Privacy Policy

Manage My Privacy

This is the Privacy Policy for the website maintained by EnTrust Global and its affiliates, and localized versions of that site as applicable (collectively “EnTrust Global”, and such website, the “Website”) and applies to all entities within the EnTrust Global group. We respect your privacy and appreciate the confidence you have placed in the Website. We are committed to protecting your privacy and preserving your trust. Please carefully review this Privacy Policy to learn about how we collect, use, and protect any personal information you provide us and your choices for managing your personal information. This Privacy Policy is subject to the Terms of Use posted on the Website.

What Types Of Personal Information Do We Collect?

We may collect information about you through the Website as described below:

  • We collect information that may personally identify you (such as your name, address, telephone number, email address, billing information, or other data which can be reasonably linked to such information). For example, we may collect personal information from you when you register on the Website or subscribe to one of our services. The decision to provide this information is optional; however, if you decide not to register or provide such information, you may not be able to use certain features of the Website or other services.
  • We may automatically collect information that does not identify an individual user, such as IP (internet protocol) address, ISP (internet service provider), the web browser used to visit the Website, the time the Website is visited, which Website pages were visited, a unique mobile device identifier (in connection with the use of the Website or related services from mobile devices) and other anonymous Website usage data.
  • We also may use cookies (a small file containing a string of characters that uniquely identifies your web browser) and web beacons (an electronic file placed within a web site that monitors usage). These tools store information about your navigation through our Website (such as pages already visited, time and date of visit) which we can remember during your next visit to our Website in order to improve your browsing experience. Most web browsers are initially set up to accept cookies, but you can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Website may not work if you delete or disable cookies.

How Do We Collect this Information?

We typically collect personal information about you when you provide it to us through your registration on our Website.  We may also collect personal information through the use of cookies as described above.

In addition, we may receive personal information about you from third parties, such as:

  • Public sources or information vendors; and
  • Introducers or other intermediaries who market or provide services to you.

How Do We Collect this Information?

The information collected will be used to facilitate your registration on the Website and will be used by EnTrust Global and its Services Providers (as defined below) to provide services to you. In providing personal information to EnTrust Global, you are agreeing to the use of such information by EnTrust Global and its applicable worldwide affiliated companies, as stated in this Privacy Policy. We request personal information for a variety of purposes throughout your interaction with EnTrust Global, some of which are listed below:

  • Contacting you or your designated representative by phone, email, fax, or mail;
  • Providing you or your representative with marketing communications;
  • Creating and managing your account with us;
  • Sharing information about our services, including investment research;
  • Facilitating financial transactions related to your account;
  • Fulfilling our legal and regulatory obligations;
  • Performing obligations under any applicable agreements;
  • Facilitating administrative processes (and related communication) carried out within EnTrust Global in providing services;
  • Communicating with you and/or your designated contacts on an ongoing basis;
  • Conducting ongoing administrative, reporting and other processes and communication required to operate the business in accordance with the agreements and other applicable documentation between you and EnTrust Global;
  • Complying with any legal or regulatory requirement; and
  • Fulfilling any other purpose that has been notified, or has been agreed, in writing

We may use aggregate information to measure general Website usage patterns and characteristics of our user base, and we may include such aggregate information about our user base in reports to our commercial vendors. We may also disclose aggregated user statistics (for example, a certain percentage of our users live in a certain area) without your permission in order to describe our audience to other third parties. However, this aggregate information does not reference names, phone numbers, e-mail addresses, or other personal information, and it is not traceable to a specific recipient or user e-mail address.

With Whom Will We Share Your Information?

We have policies that limit access to your personal information to only those people who need it to perform their jobs and provide services to you, and we have physical, electronic and procedural safeguards that comply with applicable laws to protect your information from unauthorized access.

We will not sell, share, or rent your personal information to third parties, and we will not otherwise disclose personal information to third parties, without your permission, except as disclosed in this Privacy Policy.

We may disclose the information we collect to third parties that assist us in providing financial services to you, which include, as applicable, the relevant fund’s administrator, distributors, brokers and custodians. From time to time, we disclose your information to persons or entities whom we have asked to assist us to operate our business or provide services to you (“Service Providers“). For example, we may contract with Service Providers to provide certain services including without limitation data management, web hosting, web development, and analytics tools. We provide our Service Providers with the information needed for them to perform these services. Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of your information in order to protect your personal information from unauthorized access, destruction, use, modification, or disclosure and in accordance with applicable laws. We may also disclose information with other non-affiliated third parties who perform services on our behalf or who assist us in providing services to you, such as attorneys and accountants, and as otherwise permitted by law. These third parties may be based in countries outside the European Economic Area (”EEA”) which may not offer the same level of protection of the information transmitted.

We also may share personal information with entities controlling, controlled by, or under common control with EnTrust Global. In the event that EnTrust Global is merged, or in the event of a proposed or actual transfer of the business or assets associated with the Website, we may disclose or transfer your personal information and non-personal information in connection for such transaction to the acquirer of the assets, including for due diligence purposes and to complete the transaction.

In certain instances, we may disclose your personal information when we have reason to believe it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to EnTrust Global or its affiliates, or to others. We may also disclose your personal information when we believe the law or legal process requires such disclosure, to cooperate with regulators or law enforcement authorities, or to protect our rights.

Lawful Basis

There is a need to process personal information for the purposes set out in this Privacy Policy as a matter of contractual necessity under or in connection with the applicable agreement, and in the legitimate interests of EnTrust Global and its affiliates to operate their respective businesses. From time to time, EnTrust Global may need to process personal information on other legal bases, including: to comply with a legal obligation; if it is necessary to protect the vital interests of an investor or other data subjects; or if it is necessary for a task carried out in the public interest. For the purposes listed above, EnTrust Global is relying on performance of a contract necessity and legitimate interests.

A failure to provide personal information requested to fulfill the purposes described in this Privacy Policy may result in EnTrust Global being unable to provide the services in connection with the terms of any subscription agreement, operating agreement or other agreement or arrangement.

Our Site and Use of Cookies

We use various technologies to collect other types of information, including personal information, automatically. The use of your personal information submitted through the Website is necessary for our legitimate business interest in the proper administration of our Website and business and monitoring and improving our Website and services. For example, in order to measure the usefulness and efficiency of our Website pages, we automatically track certain information from all visitors to our Website. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information. We will retain your personal data for as long as you use our Website and for a minimum period of seven years thereafter.

Additionally, like most interactive web sites, EnTrust Global uses “cookies” on certain pages of our Website. “Cookies” are small data files that are stored on your hard drive that store certain information, including certain personal information, accessible to our Website, such as your password and any information content preferences you may voluntarily set at the Website. These technologies help EnTrust Global recognize you, customize your experience on the Website and analyze your use of the Website pages to make them more useful to you. By visiting our Website, you agree to our use of cookies. For more details, please refer to our Cookie Policy.

You can refuse the use of cookies by selecting the appropriate browser setting. If you opt-out, please note that your experience using the Website may not be optimal, and you may not be able to use certain features on our Website. For information on how to remove or manage cookie functions and adjust your privacy and security preferences, access the “help” menu on your internet browser, or visit

EnTrust Global also uses analytics providers, such as Google Analytics to help EnTrust Global evaluate the Website. To opt out of the aggregation and analysis of data collected about you on the Website by Google Analytics, visit and download and install the Google Analytics Opt-out Browser Add-on.

Data Storage and Retention

Your personal information will be retained only for as long as the information is needed to fulfill the purposes for which it was collected and processed. EnTrust Global reserves the right to retain and use your personal information for as long as necessary to comply with its and its affiliates’ legal obligations and business requirements and/or to resolve ongoing disputes and enforce its and its affiliates’ agreements.

Transfers of Personal Information

Your personal information may be transferred, processed and/or stored in a country other than the one in which your personal information is collected. When transferring your personal information to the United States or other countries, EnTrust Global has implemented procedures to ensure that appropriate safeguards are in place to protect the personal information regardless of where it is being transferred.

In addition to disclosing personal information amongst its affiliated companies, EnTrust Global may disclose personal information, where permitted by law, to other Service Providers, prospective or current investors in applicable funds, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfill the purposes described in this Privacy Policy. In addition, EnTrust Global may share personal information with regulatory bodies having competent jurisdiction over them, as well as with tax authorities, auditors and tax advisors (where necessary or required by law, rule or regulation).

EnTrust Global may transfer personal information to a non-equivalent country (a country or territory other than (i) a member state of the EEA; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU law to ensure an adequate level of protection for personal information), in order to fulfill the purposes described in this Privacy Policy and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer agreements, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact the applicable fund general partner.


We use encryption and authentication tools to protect the security of personal information that you share with us. However, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect personal information, we cannot and do not guarantee or warrant the security of any information you transmit to or from the Website, and you do so at your own risk.

Links To Third-Party Websites

The Website may contain links to web sites operated and maintained by third parties, over which we have no control. Privacy policies on such linked websites may be different from our Privacy Policy. You access such linked websites at your own risk. You should always read the privacy policy of a linked website before disclosing any personal information on such site.

General Data Protection Regulation (GDPR)

GDPR (implemented across all European Union member states from 25 May 2018) applies to the collection, processing and storage of personal data undertake by organisations within the European Economic Area (EEA), as well as to firms outside the EEA that handle personal data relating to individuals in the EEA.

The GDPR has two key purposes: (a) to set guidelines for the collection, processing and protection of personal data and (b) to give individuals certain rights in relation to their personal data (such as to access and correct it and object to further processing).

This GDPR notice clarifies certain information that EnTrust Global S.A.S. as EU data controller, must provide under GDPR. It also sets out certain information that EnTrust Global Ltd. must provide under the Data Protection Act 2018, which enacted the provisions of GDPR into UK law and also the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019, which amends the Data Protection Act 2018 and merges it with the requirements of GDPR to form a data protection regime in the UK equivalent to GDPR.  Some of this information is already provided in the above Privacy Policy which sets out the privacy policy for the Website maintained by the EnTrust Global group (of which EnTrust Global Ltd. and EnTrustPermal S.A.S. form part). As such, the following GDPR disclosure should be read in conjunction with the above Privacy Policy.

The Privacy Policy includes a description of the type of personal data EnTrust Global Ltd and EnTrustPermal S.A.S., as data controller, collect from you and how we use that information. The use of your personal data submitted through the Website is necessary for our legitimate business interest in the proper administration of our Website and business and monitoring and improving our Website and services. It may also be used to satisfy any legal, regulatory, accounting or reporting requirements. We will retain your personal data for as long as you use our Website or for as long as necessary to fulfill the purposes for which it was collected and generally for a minimum period of seven years thereafter.  In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case it is no longer personal information.

You may exercise the following rights by contacting your usual EnTrust Global representative:

  • request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing
  • request rectification of your personal data
  • request the erasure of your personal data
  • request the restriction of processing of your personal data
  • object to the processing of your personal data
  • request the transfer of your personal data to another party (in a readable, “portable” format)

You also have the right to make a complaint at any time to data protection regulator.

If you do not provide us with certain information when requested, your use of the website may be limited.

We may update this Privacy Policy at any time by making the updated copy available on our Website.

Personal Information Rights for California Residents

The California Consumer Privacy Act (as amended, restated, modified and/or supplemented from time to time, including pursuant to the California Privacy Rights Act, the, “CCPA”) requires us to make certain additional disclosures and provides California residents with the ability to request additional information about their personal information. If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what EnTrust Global will do in response.

Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed pursuant to Gramm-Leach-Bliley Act (Public Law 106-102) and Fair Credit Reporting Act (12 CFR 1022).
If you are an individual who resides in California and whose personal information is collected and processed by EnTrust Global, you may have the right to:

  • Request that we disclose, free of charge, the categories and specifics of the personal information we collect about California residents, the sources from which the personal information was collected (and/or, if applicable, sell or otherwise disclose to a third party), and the business purpose for collecting personal information.
  • Choose to opt-out of the sale of personal information. Currently, however, EnTrust Global does not sell personal information.
  • Request that EnTrust Global delete the personal information it has collected. Following EnTrust Global’s verification of the request, it will comply with the request and delete any or all of the personal information in its possession that it collected from the California resident and/or any or all such personal information in the possession of its Service Providers, unless otherwise restricted by law or regulation.

Non-Discrimination for Exercising Your Personal Information Rights

EnTrust Global follows the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights set forth in this Privacy Policy.

Questions or Concerns and Exercising Your Data Subject Rights

If you have any questions or concerns regarding the information in this Privacy Policy, or would like to exercise any of your rights set forth in this Privacy Policy, please contact Bruce Kahne at (212) 224-5548 or toll free at (888) 812-5100 or by email at Please include a description of what right you want to exercise and the information to which your request relates. Please note that you may only make a disclosure request twice within a 12-month period.

If you choose to contact us with a request, you will need to provide us with identifying information that matches the personal information EnTrust Global currently has about you. For example, EnTrust Global may require identifying documents such as passport, utility bill or drivers license.

Authorized Agent

You have the right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please contact Bruce Kahne at the email address or phone number provided above.

Accessibility Information

For consumers with disabilities who need to access this Privacy Policy in an alternative format, please contact Bruce Kahne at the email address or phone number provided above

Changes to this Privacy Policy

From time to time we may update this Privacy Policy. If revisions are made to this Privacy Policy, we will update the statement with a new revision date.

This Privacy Policy was last revised and posted in January 2021.