This Privacy Policy sets forth the privacy practices of Caledonia US, LP (“Caledonia,” “we,” “our,” or “us”) with respect to our collection, use, sharing, and disclosure of Personal Information, including, but not limited to, Personal Information collected through this website (the “Site”), how it is used, and the circumstances under which it may be shared and disclosed. This Privacy Policy constitutes a legally binding agreement between you and Caledonia that conditions your use of the Site, where and as permitted by applicable law.
IF YOU ARE A CALIFORNIA RESIDENT, PLEASE READ OUR PRIVACY NOTICE FOR CALIFORNIA CONSUMERS BELOW.
Personal Information We Collect
When you visit the Site and during our ordinary business activities, Caledonia may collect or ask you to provide certain nonpublic personal information (“Personal Information”) in order to help us manage our relationship with you and serve your investment needs. The Personal Information we may collect from you may include personally identifiable information including names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under applicable law, that may be contained in the relevant materials, documents, or obtained through background searches.
Sources of Personal Information
We may collect Personal Information from:
Your communications with us;
Your transactions with us;
Your use of our website and mobile app
Services providers;
Affiliates;
Your agents and representatives;
Nonprofit organizations; and
Government entities and other governmental sources and records, and other publicly available information.
How We Use Personal Information
We use Personal Information for the following business purposes:
To provide our products and services;
To process your requests and inquires;
To offer new products and services;
To process transactions;
For account maintenance;
To confirm your identity;
To communicate with you;
To improve the Site;
To protect the security and integrity of the Site;
To prevent or investigate fraud or other unlawful activity, and detect security incidents; and
To comply with and enforce applicable legal requirements.
How We Share Personal Information
Your privacy is important to us. Caledonia does not disclose any Personal Information to nonaffiliated third parties, except to service or manage a client’s account or as permitted by law. We do not sell any Personal Information.
How We Protect Personal Information
Caledonia seeks to carefully safeguard Personal Information. We will use commercially reasonable efforts to ensure that Personal Information is kept secure and safe from any loss or unauthorized disclosure or use. We restrict access to our client’s Personal Information to employees requiring that Personal Information to provide our products or services.
Use of Cookies
We may send text files (e.g., “cookies” or other cached files) or images to your web browser to collect and/or store information on your computer. Such text files and images are used to support the operation of our digital offerings and for the technical convenience to store information on your computer. We may use information stored in such text files and images to customize your experience on our Site and to monitor use of our Site. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts or use all features of our Site. You can disable cookies from your computer system by following the instructions on your browser or at http://www.allaboutcookies.org/.
Notice for Residents of the European Economic Area and United Kingdom
Caledonia does not currently offer its products or services to natural persons resident in the European Union or the United Kingdom (“EEA/UK”) and, accordingly, is not required to comply with the EU General Data Protection Regulation (“GDPR”). Any personal data provided to us by you will be processed in the United States or other jurisdictions outside the EEA/UK which may not afford the same protections of personal data as under the GDPR.
You are responsible for the use and security of your password
The password-protected areas of the Site are established for investors and their representatives only. If you wish to access the password-protected areas of our website, you will need to apply for a password. If you apply for a password to access password-restricted areas on the Site, you must provide us with your name, mailing address, email address, phone number, investor affiliation and other relevant information, in addition to the information you have provided to us as an investor (if applicable).
You are responsible for all actions taken with your username and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your username or password to access or use any part of our Site. If your password has been compromised for any reason, you should contact us immediately for a new password.
On your request, we will deactivate your password and remove your contact information and financial information from our active databases. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy.
Contact Us
If you have any questions or comments about this Privacy Policy, please feel free to contact Caledonia at compliance@caledonia.com.au or 347-287-3760.
NOTICE TO RESIDENTS OF THE STATE OF CALIFORNIA
A resident of the State of California who has provided Personal Information to Caledonia, or regarding whom Caledonia has collected Personal Information, may have rights under the California Consumer Privacy Act of 2018 (“CCPA”), effective January 1, 2020. This section applies only to individuals who are residents of the State of California, United States of America.
CCPA – Collection and Use of Personal Information
Caledonia collects and uses Personal Information as set forth above for all clients, prospective clients, business partners and employees located within and without the State of California. Caledonia deems it to be reasonably necessary to collect such Personal Information in order to effectively operate its business or comply with applicable law. For example, we must collect Personal Information in order to comply with international Anti-Money Laundering/”Know Your Customer” standards, to comply with other applicable law, as well as its own related internal policies and procedures. Caledonia must also collect Personal Information in order to process financial transactions in connection with a fund or account managed by Caledonia, as well as to communicate with investors in such funds or accounts. Caledonia must also collect and process Personal Information in connection with internal systems administration and internal risk assessments. Finally, Caledonia must also collect Personal Information from employees in order to conduct standard due diligence on such employees and in connection with such employee’s compensation and tax obligations. As such, Caledonia collects, uses and retains such Personal Information in furtherance of legitimate business purposes.
Caledonia may disclose such Personal Information to third parties as set forth in “How We Use Personal Information” above. Such third parties may reside within and outside the State of California.
Safeguarding of Personal Information
Caledonia maintains established internal policies and procedures as well as physical and electronic safeguards that comply with applicable law, as well as industry standards, to safeguard access to Personal Information in our possession from accidental or unlawful destruction, loss, alteration, unauthorized use or disclosure. We endeavor to limit access to Personal Information about you to those employees, agents and other authorized parties who need to know the information to enable Caledonia to provide products or services to you.
Retention of Personal Information
Personal Information stored by Caledonia is generally retained for a period of ten years from (a) the date the data record was created or (b) a particular trigger event depending on the type of data record containing the Personal Information. Examples of trigger events are (i) the tax filing year in which an invoice for services received is paid, (ii) date of contract expiration or termination, and (iii) account closure or fund dissolution date.
Rights of Individuals Residing in the State of California
To the extent set forth in the CCPA, you may have certain rights relating to the collection and use of your Personal Information, including the right to (i) request specific and detailed information regarding the exact types of Personal Information collected and retained by Caledonia and specific and detailed information regarding the uses of such Personal Information and the third-parties to whom such Personal Information has been shared; (ii) delete any Personal Information retained by Caledonia; (iii) be notified of a breach of the security of your Personal Information within the timeframe set forth by the CCPA; (iv) correct inaccurate personal information that Caledonia has about you; (v) limit the use and disclosure of “sensitive personal information” (as defined in the CCPA) collected about you; (vi) the right to access and opt-out of information about automated decision making; and (vii) the right to ask organizations to transmit specific pieces of information to another entity, if technically feasible for the organization. The above rights are subject to any limitations or exceptions set forth in the CCPA, as amended. An individual may contact Caledonia at compliance@caledonia.com.au or 347-287-3760.
Sale of Personal Information
Caledonia does not sell to any third party, and as of the date of this Privacy Policy does not intend to sell to any third party, any Personal Information of any individual retained by or on behalf of Caledonia. Caledonia endeavors to notify all residents of the State of California about whom it retains Personal Information in the event that it intends to sell such Personal Information to a third party. Such notice will contain information regarding a California resident’s rights under the CCPA with respect to the sale of such resident’s Personal Information and be delivered to such individuals within a reasonable period of time to allow such individuals to exercise any such rights.
REPRESENTATIVE AGENT
To the extent you have any questions about this Privacy Policy, to request any information about the collection, use or retention of your Personal Information, or to exercise any rights you may have as a resident of an applicable jurisdiction, please contact Caledonia at compliance@caledonia.com.au or 347-287-3760.
USE OF THIS WEBSITE
This website is operated by, or on behalf of, Caledonia. Not all products and services listed on this website are available in all geographic areas. To the extent that access, distribution and/or use of this website would be deemed illegal by applicable law, such access, distribution and/or use of this website is prohibited.
LINKS TO OTHER WEBSITES
From time to time, the Caledonia website may contain links to other websites that are not controlled and/or maintained by Caledonia. Please be aware that these other websites may have different privacy policies which may subject you to different privacy practices. Please review the privacy policies of such other websites for information concerning what information is collected on such websites and how it is used.
CHANGES IN POLICY
This Privacy Policy applies to current and former Caledonia consumer customers, and in certain circumstances, to individual representatives of institutional customers. From time to time, Caledonia's Privacy Policy may change. Caledonia will post changes to the Privacy Policy on this website. Please review this Privacy Policy often so that you will remain abreast of Caledonia's current policies, including its policies concerning the gathering and use of information that may be collected on our website. You are responsible for making sure you are aware of the provisions of Caledonia’s most current Privacy Policy. This Privacy Policy was last updated in October 2025.
GOVERNING LAW
This Privacy Policy shall be governed by the laws of the State of New York of the United States of America, without regard to its conflict of law provisions. Any dispute concerning this Privacy Policy or your use of this website shall be submitted to binding arbitration in New York within one (1) year from the date that the cause of action arose (or, if multiple cause of actions are involved, from the date that the first cause of action arose), with such arbitration conducted pursuant to the then prevailing rules of the American Arbitration Association. To the fullest extent permitted by law, no arbitration brought pursuant hereto shall be joined to any other action or any other arbitration initiated pursuant hereto. In the event that any portion of this Privacy Policy is deemed unenforceable, unlawful or void by a Court of competent jurisdiction, in any jurisdiction for any reason because of the scope, duration or area of its applicability or for other reasons, unless narrowed by construction, such provision shall for purposes of such jurisdiction only, be construed as if such invalid, prohibited or unenforceable provision had been more narrowly drawn so as not to be invalid, prohibited or unenforceable (or if such language cannot be drawn narrowly enough, the court making any such determination shall have the power to modify, to the extent necessary to make such provision or provisions enforceable in such jurisdiction, such scope, duration or area or all of them, and such provision shall then be applicable in such modified form). If, notwithstanding the foregoing, any such provision would be held to be invalid, prohibited or unenforceable in any jurisdiction for any reason, such provision, as to such jurisdiction only, shall be ineffective to the extent of such invalidity, prohibition or unenforceability, without invalidating the remaining provisions. No narrowed construction, court-modification or invalidation of any provision shall affect the construction, validity or enforceability of such provision in any other jurisdiction. No waiver by Caledonia of any provision of this Privacy Policy shall be deemed a further or continuing waiver of such provision, and Caledonia’s failure to assert any right or demand compliance with any provision of this Privacy Policy shall not be deemed to constitute a waiver of any such right or provision. Furthermore, if any portion of this Privacy Policy is deemed unenforceable, unlawful or void by a Court of competent jurisdiction, then that portion of the Privacy Policy will be deemed severable and will not affect the enforceability or validity of the remaining portions of this Privacy Policy.
CONTACT US
If you have any questions or comments about this Privacy Policy, please feel free to contact Caledonia at compliance@caledonia.com.au or 347-287-3760.