Privacy Policy

Last updated Sept 2024. At Modality ("we," "us," or "our"), we are committed to ensuring the protection and confidentiality of your personal information. This Privacy Policy explains our practices regarding the collection, use, disclosure, and safeguarding of your personal information when you access our website, www.modalitymanagement.com. We encourage you to review this Privacy Policy carefully to understand our views and practices with respect to your personal data.

Information We Collect

We may collect and process various types of personal information, including:

• Personal Identification Information: Such as your name, email address, telephone number, and other contact details that you voluntarily provide to us.
• Usage Information: Information concerning your interactions with our website, including the pages visited, time spent on the website, and the navigation paths followed.
• Technical Data: Information including your IP address, browser type, operating system, and device details.
• Cookies and Tracking Data: Data collected through cookies and other tracking technologies to enhance and personalize your experience.

How We Collect Information

We collect your personal information in the following ways:

• Direct Interactions: We collect information directly from you when you fill out forms, subscribe to our newsletters, contact us, or provide information during any other direct interaction.
• Automated Technologies: We automatically collect certain information when you navigate through our website, employing cookies, server logs, and analytics tools.
• Third Parties: We may receive personal information from third parties if you engage with them via our website.

Purpose of Collecting Personal Data

The personal information we collect is used for various purposes, including:

• Provision of Services: To process transactions, fulfill orders, and respond to inquiries.
• Communication: To contact you regarding updates, services, or offers that may be of interest to you, subject to your prior consent where applicable.
• Website Improvement: To analyze user behavior and improve the functionality and user experience of our website.
• Legal Compliance: To comply with regulatory requirements and to respond to legal and administrative requests.

Legal Bases for Processing Personal Data

Our processing of personal information is conducted under several legal bases, including:

• Consent: Where you have provided explicit consent for specific purposes.
• Contractual Necessity: Where processing is required to provide the services you have requested.
• Legitimate Interest: To improve the quality of our services and deliver a better user experience.
• Legal Obligation: To comply with applicable legal and regulatory requirements.

Sharing Your Data

We may share your personal data with:

• Service Providers: We engage third-party service providers to assist in delivering our services, such as hosting, payment processing, and customer support.
• Business Transactions: In the event of a merger, acquisition, or other corporate transaction, personal data may be transferred as part of the transaction.
• Legal and Regulatory Authorities: We may also disclose personal data in response to lawful requests from regulatory bodies and authorities or to meet our legal obligations.

International Data Transfers

In certain instances, your data may be transferred to countries outside the European Economic Area (EEA). In such cases, we take all appropriate safeguards to protect your personal information, such as the use of Standard Contractual Clauses or other approved mechanisms to ensure adequate data protection.

Cookies and Tracking Technologies

We employ cookies to collect information regarding your browsing activities. Cookies facilitate improved website functionality, personalized experiences, and enhanced site performance.You may manage your cookie preferences by adjusting your browser settings at any time.

Data Security

We employ stringent administrative, technical, and physical security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Ensuring the confidentiality and integrity of your personal data is a priority for us, and we take all reasonable precautions to safeguard this information.

Retention of Personal Data

We retain your personal information only for as long as it is necessary for the purposes outlined in this Privacy Policy, as well as to comply with applicable legal, tax, and regulatory requirements. Once your data is no longer needed, it will be securely deleted or anonymized in accordance with our data retention practices.

Your Data Protection Rights

You have certain rights regarding the personal data we process, including:

• Access: The right to request access to the personal information we hold about you.
• Correction: The right to request the rectification of inaccurate or incomplete information.
• Deletion: The right to request the deletion of your personal data under certain circumstances.
• Restriction of Processing: The right to request the restriction of processing of your personal data.
• Data Portability: The right to receive a copy of your data in a structured, machine-readable format.
• Objection: The right to object to the processing of your data based on our legitimate interests.
• Withdrawal of Consent: Where we rely on your consent to process your data, you have the right to withdraw your consent at any time.

Should you wish to exercise any of these rights, please contact us at the contact information provided below.

Third-Party Websites

Our website may contain links to third-party websites. This Privacy Policy does not apply to those external websites, and we recommend that you review the privacy policies of any third-party sites that you visit.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal obligations, or other operational needs. Any amendments will be posted on this page, accompanied by an updated "Last Updated" date. We recommend that you review this Privacy Policy regularly to stay informed of any changes.

Contact Us

If you have any questions regarding this Privacy Policy or wish to exercise your data protection rights, please contact us at: info@modalitymanagement.com

Disclosures

The content provided on this website is intended solely for informational purposes and should not be construed as an offer to sell, a solicitation to buy, or a recommendation for any financial products or services. The information presented is subject to change without notice and does not constitute investment, legal, or tax advice. This website is intended for professional investors, institutional clients, and other qualifying individuals under applicable law.

The information on this website is not intended as an offer or solicitation to buy or sell securities, products, or services. Any offer of securities will be made exclusively through a formal prospectus or offering memorandum, and access to such materials may be restricted to qualifying investors who meet specific suitability criteria. Investments may only be made on the basis of the relevant offering document, which contains detailed information on the terms of the investment, risks, fees, and conditions for redemption.

MODALITY MANAGEMENT Sàrl does not actively market or promote its investment services to the public. The information presented on this website is for informational purposes only and is not intended to solicit, advertise, or market any financial services or products. Access to our services is limited to qualified individuals and entities who meet specific eligibility requirements under applicable laws and regulations. 

Performance data represents historical performance and should not be viewed as an indication of future results. Past performan Any forward-looking statements provided are based on the beliefs, expectations, and assumptions of the investment manager as of the time of publication. These statements are subject to risks, uncertainties, and changing market conditions. MODALITY MANAGEMENT Sàrl does not make any representations that forward-looking statements will materialize or that performance objectives will be achieved.

Depending on the investment strategy pursued, specific risks may apply, including liquidity risk, market risk, currency risk, credit risk, and counterparty risk. Leveraged strategies may increase the level of volatility and the risk of loss. Investing in emerging markets carries additional risks, including economic instability, political turmoil, and less regulatory oversight. Derivatives carry particular risks, including valuation, counterparty, and liquidity risk. Investors must consider these risks carefully and consult with their advisors to determine if such investments align with their individual risk tolerance.

This website may contain links to external third-party websites for informational purposes only. MODALITY MANAGEMENT Sàrl does not endorse, approve, or guarantee the accuracy of the information provided on these third-party sites. The company has no control over the content of external sites and accepts no responsibility for any loss or damage resulting from the use of, or reliance on, information contained therein. Accessing third-party links is at the user’s own risk.

All materials on this website, including text, graphics, images, and software, are the property of MODALITY MANAGEMENT Sàrl or used under appropriate licenses. These materials are protected under copyright, trademark, and other intellectual property laws. Unauthorized reproduction, redistribution, or use of any part of the website is strictly prohibited. Users agree not to exploit, modify, distribute, or store any part of this website for commercial purposes without prior written consent.

MODALITY MANAGEMENT Sàrl does not provide tax or legal advice. Investors should be aware that tax treatment depends on individual circumstances and may be subject to changes in law. Any reference to tax matters is provided solely for general informational purposes. Investors are encouraged to consult their own tax advisors to ensure their specific tax needs are met.

MODALITY MANAGEMENT Sàrl may engage in activities that could create conflicts of interest, including managing multiple accounts with similar investment strategies, conducting transactions on behalf of related entities, or receiving compensation from third parties. We maintain policies and procedures designed to identify and manage such conflicts of interest in a fair and transparent manner. Details of our conflicts of interest policy are available upon request.

To the maximum extent permitted by applicable law, MODALITY MANAGEMENT Sàrl and its affiliates disclaim all warranties, either express or implied, regarding the accuracy, completeness, or suitability of the content on this website. Under no circumstances shall MODALITY MANAGEMENT Sàrl or its affiliates be liable for any direct, indirect, incidental, special, or consequential damages, including, but not limited to, loss of profits, business interruption, or data loss resulting from the use of, or inability to use, this website or any linked content.

Your use of this website is subject to our Privacy Policy, which explains how we collect, use, and protect personal information. By accessing this website, you consent to the collection and use of your information as described in our Privacy Policy. MODALITY MANAGEMENT Sàrl is committed to compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

These disclosures may be updated or modified from time to time without prior notice. Users are encouraged to review this section periodically to ensure that they understand the current terms and conditions governing the use of this website. Continued use of the website after changes to these disclosures constitutes acceptance of the revised terms.

SFDR

The European Commission’s Sustainable Action Plan has three objectives: (1) To reorient capital flows towards sustainable investment in order to achieve sustainable and inclusive growth; (2) To manage financial risks stemming from climate change, environmental degradation, and social issues; and (3) To foster transparency and long-termism in financial and economic activity. It is a response to recommendations from the high-level expert group on sustainable finance, which were submitted to the Commission in January 2018.

Already, the European Parliament has adopted an amendment to Regulation 2016/1011 to introduce a framework for EU climate transition and EU Paris-aligned benchmarks, an amendment to the Delegated Regulation 2017/565 to integrate environmental, social, and governance (ESG) considerations into investment advice and portfolio management, and an amendment to Delegated Regulation (EU) 2017/2359 to integrate ESG considerations and preferences into the investment advice for insurance-based investment products. It has also prepared a series of related reports, including an EU Taxonomy Regulation, benchmarks, EU green bond standard, and climate-related disclosures.

SFDR which is part of a broader legislative package under the European Commission’s Sustainable Action Plan, came into effect on 10 March 2021. To meet the SFDR disclosure requirements, MODALITY MANAGEMENT Sàrl identifies, assesses and, where possible and appropriate, seeks to manage sustainability risks for the Partnership as part of its risk management process. MODALITY MANAGEMENT Sàrl believes that the integration of this risk analysis could help to enhance the long-term value of the portfolio for Investors, in accordance with the investment objective and Investment Policy of the Partnership. However, due to the nature of the investment objective, sustainability risks are not integrated in the investment decisions.

For the avoidance of doubt, the Partnership is not promoting environmental or social characteristics within the meaning of article 8 of SFDR nor has sustainable investment as its objective within the meaning of article 9 of SFDR. For the purposes of Article 6 of the EU Taxonomy Regulation, MODALITY MANAGEMENT Sàrl confirms that the investments underlying this financial product (i.e. the Partnership) do not take into account the EU criteria for environmentally sustainable economic activities.