Aquatic Technologies LLC and its affiliates (collectively, “Aquatic”) collects and processes Personal Data (defined below) about you from your use of this website and through other means, such as by contacting Aquatic directly by phone or email or more generally in the course of operating Aquatic business. This Privacy Notice explains how Aquatic collects Personal Data, how Aquatic uses your Personal Data and how you can assert your rights in accordance with applicable data protection laws. This Privacy Notice does not address Aquatic’s privacy practices with respect to any Personal Data Aquatic may collect from an investor in the funds that Aquatic sponsors or manages. Aquatic addresses these practices in separate notices to investors as required by law.

1. What is Personal Data and what Personal Data does Aquatic collect?

“Personal Data” is any information relating to you or that Aquatic can otherwise link to you or your household.

The Personal Data Aquatic collects on this website may include your name, email address, residential address, IP address, telephone number and other contact information. Some of this information Aquatic will only have access to if you provide it to us. When you visit the Aquatic website, Aquatic may collect information about you when you enter and browse the Aquatic website through the use of “cookies,” web server logs and other electronic tools. This information may include, without limitation, the number and frequency of your visits to the Aquatic website, the websites accessed before and after you visit the Aquatic website, the internet browser used by you and your IP address.

2. How does Aquatic collect Personal Data?

Aquatic collects Personal Data that you voluntarily provide to us, such as through “contact us” forms you choose to submit on the Aquatic website to obtain more information about Aquatic or its funds. Aquatic may also collect Personal Data through the use of “cookies” on the Aquatic website, in the ordinary course of evaluating service providers, vendors and investments, in marketing Aquatic funds or from publicly available or accessible directories, databases and agencies. Aquatic may combine personal information that you provide to us with information that Aquatic collects from or about you from publicly available sources. This will include information collected in an online or offline context.

In addition to Personal Data collected from your use of the Aquatic website, Aquatic may also collect Personal Data regarding Aquatic business contacts, partners, current and prospective investors, vendors and other contacts. Aquatic will collect some of this Personal Data if you contact the Aquatic office or employees directly.

3. How does Aquatic use your Personal Data?

Aquatic uses the Personal Data it collects for communication purposes, such as, but not limited to (i) sending you information about Aquatic and/or its investment funds and (ii) maintaining an Aquatic list of contacts. Aquatic uses the Personal Data Aquatic collects from you through other means for business purposes, such as, but not limited to (i) communicating with service providers and vendors, (ii) researching investment opportunities and (iii) managing Aquatic investments. No automated decision-making, including profiling, is used when processing your personal information.

4. Why does Aquatic process your Personal Data?

Aquatic processes your Personal Data collected from your use of this website for certain business reasons, including communication and marketing purposes. Aquatic processes your Personal Data collected by other means for other business reasons, including managing Aquatic business and Aquatic funds’ investments.

5. What legal basis does Aquatic use to process your Personal Data?

In accordance with the European Union’s General Data Protection Regulation (“GDPR”) and Cayman Islands Data Protection Law, Aquatic relies on Aquatic’s legitimate business interests (including, but not limited to, internal administrative purposes, direct marketing or conducting market research), contractual obligations, legal obligations or your consent in maintaining business relationships, communicating about Aquatic business and performing other business services as the basis for collecting and processing your Personal Data.

6. Is it necessary to provide Personal Data?

You are not required to submit information to us through this website. However, Aquatic may collect “cookies,” which may be automatically collected and will not necessarily require your consent. For Aquatic service providers, vendors, investors and other contacts, it is necessary to provide some Personal Data in order for us to do business with you.

7. With whom does Aquatic share your Personal Data?

Aquatic will not share your Personal Data with third parties except as permitted or required by law or regulation and to affiliates and service providers, including in the context of those third parties acting as data processors on Aquatic’s behalf and with whom Aquatic has a need to share such information. For example, Aquatic may use a customer relationship manager software platform to organize Aquatic’s business contacts, and your Personal Data may reside on that software. Where relevant, Aquatic will ensure that contractual safeguards are implemented with these third- party data processors to ensure the protection of your Personal Data.

Aquatic does not sell or transfer Personal Data to affiliates or third parties for value and does not intend to do so in the future. Aquatic will amend this Privacy Notice promptly upon any changes to this policy.

8. How long does Aquatic retain your Personal Data?

Your Personal Data will be retained for as long as you are one of Aquatic’s business contacts, or longer as required by applicable law. Your Personal Data may be deleted when it is no longer relevant or when you withdraw consent (pursuant to the rights detailed directly below which may be exercised by using the contact information contained at the end of this Privacy Notice), again within the parameters of applicable law. If Aquatic sends you emails and/or markets to you, you may unsubscribe at any time from communications from us, and Aquatic will cease sending you further communications.

9. What are my rights with respect to my Personal Data?

Your rights described in this Privacy Notice are applicable only if you reside in a jurisdiction where the provision of such rights is required by the data protection and privacy laws of the governing regulatory authority, as outlined further below. These rights may be limited and subject to further legal requirements.

California Consumer Privacy Act, 2020
  • The right to be informed about what Personal Data is being processed and the rationale for the processing;
  • The right to know whether and to whom your Personal Data is sold or disclosed and to opt out of the sale, if applicable;
  • The right to access (i.e. view or request copies of) your Personal Data that is being processed;
  • The right to request that Aquatic delete your Personal Data under certain circumstances; and
  • The right to not be discriminated against for exercising your rights under the California Consumer Privacy Act.
GDPR, 2018
  • The right to be informed about what Personal Data is being processed and the rationale for the processing;
  • The right to access (i.e. view or request copies of) your Personal Data that is being processed;
  • The right to request that Aquatic rectify Personal Data if it is inaccurate or out of date;
  • The right to request that Aquatic delete your Personal Data (the right to be “forgotten”) under certain circumstances;
  • The right to restrict processing your Personal Data if you contest its accuracy, the lawfulness of its processing or if Aquatic no longer needs it;
  • The right to object to the processing of your Personal Data if processing is based on Aquatic’s legitimate interests or for direct marketing purposes;
  • The right to be informed about and object to the existence of automated decision making, including profiling, and about its significance and consequences on you; and
  • The right to request a transfer of your Personal Data to a third party in certain circumstances.
Cayman Islands Data Protection Law, 2017
  • The right to be informed if your Personal Data is being processed and of the identity of the data controller and the purposes for which your Personal Data is being processed;
  • The right to access your Personal Data, including a description of the data, the purposes for which it is being processed and the recipients to which the Personal Data was disclosed;
  • The right to have your Personal Data, if inaccurate, be rectified, blocked, erased or destroyed;
  • The right to have the data controller cease processing your Personal Data, unless certain conditions are met;
  • The right to require that the data controller not take any action with your Personal Data as a result of automatic decision making;
  • The right to cease direct marketing; and
  • The right to receive compensation for damage as a result of the processing of your Personal Data.

Should you wish to lodge a complaint with regards to how your Personal Data has been processed by us, please contact the applicable supervisory authority which will vary based on jurisdiction, but generally include the following for individuals protected by the GDPR:, in the Cayman Islands by completing the form available at and contacting the Ombudsman at or by calling 345-946-6283 and for individuals protected by the CCPA can be reported to the Office of the Attorney General of California at or by calling 800-952- 5225.

10. Minors

This website and the services offered by Aquatic are not intended for minors and Aquatic does not knowingly collect Personal Data relating to minors and in the event of any inadvertent collection of Personal Data related to a minor, Aquatic expects to delete such Personal Data upon notice, but in any event, will comply with any provision of applicable data protection laws. The determination of whether an individual is a minor varies by jurisdiction, and may be as low as 13 years of age in some jurisdictions; however, Aquatic has determined to extend the protection afforded to minors to individuals less than 18 years of age.

11. What security does Aquatic have in place over your Personal Data?

Aquatic has implemented appropriate procedural and technical security measures to help protect your Personal Data against loss and to safeguard your Personal Data against access by unauthorized persons. Aquatic conside