Martingale Website Privacy Notice

We at Martingale Asset Management, L.P. (“Martingale”) recognize and appreciate the importance of respecting the privacy of our customers. This Privacy Notice provides information about our collection and use of personal information on our website, www.martingale.com (the “Site”).

Current, prospective, and past customers who are individuals will receive a separate Customer Privacy Policy. In the event of any conflict with the terms of our Customer Privacy Policy, the terms of the Customer Privacy Policy will apply.

As used in this Website Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Information We Collect

This Site does not directly collect any personal information unless you complete our “Contact Us” form, which collects your name, company, phone number, email address, and any other information that you choose to provide to us. Please do not provide personal information that you do not want us to have.

In addition, we may gather information about you automatically through your use of the Site, e.g., your IP address, operating system, device details, referring URL, and how you navigate our Site.  We use this information for purposes including improving our website and services, diagnosing problems with our Site or servers, detecting and preventing fraud or cybersecurity threats, reporting aggregated information, and otherwise administering the Site.

Cookies and Similar Technologies
We may collect information about you by using cookies, tracking pixels, web beacons and other technologies (collectively, “Tools”). We may use this information to better understand, customize and improve the user experience of our websites, services and offerings.

Your web browser can be set to allow you to control whether you will accept cookies. If your browser is set to reject cookies, the Site may not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies.

How We Use the Information We Collect

Where you provide information to us, the information is used for the purpose you provided it to us. For example, if you provide your contact information in an inquiry to us, we will use your contact information to process and respond to that inquiry and any related activity that may result from your inquiry. 

We may process your personal information for other business purposes, including the following:

  • Where necessary for the purposes of our legitimate business interests, including to respond to your messages and inquiries, operate and facilitate our business and services; administer and improve the Site; provide investment advisory services; communicate with you; as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets; administer and maintain our records; protect our rights, property and interests; ensure the security of our assets, systems and networks; prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services; and enforce our terms and conditions;
  • Where required by applicable laws and regulations, including laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions, and to comply with valid legal process, including a search warrant, subpoena or court order; and
  • Where the processing is necessary for the establishment, exercise or defense of legal claims.

How We Disclose the Information We Collect

We may disclose your personal information to our affiliates for the purposes described in this Privacy Notice. We may disclose personal information to service providers that perform services on our behalf such as analytics providers and hosting providers.

In addition, we may disclose personal information about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (d) in the event that we sell all or part of our business or makes a sale or transfer of assets or are otherwise involved in a merger, restructuring or business transfer.

Links to Third-Party Websites

Should you leave this website via a link contained herein, and view content that is not provided by Martingale, you do so at your own risk.  This Privacy Notice does not apply to other websites that may be linked to on the Site. Should you choose to visit those websites or applications, you should review their privacy policies to ensure that you are comfortable with them.

Security

While we use precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf and cannot guarantee that this information will not be accessed, disclosed, altered, or destroyed.  You should not supply us with sensitive information via our “Contact Us” form and should instead send such information, if necessary, using secure communications.

Contact Us

If you would like to contact us for any reason concerning our privacy practices, please email us at information@martingale.com.

Updates to This Privacy Notice

We may change or update portions of this Privacy Notice at any time without notice to you. Please check back from time to time so you are aware of any changes or updates to the Privacy Notice. The revision date appearing on the first page of this Privacy Notice underneath the title will identify the date of the last update or revision.

Last modified: June 2024