CA Resident Fund Manager Privacy Policy

Notice for California residents

This section provides additional information pursuant to the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act, applicable to information concerning California residents that constitutes “personal information” and “sensitive personal information” under the CCPA. 

If you are a California resident and the personal data constitutes “personal information” or “sensitive personal information” under the California Consumer Privacy Act (as amended by the California Privacy Rights  Act), then Albourne may “sell” that personal data under the CCPA.

Albourne collects personal information about you in connection with Albourne’s diligence services for clients who are evaluating potential investment opportunities. Albourne will provide the information that is gathered on your behalf to those clients, sophisticated investors evaluating potential investments with your associated investment firm.

As described in this Notice above, if within the scope of the CCPA, such personal information includes:

  • your educational, professional and employment-related information, as well as inferences drawn from those;
  • your civil litigation and records of criminal proceedings; and
  • identifying information (such as a real name, aliases, postal address, email address, unique personal identifiers or other similar identifiers).

Where you have created a MoatSpace account with Albourne, we will collect your user name and password, and potentially your internet and electronic network activity information.

As part of its due diligence, Albourne collects much information from publicly-available sources.  In the event that sensitive personal information is provided directly to Albourne, these categories may include: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, data concerning health, and data concerning a natural person’s sex life or sexual orientation. Where Albourne collects your sensitive personal information, it is not for the purpose of inferring characteristics about you. Albourne will attempt to limit the inclusion of this type of personal information in its reports.

The purposes for which Albourne collects the above personal information and sensitive information are:

  • to assess your skills, qualifications and suitability to manage investments;
  • to conduct analysis during the due diligence process;
  • to maintain records relating to its fund selection process and investment advisory business;
  • to comply with contractual, legal and/or regulatory requirements; and
  • to provide investment advice and due diligence reports to clients. 

Albourne considers a number of factors in its evaluation of the retention period for your personal information. These include, but are not limited to, applicable law and policy that apply to the data. Albourne will not keep personal data for longer than necessary and will dispose of any such data securely. Albourne does not collect your personal information for purposes of cross-contextual behavioral advertising, as contemplated by the CCPA.

The third parties that Albourne provides your personal data to includes clients and prospective clients of Albourne, who are bound by certain confidentiality obligations to Albourne.  We may ask these clients to safeguard your personal data and to comply with all applicable laws and regulations regarding your personal data.

A California resident may have the following rights under the CCPA: the right to know what personal information Albourne has collected about you (including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about you), the right to delete personal information that the business has collected from you, the right to correct inaccurate personal information that a business maintains about you; the right to opt-out of the sale of personal information, and the right not to receive discriminatory treatment by Albourne for the exercise of privacy rights (including the right not to be retaliated against for the exercise of these rights).  

To make a request you may email us at or contact us through the webforms listed in Albourne’s privacy statement at:  In most cases, you will be required to provide your name and business contact information, including business email address so that we can verify your request, and in some cases additional information may be required.  A California resident may also have the right to direct us to not sell the resident’s personal information.  To make an opt-out request, please go to: “California Residents – Do Not Sell My Personal Info” via this link:

Under the CCPA, California residents may use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that demonstrates authorization to submit a request for the California consumer. An authorized agent must follow the process described above to make a request, and we will also (a) require the authorized agent to verify the agent’s own identity and (b) confirm the agent’s authority with the California consumer about whom the request was made.

This Website is not intended for minors under the age of 18.

You can access the Albourne Privacy Policy and Processing Notice (“Privacy Statement”) at: