hold about you (please note that there will be circumstances in which we are entitled to refuse requests for access to copies of personal data. In particular, information that is subject to legal professional privilege will not be disclosed.);
  • requesting that we correct your personal data if it is inaccurate or incomplete;
  • requesting that we erase your personal data in certain circumstances. Please note that there will be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
  • objecting to, and requesting that we restrict, our processing of your personal data in certain circumstances. Again, there will be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request;
  • in some circumstances, receiving some personal data in a structured, commonly used and machine-readable format and/or requesting that we transmit that information to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
  • to stop direct marketing;
  • withdrawing your consent, although in certain circumstances it will be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so;
  • lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us;
  • in certain jurisdictions like France, you have the right to provide directives on the processing of your personal data after your death; and
  • to be informed about the purposes for which your personal data is processed.

You can exercise your rights by contacting us using the details set out below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we will charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we will refuse to comply with the request in such circumstances.

We will need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

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California consumers

Whilst the categories of personal data we collect, the sources of that personal data, the business and commercial purposes for which we collect it, who we disclose it to, and how long we retain it, are set out in the sections above, California law requires that we use certain categories specific to California law:

Category of personal data:  Identifiers

Examples as defined in California law:  Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Collected?  Yes

Category of personal data:  Personal information categories listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e)

Examples as defined in California law:  Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Collected?  Yes

Category of personal data:  Protected classification characteristics under California or federal law

Examples as defined in California law:  Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected?  Yes

Category of personal data:  Commercial information

Examples as defined in California law:  Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected?  Yes

Category of personal data:  Biometric information

Examples as defined in California law:  Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected?  No

Category of personal data:  Internet or other similar network activity

Examples as defined in California law:  Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Collected?  No

Category of personal data:  Geolocation data

Examples as defined in California law:  Physical location or movements.

Collected?  No

Category of personal data:  Sensory data

Examples as defined in California law:  Audio, electronic, visual, thermal, olfactory, or similar information.

Collected?  No

Category of personal data:  Professional or employment-related information

Examples as defined in California law:  Current or past job history or performance evaluations.

Collected?  Yes

Category of personal data:  Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Examples as defined in California law:  Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected?  No

Category of personal data:  Inferences drawn from other personal information

Examples as defined in California law:  Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected?  No

Category of personal data:  Sensitive personal information

Examples as defined in California law:  Social security, driver’s license, state identification card, or passport number; user name, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; contents of consumer’s mail, email, and text messages unless we are the intended recipient of the communication; processing of biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.

Collected?  Yes

In the preceding 12 months, we have collected and used Personal data in the manner described above and we may have disclosed to the categories of third parties listed under “Disclosure of your information to third parties”, for the purposes there provided, all of the categories of Personal Data as described above. We will not discriminate against you for exercising consumer rights.

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what Personal Data is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not share Personal Data with outside parties for their direct marketing.

You must provide us with enough information that we can verify your identity and that you are a California resident. If you designate an authorized agent to make an access or deletion request on your behalf, we will require the agent to show written authorization from you and require you to verify your identity with us.

We have not “sold” personal information as defined by the CCPA. For this purpose, “sold” or “sale” means the disclosure of personal information for monetary or other valuable consideration but does not include, for example, the transfer of personal information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

We have not “shared” personal data as defined by the CCPA. For this purpose, “share”, “shared” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, your personal data in writing or by electronic or other means, to third parties for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions in which no money is exchanged.

We do not use personal data for automated decision-making or data profiling.

Supervisory Authorities

You can find out more information about your rights by contacting the applicable supervisory authority below:

We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or, if applicable, the exercise of any of the rights listed above, please address questions, comments and requests to the

Tudor Group Data Privacy Team:

Tudor Investment Corporation        

200 Elm Street, Stamford, CT 06902                         

Telephone: +1 203 863 8677   

Email: dataprivacy@tudor.com    

   

Tudor Capital Australia Pty Ltd      

c/o DLA Piper Australia

Level 22

1 Martin Place

Sydney NSW 2000 Australia

Email: dataprivacy@tudor.com

 

Tudor Capital Europe LLP    

10 New Burlington Street              

London W1S 3BE      

United Kingdom      

Telephone: +44 207 518 5151     

Email: dataprivacy@tudor.com

 

Tudor Capital Singapore Pte. Ltd.       

Marina One West Tower

08-10 at 9 Straits View

Singapore 018937

Phone: +65-6932-6270             

Email: dataprivacy@tudor.com            

 

Tudor Capital France S.A.S,

12 Place Dauphine, 75001 Paris,

Email: dataprivacy@tudor.com

 

Changes to this Privacy Notice

Tudor may change this privacy notice from time to time by posting an updated version on its website. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes to this privacy notice will apply to you and your data immediately.

 

 

 

RESOURCES

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.