Privacy Notice
Last updated: 3rd of July, 2025
Your privacy is very important to us. This Privacy Notice describes how Asymmetry Point Capital LLC (“APC” “we,” or “us”) collects, uses, shares, and protects your personal information. It also describes certain choices you may have with regards to your personal information under applicable law. Please read this notice carefully to understand what we do.
Information We Collect
How We Collect Information
How We Use Information
How We Share Information
Your Choices
Automated Decision-Making
How We Protect Information
How Long We Retain Information
International Transfers of Information
Changes to this Privacy Notice
Contact Information
Information We Collect
We collect different types of personal information about you depending on how you interact with us and our services. The information we collect may include:
Context Types of Information Primary Purpose for Collection and Use of Information
Account Registration and Management We collect names, residential addresses and other contact details (phone, fax, email), signature, and we may collect some or all of the following: nationality, passport number, tax identification number, date of birth, place of birth, photo ID, copies of government issued identification documents, bank account details, account balances and transaction information, information about assets or net worth, credit history, or source of funds details. We collect this information to fulfill our contract to provide our investor services and to comply with legal and regulatory obligations. We have a legitimate interest in providing account related functionalities to our investors. We have a legitimate interest in managing and administering services to our current, prospective, and former investors.
Demographic Information We may collect information such as your age or location. We have a legitimate interest in understanding our investors. We also may need to collect this information to comply with legal and regulatory obligations.
Web logs and First Party Cookies We collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the internet), domain name, click-activity, referring website, and/or a date/time stamp for your visit. We have a legitimate interest in monitoring and operating our networks and website.
How We Collect Information
We collect your personal information in different ways. For example, we collect personal information:
• Directly from you. This includes when you complete forms on our website or correspond with us by mail, phone, email, or otherwise; open an account, seek advice about your investments, tell us about your investment portfolio.
• From third parties or other sources. These can include our affiliates, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources.
How We Use Information
We may use the personal information we collect for the following purposes:
• To provide support, personalize, and develop our website and services.
• To communicate with you, including in response to your inquiries and to fulfill your requests, including investigating and addressing your concerns and to monitor and improve our responses.
• To provide our services to you.
• To conduct analytics.
• To detect and prevent security incidents.
• To debug, find, and fix errors that impair our website and services.
• For business purposes, including to operate and improve our business and business activities; to manage our relationships; to detect and prevent malicious, deceptive, fraudulent, or illegal activity; and for any other business purpose permitted by law.
• For legal and safety purposes, including to enforce our policies and agreements; to establish or exercise our rights; to defend against legal claims; to respond to court orders, lawsuits, subpoenas, and government requests; to address legal and regulatory compliance; and as otherwise permitted or required by applicable law.
• For other purposes with your consent and as permitted by applicable law.
How We Share Information
All financial companies need to share customers’ personal information to run their everyday business. Below is a list of the ways we share personal information and whether you can limit such sharing. We may share your personal information:
• For our everyday business purposes (such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus). You cannot limit this sharing.
• For our marketing purposes (to offer our products and services to you). You can sometimes limit this sharing.
• For our affiliates’ everyday business purposes (such as information about your transactions and experiences). You cannot limit this sharing.
We do not share your personal information with our affiliates for direct marketing purposes. We do not share your personal information with non-affiliates except as required or permitted by law. We do not share your personal information with non-affiliates for them to market to you, and we do not share your personal information for joint marketing with other financial companies.
In addition to the specific situations discussed above, we may disclose personal information in the following situations:
• Affiliates. We may share information with our affiliates (e.g., companies related by common ownership or control).
• Business Transactions. We may disclose information to a buyer or other successor in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, including at the negotiation stage.
• Service Providers. We may share information with service providers who perform services on our behalf and/or help with our business activities. Among other things, service providers may help us to administer our website, assist or support our business operations, provide technical support and information technology and security programs, conduct research and analysis.
• Professional Services. We may share information with our professional service providers, such as auditors or lawyers.
• Other Third Parties. We may disclose information to cooperate with law enforcement, participate in a legal process, or for legal compliance. We may disclose your information to establish or exercise our rights, to defend against legal claims, to investigate, prevent, or act on possible illegal activities, threats to safety of person or property, or a violation of our policies.
• Other Disclosures with Your Consent. We may share your information with third parties when you consent or direct us to.
Your Choices
Subject to applicable law, individuals in certain jurisdictions may make the following choices regarding their personal information:
• Access to Your Personal Information. You may request access to your personal information or confirmation that we are processing your personal information. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. You may also have the right to data portability.
• Deletion of Your Personal Information. You may request that we delete your personal information. If required by law, we will grant a request to delete your personal information, but you should note that in many situations we must keep your personal data to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
• Objection to or Restriction of Certain Processing. In certain circumstances, you may object to our processing of your personal information, or request that we restrict processing of your personal information. We will no longer process your personal information unless we have compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims. Note that you can object to processing for direct marketing purposes.
• Revocation of Consent. Where we process your personal information based on consent, if you revoke or restrict your consent, we may no longer be able to provide you services.
• Right to compensation for damage and to make a complaint. Under certain data protection laws, you may have the right to be informed of a personal information breach (unless the breach is unlikely to be prejudicial to you) and may have a right to compensation for any damage that occurred because of a personal information breach. Where you feel that your rights are not being respected, you may submit a complaint to the Office of the Ombudsman of the Cayman Islands or your appropriate supervisory authority.
• Limit Sharing of Your Personal Information. In certain circumstances, you may limit the sharing of your personal information with nonaffiliated third parties. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws and applicable foreign jurisdictions may give you additional rights to limit sharing. To request that we limit sharing where permitted, please contact us using the information below.
• Unsubscribe From Marketing Communications. You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you or by contacting us using the details in the “Contact Information” section below.
Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may exercise the above rights by contacting us using the details in the “Contact Information” section below.
Automated Decision-Making
We will not make decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your personal information, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the applicable data protection law requirements.
How We Protect Information
We maintain commercially reasonable procedures designed to protect your personal information from unauthorized access and use. However, no method of internet transmission or electronic storage is fully secure, and we cannot guarantee the security of your personal information. If we are required to inform you about a security incident, we will do so electronically, in writing, or by phone, as the law permits.
How Long We Retain Information
We keep your personal information for only as long as necessary to fulfil the purposes in this Privacy Notice unless a longer retention period is required or permitted by law. This includes the purposes of satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information. We also weigh the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can meet those purposes through other means, as well as applicable legal requirements.
International Transfers of Information
Because of the international nature of our business, personal information may be transferred to countries outside your country of residence to jurisdictions where we conduct business or have a service provider. This may include countries that may not have the same level of data protection as that afforded by the applicable data protection laws in your country of residence, including, but not necessarily limited to, the United States. In such cases, we will process personal information (or procure that it be processed) in such countries in accordance with the requirements of applicable data protection laws.
Changes to this Privacy Notice
We may update our Privacy Notice from time to time to reflect changes to our practices, technology, legal requirements and other factors. If changes are material, the Privacy Notice that was in place when you submitted personal information to us will generally govern that information unless you consent to the new Privacy Notice. You can check the “Last Updated” legend at the top of this page to see when this Privacy Notice was last revised.
Contact Information
If you have questions, comments, or complaints about our privacy practices, please contact us at: [email protected].