Data Protection Privacy Policy

Moline Investment Management [MIM] | Moline Management, LLC is committed to protecting your privacy. This Privacy Policy (“Policy”) describes how we collect and use your personal data and the information we collect from you in the course of our regular business and through our website.

We encourage you to read this Policy carefully and contact us with any questions or concerns regarding our privacy practices. We reserve the right to update this policy based on changes in our business or regulations which may require an update to be made. You are encouraged to check this page www.molinemgt.com/privacy_policy from time to time for any revisions to this Policy.

Who We Are

When we refer to Moline Investment Management [MIM] | Moline Management, LLC or “we”/“us”/“our”, we mean Moline Management, LLC and our domestic and/or international affiliates. Our registered office is located at 205 West Walnut Street, Suite 200 Springfield, MO 65806. Contact details for any of our regional office locations may be found in the Contact section of our website at www.molinemgt.com.

The Information We Collect

“Personal data” is any information relating to an identified or identifiable natural person which we have in our possession or control. Examples of such information we collect include your name, job title, email address and telephone number.

In the course of our business, we do not collect “sensitive personal data”. Examples include racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning a natural person’s birth gender, associated gender and/or sexual orientation.

Information You Provide to Us Directly

We will process personal data that you provide to us when you email us or contact us regarding the following:

General Partner: If you are a fund manager (or other investment/advisory) client of MIM, you may provide us with personal data when you became, or in connection with becoming or continuing to be a partner or client of MIM.

Prospective or Current Investor/Limited Partner: If you are an investor or potential investor, you may provide us with personal data in connection with receiving information about our investment activities and/or current offerings.

Recruitment: if you apply for an employment opportunity with us you may provide us with personal data including your CV/resume, contact details and other details set out in your application.

Additional Circumstances Where We May Collect Personal Data

We may collect personal data when you use our website, invest with us, or provide services to us. We may also collect information that is available through one or more publicly available sources.

Cookies

A cookie is a text file that downloads to your hard drive, tablet or mobile device containing small amounts of information. The purpose of a ‘cookie’ is to create a better experience for the end user when visiting a particular website and to recognize you when you return to our site.  Cookies used on our website do not collect personal data and do not link the information collected to an individual. We may also obtain your IP address, browser information, user agent strings or other anonymous data sources. All data collected in this manner is anonymous and in aggregated form.

At any time you reserve the right to refuse the acceptance of cookies used on our website. You may exercise this right by adjusting the settings on your web browser. If you do not make this adjustment, our system will activate cookies when you access our website.

Data Retention Period and Security

Personal data may be kept for different periods of time based on the following varying criteria:

  • The length of time we have had a relationship with you
  • The types of services we provide to you
  • The purpose for and method by which we have collected your personal data
  • When you will cease having a relationship with us
  • The length of time that has been set or recommended by regulators or the law to demonstrate we have met all appropriate obligations
  • Any relevant proceedings that apply.

We take the security of your personal data seriously. We will maintain the appropriate level of security to ensure your data remains secure. We will not maintain personal data for a period longer than is necessary for any of the above reasons.

How We Use Personal Data

Personal Data we collect may be used in our daily business activities as follows:

  • To provide marketing, investment, advisory and fundraising services to our clients
  • As requested by legal and regulatory agencies in reference to our business activities
  • For internal audit requirements
  • Delivering investment and fundraising communications and business opportunities to our investor clients and potential clients
  • In the legitimate operation of our daily investment fundraising and advisory business
  • Internal research and business development
  • Website activity, performance, and usage
  • Job application review for recruitment and on-boarding procedures

Basis for Processing Your Personal Data

We process your personal data on the following legal basis:

  • While we do not necessarily need your consent to use your personal data, you may at any time withdraw consent by contacting us directly
  • In the course of doing business directly with us, we may need to process your personal data with respect to entering same into a contract or other agreement with you
  • We reserve the ability to use your personal data in connection with our legitimate business interests
  • We may from time to time be required to use your personal data in relation to compliance with a regulatory or legal obligation.

Sharing Your Personal Data

MIM maintains offices with which it may share your personal data for legitimate business purposes. We treat all personal data with the greatest respect to confidentiality. At no time will we share or release any personal data to an unaffiliated entity for the purpose of marketing.

Your Rights

You have legal rights with respect to your personal data we have in our possession. You may exercise these rights by contacting us at any time using the contact information listed below.

You have the following rights (certain exceptions apply):

  • The right to make a written request for details of your personal data and a copy of that personal information. Please note that there may be certain circumstances when we are entitled to refuse requests for access to copies of personal information
  • The right to have inaccurate information about you which we hold corrected or removed
  • The right to have certain personal information about you erased or “the right to be forgotten”. Please note, there are certain circumstances for legal or regulatory purposes that this request may not be granted
  • The right to request that your personal information is only used for restricted purposes or to object to it being used at all. Please note, there are certain circumstances for legal or regulatory purposes that this request may not be granted
  • The right to withdraw consent you have previously given us to process your personal data
  • The right to file a formal complaint with the authorities should you believe we have infringed on your rights

The above listed rights are not absolute and do not apply in all cases. Requests may be denied if such request would expose personal data regarding another subject or for other legal instances.

If you chose to exercise your rights, we may ask you to confirm your identity and to provide information that helps us to better understand your request. If we are unable to process your request, we will provide an explanation of same.

Getting in touch with us

If you would like to contact us with any queries or comment on this practice or our website, please contact us at:

Moline Investment Management [MIM] | Moline Management, LLC

Attention:  Data Privacy Officer

205 West Walnut Street, Suite 200

Springfield, MO 65806