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Privacy Policy

Last updated: December 2024

Introduction

Samsara Management ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or engage with our services.

This policy complies with the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable privacy laws.

Information We Collect

Personal Information

  • Contact information (name, email address, phone number, mailing address)
  • Professional information (company, job title, industry)
  • Financial information (for qualified investors only, as required by law)
  • Communication preferences and interaction history

Technical Information

  • IP address, browser type, and operating system
  • Website usage data and analytics
  • Cookies and similar tracking technologies
  • Device identifiers and location data (with consent)

How We Use Your Information

  • To provide and improve our investment services
  • To communicate about investment opportunities (qualified investors only)
  • To comply with legal and regulatory requirements
  • To analyze website usage and improve user experience
  • To protect against fraud and ensure security
  • To send newsletters and market insights (with consent)

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

  • Consent: When you provide explicit consent for marketing communications
  • Contract: To perform our investment advisory services
  • Legal Obligation: To comply with financial regulations and reporting requirements
  • Legitimate Interest: For business operations, security, and website analytics

Information Sharing

We do not sell your personal information. We may share your data with:

  • Service providers and professional advisors (under strict confidentiality agreements)
  • Regulatory authorities as required by law
  • Portfolio companies (for qualified investors participating in investments)
  • Legal and compliance teams for regulatory purposes

International Data Transfers

As a global family office with operations in the US, UK, and Hong Kong, we may transfer your data internationally. All transfers are protected by appropriate safeguards including Standard Contractual Clauses and adequacy decisions where applicable.

Data Retention

We retain personal data for as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations, and resolve disputes. Investment-related records are retained in accordance with financial services regulations, typically 7-10 years after the relationship ends.

Your Privacy Rights

Depending on your location, you may have the following rights:

  • Access: Request copies of your personal data
  • Rectification: Correct inaccurate or incomplete data
  • Erasure: Request deletion of your data (subject to legal requirements)
  • Portability: Receive your data in a structured, machine-readable format
  • Restriction: Limit how we process your data
  • Objection: Object to processing based on legitimate interests
  • Withdraw Consent: Withdraw consent for marketing communications

To exercise these rights, contact us at privacy@samsaramanagement.com

Cookies and Tracking

We use cookies and similar technologies to enhance your browsing experience and analyze website usage:

  • Essential Cookies: Required for website functionality
  • Analytics Cookies: Help us understand how visitors use our site
  • Preference Cookies: Remember your settings and preferences

You can control cookies through your browser settings, though this may affect website functionality.

Data Security

We implement industry-standard security measures including encryption, access controls, and regular security assessments. However, no method of transmission over the internet is 100% secure. We continuously monitor and update our security practices to protect your information.

Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child, we will delete it promptly.

Policy Updates

We may update this Privacy Policy periodically to reflect changes in our practices or applicable laws. We will notify you of material changes by email or through our website. Your continued use of our services after such changes constitutes acceptance of the updated policy.

Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

Email: privacy@samsaramanagement.com

Phone: +1 (212) 555-1234

Address: 432 Park Avenue, 15th Floor, New York, NY 10016

For EU residents: You have the right to lodge a complaint with your local data protection authority.