Privacy Policy
Introduction
GP Fund Solutions and its (together, “GPFS,” “we,” “us” or “our”) understands that when you interact with us, including through our website, you may entrust us with your personal information. As a result, we have crafted this Privacy Policy (“Privacy Policy”) with you in mind, so that we can protect your personal information and inform you of your privacy rights. In this Privacy Policy, we explain our policies and procedures for data collection, use, maintenance, protection, and disclosure when you visit our website (the “Site”). This policy also governs and provides you with information concerning the data we collect from and concerning you when you interact with GPFS other than through our Site, for example when you contact one of our sales representative or technical support.
GPFS respects your privacy. Any information that can be used to identify you will be used only in accordance with this Policy. GPFS may share customer information with its subsidiaries, affiliates, and any agents.
We will update this Policy when we adjust our procedures to protect your information. Before these changes go into effect, we will post the updated Policy, along with an effective date for the new Policy. Once we alter the Policy, continued use of the Site, or continued interaction with GPFS other than through the Site, will be governed by the updated Policy.
About Your Use of this Site
Automatically Collected Information
Automatic Information Collection
As is customary for websites, the Site will collect information, including technical and routing information about your computer or device, without you being prompted. This may include geolocation data and Internet or other electronic network activity such as device identifiers and advertising identifiers. We use this information to optimize our Site for our users’ use. If, however, you choose to browse the Internet anonymously, we will not collect technical or routing information about your computer or device.
Cookies & Web Analytics
Our Site allows users to log in and provide certain personal information (for example, your name, the purchaser, or recipient’s name, mailing address, phone number or email address) in order to properly serve you as the customer in connection with the provision of fund administration and other services. In order to enable these and other login-based features, we use cookies to store session information for your convenience and ease of login. A cookie is a very small text file placed on your device by a web server to collect standard Internet log information and visitor behaviour information in an anonymous form. It is uniquely yours and can only be read by the server that gave it to you. The cookie that we place on your device will contain only an identifying number that we assign to you. It will contain no other personal information. Third party cookies may also be used.
Our Site uses Google Analytics. This helps us analyze data and improve our website, as well as tailor it to customer needs. Third parties may use cookies and similar technologies to collect or receive anonymous data to provide measurement Cookies are used to inform, optimize, and serve ads based on your previous visits to our website. You may opt out of Google’s use of cookies here, opt out of interest-based advertising here, or opt out of online behavioral advertising here.
You can find more detailed information on the terms and conditions of use and data protection at https://www.google.com/analytics/terms/us.html and at https://policies.google.com/?hl=en&gl=us.
Children Under the Age of 13
We do not knowingly collect information from children under the age of 13. Our Site is not directed at persons under the age of 13 and should not be used by them. In no event should children under the age of 13 provide any personal information through our Site. More information about the Children’s Online Privacy Protection Act (COPPA) and how it protects children who use the Internet may be found at www.ftc.gov.
About the Data We Collect Generally
Other Information We Collect
As part of our services, when you visit our Sites, our server automatically collects certain browser or device-generated information, including but not limited to: web requests, the data sent in response to such requests, the Internet Protocol address, the browser type, the browser language, and a timestamp for the request. We may de-identify and aggregate certain data we collect such that the data no longer identifies or can be linked to a particular visitor to our Site in order to analyse trends and make improvements to our websites to provide you with optimal online experiences with us.
If you apply for a job with us we may collect personal information in a number of circumstances. Personal information we may collect includes: name, address, telephone number and other contact information; educational or other credentials, employment history and experience, volunteer work, and other information necessary to evaluate a candidate’s suitability for employment; together with any other information we may collect with your consent or as required by applicable law.
Use of Personally Identifiable Information
We do not sell your personal information. We may use (and, where specified, share) your personal information for the following purposes:
Communication
When you contact us, we may use personal information (like your email address) to reply and provide you with the services or information you requested. For example, GPFS may send you promotional emails relating to GPFS, or communicate with you about your use of the Site. GPFS may also use technology to alert us via a confirmation email when you open an email from us. You can modify your email notification preferences by clicking the appropriate link included in the footer of email notifications. If you do not want to receive emails from GPFS, please opt out of receiving emails at the bottom of any GPFS emails. We also may use your personal information to collect feedback on our Site, services, and policies.
Employment
If you apply for a job with us, we will use personal information for the purposes of deciding whether to offer you employment with GPFS. GPFS may also use personal information for the purposes of statistical analysis. If you are offered employment with GPFS then GPFS will use your personal information and any further information you may provide in connection with that offer and (if applicable) your subsequent employment for the purposes of establishing and maintaining an employment relationship with you, including for personnel administration, payroll, and management purposes. If you are unsuccessful in your application for employment with us, we may keep your personal information on file for a reasonable period in order to evaluate your suitability for future employment opportunities. However, in those circumstances GPFS will remove your personal information from its systems if you request it to do so.
We may transfer personal information to outside agents or service providers (including affiliates acting in this capacity) who perform services on our behalf. Our service providers and affiliates may collect, use, disclose, store or process personal information on our behalf for the purposes described in this Policy, including storage of personal information on a central database accessible to human resources personnel within GPFS.
Site Improvement
We reserve the right to use your personal information and browsing behaviour to personalize our Site and improve the overall user experience. We also may use personal information to evaluate response rates or gauge the usability of the Site.
Protect Content
In order to stop malicious, deceptive, fraudulent or illegal activity from occurring on our Site, we may use identifying information to monitor users’ behaviour on the Site. Our attempts to prevent malicious, deceptive, fraudulent, or illegal Internet activity may cause some users to be suspended from the Site and its features.
Data Rights
Subject to applicable law, you may have certain rights with respect to your data.
EU/UK Data Rights
Where your personal information is processed in the context of our activities as a data controller in the United Kingdom, Guernsey or the European Union, you have the following statutory rights with regards to your Personal Data under the General Data Protection Regulation or equivalent (“GDPR”):
- you can request access to your personal information, including the provision of a copy of the personal information subject to processing (right of access according to Art. 15 GDPR);
- you can ask us to update or correct any inadequate, incomplete, or inaccurate data (right to rectification according to Art. 16 GDPR);
- you can request erasure of your personal information (right to erasure according to Art. 17 GDPR)
- you can restrict the processing of personal information (e.g. we may only store but not use your information while we assess your request for erasure – right to restriction according to Art. 18 GDPR);
- where processing is based on our legitimate interests including profiling, you have the right to object to the processing (right to object according to Art. 21 (1) GDPR);
- where we process your personal information for direct marketing purposes, you have the right to object to the processing at any time (right to object according to Art. 21 (2) GDPR);
- where processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal (right to withdrawal according to Art. 7 (3) GDPR);
- where processing is based on consent or on a contract, you have the right to data portability, meaning that you can ask us to provide your personal information in a structured, commonly used, and machine-readable format for your use or transfer to another controller (right to data portability according to Art. 20 GDPR).
If you wish to exercise any of the rights described above or you have any questions or concerns about how we treat your Personal Data, please contact us via these methods:
- Visit the GP Fund Solutions DSAR Portal page
- Send an email to
This email address is being protected from spambots. You need JavaScript enabled to view it. - Mail a letter to Data Privacy Officer, 12 Cornell Rd, 2nd Floor, Latham, NY 12110
We will respond to your request within one month of receipt, either to provide the information or confirm completion of the act requested or, in certain circumstances, to notify you of an extension of the time frame for response by a maximum of two further months.
Pursuant to Art. 21 of GDPR, you have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6 para. 1 letter e or f GDPR. We will discontinue the processing of your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or if the processing serves the purpose of the establishment, exercise, or defence of legal claims. To exercise this right, please contact us at the contact addresses indicated below.
UK Office:
GP Fund Solutions UK Limited
Attn: Privacy Officer
25 Wilton Road
Victoria, London SW1V 1LW
Ireland Office:
GP Fund Solutions Ireland Limited
Attn: Privacy Officer
Crescent House
Suite 2, 2nd Floor
Hartstonge Street
Limerick, Ireland V94 K35Y
Guernsey Office:
GP Fund Solutions Guernsey Limited
Attn: Privacy Officer
Kingsway House
Havilland Street
St. Peter Port
Guernsey
Channel Islands
GY1 2QE
If you believe that our processing of personal data concerning you is unlawful, you have the right to complain to the supervisory authority with jurisdiction over us, which you can contact as follows: for the United Kingdom, via the UK Information Commissioner’s Office, at https://ico.org.uk/concerns/, for the European Union, via the Irish Data Protection Commission at https://forms.dataprotection.ie/contact and for Guernsey, via the Office of the Data Protection Authority in Guernsey at https://www.odpa.gg/for-individuals/make-a-complaint/complaint-form/?nc=1.
Our Site and the servers and facilities that maintain the data we hold are operated in the United States and other countries outside of the European Union. As an international business, our use of information necessarily involves the transmission of personal information on an international basis. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be accessed, transferred to and processed in the United States. By using the Site, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable territories that have been deemed by the relevant jurisdiction to provide an adequate level of protection for personal data.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
California Data Rights
Residents of California may have the following rights with respect to their personal information, in certain circumstances:
- The right to know the categories and specific pieces of personal information we have collected about you in the last 12 months, the sources from which the personal information was collected, and the business purpose for collecting such information;
- The right to know whether and how we sell or disclose your personal information, to whom we sell or disclose your personal information and the categories of personal information sold or disclosed, and the business purpose for selling or disclosing your personal information;
- The right to request a copy of the specific pieces of personal information we have collected about you in the last 12 months;
- The right to request that we not sell your personal information;
- The right to request that we delete the personal information that we have collected from you, in certain circumstances; and
- The right not to receive discriminatory treatment for the exercise of your privacy rights.
Residents of California may make a request to exercise these rights by contacting us at
Upon receipt of a request to exercise your rights, we may request additional information in order to verify your identity. You may also be required to confirm your identity under relevant law or regulation. To the extent possible, we will utilize information already in our possession to verify your identity. Any information you provide in connection with such verification will be deleted as soon as practicable following your request and not used for any other purpose.
You may designate an authorized agent to make a request on your behalf. If you submit a request through an authorized agent, we may require that the authorized agent provide proof that the authorized agent has been authorized by you to act on your behalf and may still require you to verify your identity in accordance with the above and directly confirm that you provided the authorized agent with permission to submit the request.
You have the right to not be discriminated against for exercising any of your rights under CCPA. For example, GPFS will not deny you goods or services; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
California law permits consumers who are California residents to request and obtain from us once a year, free of charge, information about the personal information, if any, we disclosed to third parties for direct marketing purposes within the immediately preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information for these purposes within the immediately preceding calendar year.
If you are a California resident and would like to make such a request, please submit your request in writing to:
GP Fund Solutions, LLC
12 Cornell Road
2nd Floor
Latham, NY 12110
Attn: Data Privacy Officer
The chart below summarizes our practices in relation to your personal information over the preceding 12 months.
| Category of Information Collected | Source of Information | Purpose for Collection | Third Parties to whom Information is Disclosed and Specific Purpose for Disclosure |
|---|---|---|---|
| Identifiers, such as real name, postal address, unique personal identifier, online identifier, Internet Protocol address, e-mail address, account name or other similar identifiers | You, financial advisors, brokers, custodians, referral sources, contracts, and/or your use of our Site | To contact you; provide you with, services or information you request; to process your transactions; to maintain your account(s); or to make our services better | We disclose your information to service providers, such as mailing fulfillment vendors or Cloud services providers. We may also share your personal information with other service providers, such as investor services companies or professionals, like attorneys or accountants, where necessary for our business. We may share information about your transactions and experiences with our affiliates. |
| Other identifiers such as signature, telephone number, credit card number, or debit card number | You, financial advisors, brokers, custodians, referral sources, contracts, and/or your use of our Site | See above | See above |
| Investment information, including products or services obtained or considered and records of transactions | You, financial advisors, brokers, custodians, referral sources, contracts, and/or your use of our Site | See above | See above |
| Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the Site, an application, or advertisement | You and/or your use of our Site | See above | See above |
| Inferences we draw from any of the information identified above to create a profile about you reflecting your preferences | You, financial advisors, brokers, custodians, referral sources, contracts, and/or your use of our Site | See above | See above |
Information Disclosure
We may need to disclose your personal information occasionally. Most of our disclosures are necessary to complete a transaction or provide the information or service you have requested. In addition to this, we may disclose your information if needed to comply with a court order, law, legal proceeding, or request from the government. We also reserve the right to disclose your information if we have the reasonable belief that such disclosure is fundamental to the safety of individuals associated with GPFS or others unaffiliated with the company, or to report or investigate fraud or a crime.
We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to require that the transferee use personal information collected concerning consumers in a manner that is consistent with this Privacy Policy.
Security
GPFS considers the protection of personal information a high priority. To that end, we are SOC I Type II Certified and employ technical and organizational safeguards to protect the data you have provided to us against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.
Virus Protection
We use computer anti-virus software that is designed to detect and prevent computer viruses from entering our computer network system.
Firewalls
We use a specially programmed computer system that stands between GPFS and the Internet. It is a security measure used by many companies to prevent unauthorized access by individuals or computer networks.
Continual Monitoring
We continually monitor for attempts to bypass or penetrate beyond our security perimeter.
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.
Links to Other Websites
Our Site may contain links to other websites. However, once you have used such a link to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites and such sites are not governed by this Policy. You should exercise caution when visiting other sites and familiarize yourself with the privacy policy applicable to the website in question.
Contact Us
If you have any questions or concerns about this Policy, or how GPFS protects your personal information, please feel free to contact the Data Privacy Officer, at
Effective Date
This policy was last updated July 1, 2024.
